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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.

ASS
Aena SME, SA

Company · Spain

2
files engaged
of 583 tracked
2
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
VDM
VDMA

Industry association · Germany

41
files engaged
of 583 tracked
53
positions filed
in those 583 files
14
declared FTE
self-declared
4
EP accreditations
as declared to the register

Declared costs: €2.5M+ a year · in the register since 2008

Files both filed on (2)

EU taxonomy - review of the climate delegated act · Sustainable aviation fuels (ReFuelEU Aviation Initiative)

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.

EU taxonomy - review of the climate delegated act

VDMA · filed 13 Apr 2026 · source

The EU Taxonomy is a central instrument to guide sustainable investment and to define environmentally sustainable economic activities. The ongoing review of the Climate and Environmental Delegated Acts is therefore an important opportunity to further enhance the frameworks clarity, coherence and usability.

Aena SME, SA · filed 14 Apr 2026 · source

Aena welcomes the European Commissions 2026 review of UE Taxonomy Delegated Regulations amending Delegated Regulation (EU) 2021/2139 and Delegated Regulation (EU) 2023/2486. The initiative addresses issues widely highlighted by stakeholders, including excessive complexity, insufficient clarity in the technical screening criteria, and challenges in practical implementation.

VDMA · filed 14 Apr 2026 · source

The VDMA welcomes the Commissions intention to revise the Climate Delegated Act and acknowledges certain positive developments, such as the recognition of energy efficiency services and the replacement of the benchmarking concept best available alternative with current state of the art.

Sustainable aviation fuels (ReFuelEU Aviation Initiative)

Aena SME, SA · filed 21 Apr 2020 · source

Aena is one of the leading airport operator in the world by passenger volume and strongly supports the EU’s ambition to become the first climate-neutral continent by 2050. Achieving this ambition requires transformational changes to the broader systems in which we operate.

VDMA · filed 21 Apr 2020 · source

The German Mechanical Engineering Industry Association (VDMA) is the largest European industrial association. VDMA represents more than 3.300 member companies in the SME-dominated mechanical engineering industry in Germany and Europe.

VDMA · filed 18 Nov 2021 · source

The Mechanical Engineering Industry Association (VDMA) is the largest European industrial association. VDMA represents around 3300 German and European companies in the mechanical engineering industry. The industry represents innovation, export orientation, medium-sized companies and employs around four million people in Europe, more than one million of them in Germany.

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