The Carbon Border Adjustment Mechanism (CBAM) can only achieve its objectives if reported emissions are accurate, fair, and resistant to circumvention. We see three key challenges: (1) reliance on facility-level averages instead of product-level reporting, (2) the lack of clear rules for traders and distributors including origin verification, (3) the need to account for supply chain variability in downstream…
SSG
S1Seven 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.
3
positions filed
in the 665 files tracked
3
legislative files
of 665 tracked
2
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
S1Seven Gmbh filed 3 positions between 10 Dec 2024 and 27 May 2026, across 3 of the 665 legislative files tracked here, attaching a full position paper 2 times.
2024 · 1 filed2025 · 1 filed2026 · 1 filed
What they argued
S1Seven welcomes the draft Implementing Regulation as a necessary step toward operationalising the Digital Product Passport. The attached response sets out ten specific concerns and recommendations, informed by the FprEN 1821618246 standards developed under JTC 24 and by sectoral experience with intermediate steel DPPs.
S1Seven has developed Digital Material Passport, a platform for exchanging material data across chemicals, metals, and wood industries. Our recommendations stem from extensive experience in the steel industry, which encompasses approximately 500 manufacturers, 3,000 distributors, and 500,000 EU companies that create steel products: 1.
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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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