It appears that the current formulation places sole emphasis on the size of the company when determining the scope of obligations. However, it is important to clarify whether this was the intended approach. It seems disproportionate that a large company, placing only a limited number of primary batteries in one of its products, would be required to comply with the full range of obligations.
CA
Celltech AB
Company · Sweden
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.
2
positions filed
in the 639 files tracked
2
legislative files
of 639 tracked
0
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 639 consultation files tracked so far (53,766 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
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Their record over time
Celltech AB filed 2 positions on 12 Jun 2025, across 2 of the 639 legislative files tracked here.
What they argued
The current approach appears to base the applicability of obligations solely on the size of the company. It would be helpful to clarify whether this was the intended outcome. Requiring a large company to comply fully with all regulatory obligationseven in cases where it places only a minimal number of primary batteries in a productmay lead to disproportionate administrative and compliance burdens.
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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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