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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.

ANE
ANETRA

Industry association · Spain

2
files engaged
of 583 tracked
2
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register

Files both filed on (2)

Minimum requirements on minimum breaks and daily and weekly rest periods in the occasional passenger transport sector · VAT package on travel and tourism

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.

Minimum requirements on minimum breaks and daily and weekly rest periods in the occasional passenger transport sector

International Road Transport Union (IRU) · filed 18 Feb 2021 · source

IRU, the voice of the commercial road transport sector, welcomes the opportunity to participate in the initiative of the European Commission (EC) inception impact assessment specifically relating to the “need for specific driving and rest time rules for drivers in occasional transport of passengers”.

ANETRA · filed 18 Jul 2023 · source

La Asociación Nacional de Empresarios de Transportes en Autocares, ANETRA, apoya la propuesta de la Comisión Europea de revisar el Reglamento CE 561/2006 sobre tiempos de conducción y descanso, estableciendo disposiciones específicas para los conductores de autobuses y autocares.

International Road Transport Union (IRU) · filed 19 Jul 2023 · source

IRU welcomes the European Commission's proposal for specific derogations on driving and rest time rules applicable to coach tourism drivers in the EU. This acknowledges the specificity of coach tourism as a peoples business, including the fact that the current rules are not suited for group tourism by coach.

VAT package on travel and tourism

ANETRA · filed 29 Sept 2025 · source

The current VAT treatment of passenger transport by coach shows considerable disparities between the Member States of the European Union. While some countries apply the standard rate, others opt for reduced rates or even exemptions.

Filed in Spanish · English published by the European Commission

International Road Transport Union (IRU) · filed 16 Oct 2025 · source

The VAT system within the European coach sector is deeply fragmented, with huge variations in the way Member States treat these services applying a zero percent VAT rate, a low rate or, in some cases even a high rate (e.g. 0% in Estonia, 8% in Poland and 25% in Croatia).

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