Side by side
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.
Industry association · France
NGO · Germany
Declared costs: not declared · in the register since 2012
CO2 emission standards for cars and vans · Deployment of alternative fuels infrastructure · Strengthening the CO2 emission performance targets for new heavy-duty vehicles
Register facts self-declared (snapshot 2 Sept 2026); cost bands are floors. Shared files are shared attention, not evidence of coordination.
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.
Deutsche Umwelthilfe e.V. · filed 26 Nov 2020 · source
The car CO2 standards represent the primary EU policy instrument driving the transition to zero-emission road transport. Current standards are not in line with the Paris Agreement, and several elements of the regulation limit its effectiveness. These shortcomings must now be addressed, and the overall ambition significantly increased to set road transport on a rapid path to zero emissions within the next few years.
AFGNV · filed 8 Nov 2021 · source
AFGNV welcome this opportunity to further how on the proposal of the European Commission to revise the CO2 standards for cars & vans. Setting an objective 2035 target of a 100 % reduction in GHG emissions definitely based on tailpipe, without identifying the potential of renewable fuels in determining the emissions of road transport means a de facto ban of the internal combustion engine vehicles.
Filed in French · English published by the European Commission
Deutsche Umwelthilfe e.V. · filed 8 Nov 2021 · source
DUH welcomes the opportunity to submit feedback on the European Commission (EC) proposal for revised car CO2 standards. Road transport emissions have been rising over the last 30 years. Without fast and significant reductions in passenger car emissions, the EU won’t be able to meet its own climate targets, let alone the 1.5°C limit.
AFGNV · filed 18 Nov 2021 · source
AFGNV welcomes the revision of the current Alternative Fuels Infrastructure Directive, which should align with the GHG emission reduction targets of the EU. AFGNV is convinced that the only way of achieving a quick decarbonisation of road transport is to support all existing solutions, including biomethane (both in compressed and liquified forms – bioCNG and bioLNG).
Deutsche Umwelthilfe e.V. · filed 18 Nov 2021 · source
The revision of the AFIR offers the opportunity to set an important course for a change of engines towards a sustainable transport sector. We support the rapid development of the infrastructure in order to enable a faster conversion to electric motor operation.
AFGNV · filed 16 May 2023 · source
Considering that BioGNV is a valuable option to sharply reduce GHG emissions (up to -80% vs diesel over the lifecycle), France's AFGNV advocates to introduce a carbon correction factor in the emissions calculation.
Deutsche Umwelthilfe e.V. · filed 17 May 2023 · source
Deutsche Umwelthilfe welcomes the opportunity to comment on the revision of the emission standards for heavy duty vehicles. Summary of our key recommendations: 1. 100 % CO2 reduction target for new registrations of trucks and buses from 2030 2. Stringent intermediate targets before 2030 3. Zero emissions target for new city buses in 2027 4. Application of the standards to 100 % of fleet 5.
Filed in German · English published by the European Commission
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