Executive summary (detailed response in the attachment) 1. Clarification Needed on the Treatment of Fuel Based Carbon Taxes The proposed Annex 3.3.3 outlines a fuel based carbon tax algorithm which requires an emission factor for the fuel.
SSE
SSE
Company · United Kingdom · EU Transparency Register 901176348730-75
2
positions filed
in the 326 files tracked
1
legislative file
of 326 tracked
2
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 326 consultation files tracked so far (29,503 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 925 companies & groups on this site, they rank #556 by legislative files engaged — a count of participation, not a measure of influence.
1.5
declared lobbying FTE
self-declared
€100K+
declared costs / yr (floor)
1
EP accreditations
as declared to the register
2023
in the register since
Declares membership of
- Eurelectric →
- Windeurope →
- OCEAN coalition
- EU Energy Forum
- IATA →
- EU-British Chamber of commerce
Self-declared to the EU Transparency Register (snapshot 30 Aug 2026).
- Register category
- Companies & groups
- Head office
- Perth, United kingdom
- EU office
- London
Self-declared to the EU Transparency Register (snapshot 30 Aug 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
SSE filed 2 positions between 23 Sept 2025 and 9 Jun 2026, across 1 of the 326 legislative files tracked here, attaching a full position paper 2 times.
2025 · 1 filed2026 · 1 filed
What they argued
SSE is a leading energy provider headquartered in UK and operating in multiple EU countries. Emissions factor for electricity Electricity differs from the other goods in CBAMs scope, as electricity is an interconnected networked system where electrons cannot be easily traced and are traded anonymously.
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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.