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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

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.

Deutsche Umwelthilfe e.V. · filed 7 Sept 2020 · source

The F-gas Regulation is a key and guiding part of the European Union (EU) climate legislation for the transition from the use of fluorinated gases such as hydrofluorocarbons (HFCs) and sulphur hexafluoride (SF6) to the use of natural refrigerants. Having been in force for five years, the Regulation is now being reviewed with a view to improving it.

Filed in German · English published by the European Commission

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.

Deutsche Umwelthilfe e.V. · filed 29 Jun 2022 · source

Deutsche Umwelthilfe e.V. calls for more ambition in the current proposal of the EU F-Gas regulation. Please find our detailed comments in the document attached. We would like to emphasize that this is the crucial moment to set the course for a genuine sustainable transformation instead of, again, replacing one problem with the next: First, ozone-depleting chlorofluorocarbons and hydrochlorofluorocarbons were…

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.

Deutsche Umwelthilfe e.V. · filed 10 Jun 2024 · source

Deutsche Umwelthilfe would like to thank the European Commission for preparing this draft certification requirements in line with the F-Gase Regulation (EU) 2024/573, as well as for the possibility to comment. We see the enforcement of natural refrigerants instead of F-gases as an important milestone in achieving climate objectives while at the same time being environmentally friendly by avoiding regrettable…

Filed in German · English published by the European Commission

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