UNFAIR POSITION OF EU IMPORTERS IN RESPECT OF THE USE OF ACTUAL EMISSION VALUES EU importers have many different sources of supply of CBAM goods from third countries. The number of installations in third countries that should be verified by accredited CBAM verifiers is very large.
KDD
KOVINTRADE D.D. CELJE
Company · Slovenia
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.
2
positions filed
in the 665 files tracked
2
legislative files
of 665 tracked
0
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
KOVINTRADE D.D. CELJE filed 2 positions on 25 Sept 2025, across 2 of the 665 legislative files tracked here.
What they argued
UNFAIR POSITION OF EU IMPORTERS IN RESPECT OF EMISSIONS PRICE We would like to point out to the Commission that in 2026, EU importers will be in a worse position than EU producers included withing the scope of EU ETS (hereinafter referred to as EU ETS producers).
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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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