Regarding the carbon price paid in a third country, we hope the following aspects can be clarified: 1. Clarify the method for apportioning the carbon price at the third-country organization level to the product level: Most countries levy carbon prices based on installation-level emissions.
SCD
Shanghai E-Carbon Digital Technology Co., Ltd
Company · CHN
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.
11
positions filed
in the 665 files tracked
3
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
Shanghai E-Carbon Digital Technology Co., Ltd filed 11 positions between 4 Sept 2025 and 23 Sept 2025, across 3 of the 665 legislative files tracked here.
What they argued
If other self-produced heat and electricity are input into the on-site self-produced heat and power process, should the emissions corresponding to the other self-produced heat/electricity be calculated? There are two examples: if there is a heat production process A in the facility, whose product is Heat 1, and a heat production process B, whose product is Heat 2, and if Heat 2 is input into heat production process…
If other self-produced heat and electricity are input into the on-site self-produced heat and power process, should the emissions corresponding to the other self-produced heat/electricity be calculated? There are two examples: If there is a heat production process A in the facility, whose product is Heat 1, and a heat production process B, whose product is Heat 2, and if Heat 2 is input into heat production process…
If other self-produced heat and electricity are input into the on-site self-produced heat and power process, should the emissions corresponding to the other self-produced heat/electricity be calculated? There are two examples: If there is a heat production process A in the facility, whose product is Heat 1, and a heat production process B, whose product is Heat 2, and if Heat 2 is input into heat production process…
If other self-produced heat and electricity are input into the on-site self-produced heat and power process, should the emissions corresponding to the other self-produced heat/electricity be calculated? There are two examples: If there is a heat production process A in the facility, whose product is Heat 1, and a heat production process B, whose product is Heat 2, and if Heat 2 is input into heat production process…
If other self-produced heat and electricity are input into the on-site self-produced heat and power process, should the emissions corresponding to the other self-produced heat/electricity be calculated? There are two examples: If there is a heat production process A in the facility, whose product is Heat 1, and a heat production process B, whose product is Heat 2, and if Heat 2 is input into heat production process…
If other self-produced heat and electricity are input into the on-site self-produced heat and power process, should the emissions corresponding to the other self-produced heat/electricity be calculated? There are two examples: If there is a heat production process A in the facility, whose product is Heat 1, and a heat production process B, whose product is Heat 2, and if Heat 2 is input into heat production process…
Regarding the calculation of heat and electricity, we have the following question: If other self-produced heat and electricity are input into the on-site self-produced heat and power process, should the emissions corresponding to the other self-produced heat/electricity be calculated?
The following aspects of the CBAM methodology remain unclear in practical implementation: 1. Clarify the calculation method for source flows in the production process and installation level: If an installation contains both balance-based and standard-based production processes, should the materials be calculated separately based on the production process method (balance-based and standard-based) when determining…
The following aspects of the CBAM methodology remain unclear in practical implementation: 1. Clarify the specific content included in the boundaries of production processes: Currently, the definition of the boundaries for each production process is not clear enough.
Regarding free allowances, we hope the following aspects can be clarified: 1. Clarify the granularity of free allowances: Specify whether free allowances are allocated to aggregated goods category or to individual CN code products, as this will inversely affect the granularity of production process division. 2.
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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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Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.