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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.

AFG
AFGNV

Industry association · France

3
files engaged
of 583 tracked
3
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
BDI
Bundesverband der Deutschen Industrie e.V.

Industry association · Germany

56
files engaged
of 583 tracked
68
positions filed
in those 583 files
20.6
declared FTE
self-declared
15
EP accreditations
as declared to the register

Declared costs: €4M+ a year · in the register since 2008

Files both filed on (3)

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.

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.

CO2 emission standards for cars and vans

Bundesverband der Deutschen Industrie e.V. · filed 25 Nov 2020 · source

The IIA correctly states that "CO2 standards give vehicle manufacturers the legal certainty to invest more in related R&D, to produce more zero-emission vehicles so that with increased supply and economy of scale they can become more affordable for citizens”.

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

Bundesverband der Deutschen Industrie e.V. · filed 8 Nov 2021 · source

To stay ahead in the global race for the best climate and energy technology solutions, companies need a clear and reliable fit-for-55 implementation plan providing a clear commitment to Europe as an attractive business, investment and innovation location.

Deployment of alternative fuels infrastructure

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).

Bundesverband der Deutschen Industrie e.V. · filed 18 Nov 2021 · source

To stay ahead in the global race for the best climate and energy technology solutions, companies need a clear and reliable fit-for-55 implementation plan providing a clear commitment to Europe as an attractive business, investment and innovation location.

Strengthening the CO2 emission performance targets for new heavy-duty vehicles

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.

Bundesverband der Deutschen Industrie e.V. · filed 17 May 2023 · source

Industry is committed to ambitious but technically and economically realistic targets. The overall trajectory proposed by the European Commission for all vehicle categories (-45 % from 1 January 2030, -65 % from 1 January 2035 and -90 % from 1 January 2040) is very ambitious.

Filed in German · English published by the European Commission

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