TCO

Third Country Operator

Company · Turkey

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.

positions filed

in the 665 files tracked

legislative files

of 665 tracked

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 (57,800 submissions, mostly 2021–26), 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 665 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.

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 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.