Ternium (a Latin American steel producer) sends its concerns and commments about the draft regulation rules for converting into a corresponding number of carbon border adjustment mechanism certificates the carbon price paid in a third country for declared embedded emissions, taking into account any form of compensation available in that country resulting in a reduction of the price.
TER
Ternium
Company · BRA
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
2
legislative files
of 665 tracked
3
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
Ternium filed 3 positions between 23 Sept 2025 and 10 Jun 2026, across 2 of the 665 legislative files tracked here, attaching a full position paper 3 times.
2025 · 2 filed2026 · 1 filed
What they argued
As a steel producer outside the EU, we understand that the emissions intensity calculations using CBAM methodology (Guidance document on CBAM implementation for installation operators outside the EU and Commission Implementing Regulation (EU) 20231773) require improvements and clearer resolutions for typical and complex activities involving the iron and steel production sector, especially for integrated plants on…
As a steel producer outside the EU, we understand that the emissions intensity calculations using CBAM methodology (Guidance document on CBAM implementation for installation operators outside the EU and Commission Implementing Regulation (EU) 20231773) require improvements and clearer resolutions for typical and complex activities involving the iron and steel production sector, especially for integrated plants on…
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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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