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.
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.
The German automotive industry is meeting the challenge of climate change and will contribute to tackling it through innovation and technology. Our vision is climate-neutral mobility by 2050 at the latest. It is important that the regulatory framework is open to technology and stable in the long term.
Filed in German · English published by the European Commission
For the automotive industry the regulation of fleet emissions is an important instrument that has been tightened again. The German automotive industry is committed to the goal of making EU road transport climate-neutral by 2050 at the latest.
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
The German Association of the Automotive Industry (VDA), representing 630 German based, mostly fully in the EU-internal market integrated and globally acting members across the whole automotive value chain, welcomes the opportunity to provide feedback on the inception impact assessment for an EU revision of the Alternative Fuels Infrastructure Directive (AFID).
In order to achieve the more stringent fleet targets and the necessary scaling-up of e-mobility, a binding, rapid and comprehensive expansion of the charging infrastructure (CI) across Europe is essential. We welcome the fact that the COM plans to use the legal instrument of a regulation to provide a firm legal basis for the accelerated expansion of the CI for EVs in the member states.
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).
The forecast predicts a growing haulage capacity in Europe with the need for fossil-free transportation modes. In Europe about three third of goods are transported on roads by light and heavy duty vehicles. Stringent CO2 reduction targets for Heavy Duty Vehicles (HDV) will contribute to the objective to reduce overall CO2 emissions by 55% by 2030 and to reach climate neutrality until 2050.
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.
VDA welcomes the opportunity to contribute comments on the proposed revision of Regulation (EU) 2019/1242 for CO2 standards of HDV. German heavy-duty vehicle manufacturers and suppliers are strongly committed to rapidly reducing CO2 emissions in the public passenger and road freight transport sector and to making newly registered commercial vehicles fossil-free by 2040.
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