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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.

ASE
ASERCOM

Company · Belgium

2
files engaged
of 583 tracked
3
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
APP
APPLiA

Industry association · Belgium

46
files engaged
of 583 tracked
53
positions filed
in those 583 files
7.5
declared FTE
self-declared
6
EP accreditations
as declared to the register

Declared costs: €400K+ a year · in the register since 2010

Files both filed on (2)

Fluorinated gases regulation · Minimum requirements for certification programmes and training attestations for RACHP equipment

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.

Fluorinated gases regulation

ASERCOM · filed 7 Sept 2020 · source

We as ASERCOM, the Association of European Refrigeration Component Manufacturers, reaffirmed in 2018* our commitment and engagement to accompany our industry to reach the 2030 F-gas target of CO2 emission réductions: 1.- Containment & Safety Measures:  Our industry has always led standardization committees and followed standards concerning tightness of components and safety requirements.

APPLiA · filed 28 Jun 2022 · source

APPLiA, the EU trade Association representing manufacturers of home appliances, including, ventilating and air conditioning and heat pump equipment, would like to share with the European policy-makers its stance and views on the new proposal for a Regulation on F-Gases revising (EU) No 517/2014 published on 5 April 2022. Please find our position paper attached.

ASERCOM · filed 29 Jun 2022 · source

ASERCOM is not supporting the proposed phase down. We think the phase down is a phase out and not phase down. The proposed phase down is unconsistent due to : Only quota for maintenance and service [EPEE HFC model] The number of units in general are increasing : Datacenters/Heat pumps/Air con. High uncertainty based on regulations which are not synchronised.

Minimum requirements for certification programmes and training attestations for RACHP equipment

APPLiA · filed 7 Jun 2024 · source

APPLiA, the European Trade Association representing manufacturers of home appliances, including ventilation, air conditioning and heat pump equipment, would like to share the following comments as a response to the consultation on the draft implementing regulation laying down rules for the application of Regulation (EU) 2024/573 of the European Parliament and of the Council establishing minimum requirements for the…

ASERCOM · filed 10 Jun 2024 · source

ASERCOM welcomes the opportunity to give feedback on establishing minimum requirements for the issuance of certificates to natural and legal persons and the conditions for the mutual recognition of such certificates pursuant to Regulation (EU) 2024/573.

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