TCM

Turkish Cement Manufacturers' Association

NGO · 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 (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.

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Their record over time

Turkish Cement Manufacturers' Association filed 3 positions on 23 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 23 Sept 2025source

This initiative will establish rules for converting the carbon price paid in a third country for declared embedded emissions into a corresponding number of CBAM certificates. These rules will take into account any form of compensation or support mechanisms available in the third country that effectively reduce the carbon price.

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 23 Sept 2025source

This initiative will establish the methodology to be applied during the definitive period of the CBAM, starting on 1 January 2026. The methodology will include the following components: The determination of direct embedded emissions based on actual emissions data The determination of embedded emissions from electricity The determination of indirect embedded emissions The use of default values for goods other than…

Adjustment of the obligation to surrender CBAM certificates to take account of ETS free allowances phase-outfiled 23 Sept 2025source

This initiative outlines detailed rules governing the adjustment of CBAM certificates to be surrendered by authorised CBAM declarants, in order to reflect the extent to which allowances under the EU Emissions Trading System (EU ETS) are allocated free of charge. These rules should be aligned with the principles of the EU ETS, taking into consideration the various EU ETS benchmarks used for free allocation.

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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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