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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.

AIR
AirClim

NGO · Sweden

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

Industry association · Belgium

73
files engaged
of 583 tracked
111
positions filed
in those 583 files
46.7
declared FTE
self-declared
11
EP accreditations
as declared to the register

Declared costs: €10M+ a year · in the register since 2009

Files both filed on (4)

Energy Efficiency Directive · Circularity requirements for vehicle design and management of end-of-life vehicles · Commission Directive amending Annex III of the Nitrates Directive · Integrated Nutrient Management Action Plan

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.

Energy Efficiency Directive

AirClim · filed 21 Sept 2020 · source

AirClim’s response to the Energy Efficiency Directive (EED) roadmap The action taken in the next 10 years will determine if it will be possible to reach the 1.5°C objective. The EU's commitment to put energy efficiency first needs to be strengthened to enable this.

Cefic · filed 21 Sept 2020 · source

Cefic supports Europe’s ambition to become climate neutral by 2050 requiring breakthrough technologies and enabling frameworks for the very large investments required. The Green Deal recognises that Energy Intensive Industries (EIIs) are indispensable for Europe’s transition. The chemical industry provides all other sectors including efficiency solutions to multiple value chains such as the construction sector.

Circularity requirements for vehicle design and management of end-of-life vehicles

AirClim · filed 27 Nov 2023 · source

Overall, AirClim strongly supported the adoption of ambitious measures to tackle the continuing problem of 'missing vehicles'. AirClim also supports stricter requirements on the export of used vehicles, to avoid used vehicles which are not roadworthy, generate air pollution and present health risks are exported from the EU to third countries.

Cefic · filed 4 Dec 2023 · source

Cefic welcomes the proposed Regulation addressing circularity requirements for vehicle design and the management of end-of-life vehicles (ELV) aiming to replace the 3R type-approval and ELV Directives. As raw material supplier at the top of this value chain, the chemical industry would like to provide feedback on cross cutting aspects of the proposal: Performance and information requirements on substances of…

Commission Directive amending Annex III of the Nitrates Directive

Cefic · filed 15 May 2024 · source

Fertilisers Efficiency Enhancers, a sector group of Cefic, represents the value chain of nitrogen stabilisers and other efficiency enhancers in Europe and promotes the agronomic and environmental benefits of nutrient enhancers in fertiliser applications.

AirClim · filed 17 May 2024 · source

While there may be reasonable grounds for subjecting RENURE fertilisers to different regulations than untreated manure, it is perplexing why this change is being rushed through without a proper impact assessment and before the ongoing fitness check evaluation of the Nitrates Directive is completed. Moreover, it is unclear how this change facilitates achieving the overall objectives of the Nitrates Directive.

Integrated Nutrient Management Action Plan

Cefic · filed 14 Apr 2022 · source

Fertilisers Efficiency Enhancers, a Sector Group of Cefic, appreciates the opportunity to contribute to the consultation on a Nutrients' action plan for better management. Please refer to the documents attached for detailed information about urease and nitrification inhibitors and their contribution towards the achievement of the ambitions of the Action Plan and the green Deal in general.

AirClim · filed 22 Apr 2022 · source

We welcome the goal to halve nutrient losses. It will have great benefits through improved air quality, improved water quality, biodiversity and reduced N2O emissions. Halving NH3 emissions alone would bring health benefits that would outweigh the costs for reducing emissions(1). In the Farm to Fork strategy, a reduction of fertilizer use by 20 % by 2030 is mentioned.

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