Industry association · Germany · EU Transparency Register 185689791629-60
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.
Among the 1205 trade and business associations on this site, they rank #347 by legislative files engaged — a count of participation, not a measure of influence.
Self-declared to the EU Transparency Register (snapshot 30 Aug 2026).
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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Bundesverband Großhandel, Außenhandel, Dienstleistungen filed 6 positions between 26 Aug 2025 and 31 Jul 2026, across 4 of the 326 legislative files tracked here, attaching a full position paper 6 times.
In principle, we support the objective of the IAA. However, there are significant risks in the current set-up: increasing bureaucracy and costs, additional burdens especially for SMEs, higher input prices, and restrictions on global supply chains. Local content requirements can weaken functioning procurement structures and undermine international competitiveness.
Filed in German · English published by the European Commission
The Bundesverband Großhandel, Foreign Trade, Services e.V. (BGA) is enclosed with its opinion on the initiative to accelerate the transition to zero-emission corporate fleets. In the BGA’s view, the initiative is in principle a correct step towards achieving the European climate targets. However, the proposed measures cannot be implemented in the given context and should therefore be reviewed and adapted.
Filed in German · English published by the European Commission
Please find enclosed the opinion of the Bundesverband Großhandel, Foreign Trade, Services e.V. (BGA) on the initiative to accelerate the transition to zero-emission corporate fleets. In the BGA’s view, the initiative is in principle a correct step towards achieving the European climate targets. However, the proposed measures cannot be implemented in the given context and should therefore be reviewed and adapted.
Filed in German · English published by the European Commission
The Bundesverband Großhandel, Foreign Trade and Services (BGA) has long been critical of the CBAM and strongly opposes its planned extension to downstream products, the introduction of additional circumvention measures and the inclusion of electricity emissions in its scope.
Filed in German · English published by the European Commission
We support a level playing field and effective measures against carbon leakage. However, the mechanism must not be designed in such a way as to impose a disproportionate burden on small and medium-sized importers, to commit capital and to generate significant additional bureaucracy without creating additional climate benefits.
Filed in German · English published by the European Commission
The Federation of German Wholesale, Foreign Trade and Services (BGA) represents companies from the German wholesale, foreign trade and business services sectors. Our members account for a substantial share of Germany's imports and exports and include numerous companies already directly affected by the Carbon Border Adjustment Mechanism (CBAM), as well as many that will become subject to CBAM as its scope expands.
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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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