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.
EurEau is the European federation of water services and represents drinking water (DW) and waste water (WW) operators from 29 countries. We support the EU’s Green Deal, including its climate targets and Strategies. We call for full coherence between the EED, other energy legislation (RED), and sectoral legislation (Drinking Water Directive - DWD, Urban Waste Water Treatment Directive - UWWTD).
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.
EurEau welcomes the Proposal for a Directive on energy efficiency (recast) (EED) and supports the role of circular economy and the life cycle approach. Water operators are moving towards energy neutrality, combining high energy efficiency and generation of renewable energy.
EurEau would like to share its feedback to the draft act for a Directive to amend Annex III of the Nitrates Directive. In the attached document you can find our concerns regarding the Commissions draft act to amend Annex III of the Nitrates Directive and its potential impact on water resources, in particular those used for abstraction of water intended for human consumption.
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.
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.
EurEau is the European Federation of National Associations of Water Services and is therefore very much involved in environmental topics and welcomes the holistic nutrient management approach proposed by the European Commission in order to address the nitrogen and phosphorus cycles.
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