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Consultation participation and their own register declarations, side by side. Counts, not judgments — participation is not influence.

Counts here are a floor, never a total: they cover the 583 consultation files tracked so far (42,224 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.

AR
ADC3R

Industry association · France

2
files engaged
of 583 tracked
2
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
AEH
26
files engaged
of 583 tracked
29
positions filed
in those 583 files
7.1
declared FTE
self-declared
3
EP accreditations
as declared to the register

Declared costs: €200K+ a year · in the register since 2012

Files both filed on (2)

Fluorinated gases regulation · Minimum requirements for certification programmes and training attestations for RACHP equipment

Register facts self-declared (snapshot 2 Sept 2026); cost bands are floors. Shared files are shared attention, not evidence of coordination.

What each said, in their own words

Their opening passages on the files they share, verbatim and in filing order. We do not summarize, compare, or characterize positions — read them at source.

Fluorinated gases regulation

Association of the European Heating Industry (EHI) · filed 2 Sept 2020 · source

Please find our comments attached. About the European Heating Industry The European heating industry brings together companies that are leaders in the production of efficient heating systems. Our members produce advanced technologies for heating in buildings, including: heating systems, boilers, heat pumps, burners, components and system integrators, radiators, surface heating & cooling.

ADC3R · filed 29 Jun 2022 · source

Founded in 2013, ADC3R members are key players in the distribution, collecting and treatment of refrigerants in Europe. We fully support the F-Gas review as well as other related EU climate change and decarbonisation initiatives, such as Green Deal, Fit for 55 and most recently REpowerEU.

Association of the European Heating Industry (EHI) · filed 29 Jun 2022 · source

Dear Madam, dear Sir, Please find our contribution attached. Our general messages: - EHI is committed to reduce CO2 emissions from heating appliances, including from fluorinated gases used in our heat pumps. - The hydrofluorocarbons (HFCs) phase down needs to consider the projected growth in REPowerEU of the heat pump market and the need for servicing and maintenance.

Minimum requirements for certification programmes and training attestations for RACHP equipment

ADC3R · filed 10 Jun 2024 · source

ADC3R has summarised in the attached file some points that need to be adjusted, in particular the scope and particularities of the categories of professional qualifications. Regulation (EU) 2024/573 (Art. 2 ) applies : (a) fluorinated greenhouse gases listed in Annexes I, II and III, whether alone or in mixtures; and b) products and equipment and parts thereof containing, or whose functioning relies upon…

Association of the European Heating Industry (EHI) · filed 10 Jun 2024 · source

The European Heating Industry (EHI) thanks the European Commission for preparing this draft implementing act that will update the certification requirements, in line with F-Gas Regulation (EU) 2024/573. We agree that an update is needed to include non f-gas alternatives (hydrocarbons, ammonia, CO2).

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