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 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”.
Agora Verkehrswende appreciates the opportunity to provide feedback at the beginning of this process. Generally, as electrification progresses, it would be more suitable to base the standards on energy efficiency rather than CO2 emissions in order to address the imbalance between electric and combustion cars, to ensure that all vehicle types improve over time, and also because a shrinking share of new vehicles will…
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.
We agree with the choice of the four problems identified in the inception Impact Assessment and the way they are to be tackled. We would however point out a fifth line of enquiry which concerns the range of fuels covered by the Directive.
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.
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