From today's perspective, the design of the CBAM still has serious gaps that significantly reduce the effectiveness of the instrument and therefore need to be closed immediately. CBAM is unsuitable for ensuring the competitiveness of European metalprocessing companies with an export focused business model becasue there is no coverage of finished goods (downstream goods) garanuteed, comes with high administrative…
JBG
Julius Blum GmbH
Company · Austria
not in the EU Transparency RegisterThis organization files on consultations without a register number, so its record here is built from its filings alone. Register facts (staff, costs, accreditations) are not available for it.
4
positions filed
in the 665 files tracked
4
legislative files
of 665 tracked
4
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
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Their record over time
Julius Blum GmbH filed 4 positions between 22 Aug 2025 and 25 Sept 2025, across 4 of the 665 legislative files tracked here, attaching a full position paper 4 times.
What they argued
Clear and transparent rules should be laid down on how carbon prices paid in third countries are converted into CBAM certificates. Predictability is particularly important so that companies can reliably calculate their cost planning, procurement decisions and mitigation strategies. In that regard, responsibility for such credit must be clearly defined.
Filed in German · English published by the European Commission
We welcome the Commission’s efforts to standardise and communicate in a transparent manner the determination of direct and indirect embedded emissions and the use of default values. Otherwise, different interpretations and measurement approaches lead to biases and a lack of comparability of data.
Filed in German · English published by the European Commission
We stress that the treatment of free allocations under the EU Emissions Trading System (ETS) for CBAM allowances must be fair, transparent and not distortive. Therefore, we strongly recommend that the rules avoid a double burden on carbon costs and provide for a sector-specific methodology to ensure a level playing field. At the same time, there is great concern about the lack of benchmarks for CBAM as of 2026.
Filed in German · English published by the European Commission
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers, not evidence of coordination, and we do not suggest any.
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