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TCO

Third Country Operator

Company · Turkey

3
positions filed
in the 326 files tracked
3
legislative files
of 326 tracked
0
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.

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Their record over time

Third Country Operator filed 3 positions on 25 Sept 2025, across 3 of the 326 legislative files tracked here.

What they argued

Carbon price paid in a third country under the carbon border adjustment mechanism (CBAM)filed 25 Sept 2025source

Ensuring fair recognition of carbon pricing instruments applied in third countries is essential both for WTO compatibility and for maintaining international legitimacy of the CBAM framework. As most jurisdictions levy carbon costs at the installation level, the regulation must establish a harmonised methodology to allocate such costs to individual CBAM-covered commodities.

Carbon border adjustment mechanism (CBAM) methodology for the definitive periodfiled 25 Sept 2025source

For the use of actual emissions data, the definitive CBAM methodology should provide a detailed explanation of how verification will operate. In particular, it must set out the local-based conditions under which verified data can be accepted, ensuring clarity on how verification requirements are applied at the installation and operator level in each jurisdiction.

Adjustment of the obligation to surrender CBAM certificates to take account of ETS free allowances phase-outfiled 25 Sept 2025source

The interaction between CBAM certificates and the phase-out of free allowances under the EU ETS must be designed with clarity and precision to avoid market distortions and administrative complexity. The Commission should clarify whether adjustments for free allowances will be applied at the level of aggregated product groups or at the level of individual CN-code commodities, since this choice will determine the…

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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.

Showing 5 of 103.

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Everything on this page comes from Third Country Operator’s own submissions to the European Commission — we have added nothing and interpreted nothing. If something is wrong or out of date, email info@policyspeak.com and we will correct it. If you are an individual named in a record, our privacy policy sets out your rights to correction, objection and removal.

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.