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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
AEH
26
files engaged
of 583 tracked
29
positions filed
in those 583 files
7.1
declared FTE
self-declared
3
EP accreditations
as declared to the register

Declared costs: €200K+ a year · in the register since 2012

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

Association of the European Heating Industry (EHI) · filed 2 Sept 2020 · source

Please find our comments attached. About the European Heating Industry The European heating industry brings together companies that are leaders in the production of efficient heating systems. Our members produce advanced technologies for heating in buildings, including: heating systems, boilers, heat pumps, burners, components and system integrators, radiators, surface heating & cooling.

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.

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.

Association of the European Heating Industry (EHI) · filed 29 Jun 2022 · source

Dear Madam, dear Sir, Please find our contribution attached. Our general messages: - EHI is committed to reduce CO2 emissions from heating appliances, including from fluorinated gases used in our heat pumps. - The hydrofluorocarbons (HFCs) phase down needs to consider the projected growth in REPowerEU of the heat pump market and the need for servicing and maintenance.

Minimum requirements for certification programmes and training attestations for RACHP equipment

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.

Association of the European Heating Industry (EHI) · filed 10 Jun 2024 · source

The European Heating Industry (EHI) thanks the European Commission for preparing this draft implementing act that will update the certification requirements, in line with F-Gas Regulation (EU) 2024/573. We agree that an update is needed to include non f-gas alternatives (hydrocarbons, ammonia, CO2).

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