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Silcotub

Company · Romania

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
1
legislative file
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

Silcotub filed 2 positions between 11 Sept 2025 and 19 Sept 2025, across 1 of the 665 legislative files tracked here.

What they argued

Objection pursuant to Rule 115(2) and (3) of the Rules of Procedure on the draft Commission Implementing Regulation laying down rules for the application of Regulation (EU) 2023/956 of the European Parliament and the Council as regards the methods for the calculation of emissions embedded in goodsfiled 19 Sept 2025source

1. As regards the deadline for submitting the CBAM annual declaration, we consider it essential to allow sufficient time for the collection of verified declarations from suppliers. Given the time needed to collect the primary data, prepare the CBAM declaration and carry out the external verification, we consider that a period of five months (until 31 May as currently defined by the Regulation) is too short…

Filed in Romanian · English published by the European Commission

Objection pursuant to Rule 115(2) and (3) of the Rules of Procedure on the draft Commission Implementing Regulation laying down rules for the application of Regulation (EU) 2023/956 of the European Parliament and the Council as regards the methods for the calculation of emissions embedded in goodsfiled 11 Sept 2025source

Please provide proper importance on ensuring a four-month window for the CBAM reporting process. The realistic timeframe, based on real processes, the CBAM declaration for the year 2026 should be submitted via the platform by April 2027, with the corresponding CBAM tax payment due by June 2027.

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