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.
Executive Summary As a supporter of the F-Gas Regulation and the European Green Deal, EPEE, representing the refrigeration, air-conditioning and heat pump industry, emphasizes that the heating and cooling sector can make an important contribution to achieving climate neutrality in Europe by 2050.
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.
EPEE – representing the Refrigeration, Air Conditioning and Heat Pump (RACHP) Industry in Europe – supports the F-Gas Regulation as an essential tool to reduce emissions of F-gases. To tackle the global climate change crisis, F-gases such as HFCs, must be contained, their consumption phased down and their emissions reduced as much and as fast as possible.
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.
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.
EPEE representing the Refrigeration, Air Conditioning and Heat Pump (RACHP) Industry in Europe supports the F-Gas Regulation as an essential tool to reduce emissions of F-gases and would like to bring its contribution to this implementing act on on training and certification requirements and on its draft annex. EPEE thanks the Commission for giving the opportunity to deliver feedback on this draft implementing act.
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