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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.

APF
ASFE - Paraffinic Fuels for Europe

Industry association · Belgium

2
files engaged
of 583 tracked
2
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
TE
49
files engaged
of 583 tracked
59
positions filed
in those 583 files
21.7
declared FTE
self-declared
26
EP accreditations
as declared to the register

Declared costs: not declared · in the register since 2010

Files both filed on (2)

Revision of the Energy Tax Directive · Deployment of alternative fuels infrastructure

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.

Revision of the Energy Tax Directive

Transport & Environment · filed 31 Mar 2020 · source

While every other sector’s climate emissions have decreased since 1990, on average, transport emissions have increased by almost 30% since 1990 (aviation emissions, for one, have more than doubled). Each mode of transport faces varying challenges to reverse this trend and reduce them in the coming decade.

ASFE - Paraffinic Fuels for Europe · filed 1 Apr 2020 · source

ASFE's input to Energy Taxation Directive’s Revision roadmap ASFE (the voice of Paraffinic Fuels in Europe) welcomes the Commission’s intention to review the Energy Taxation Directive, as a more harmonised European taxation framework will support the uptake of cleaner, sustainable fuels across Europe.

Deployment of alternative fuels infrastructure

Transport & Environment · filed 29 Apr 2020 · source

The EU urgently needs a new and robust legislative framework on zero emission infrastructure to support the 33-44 million electric cars (battery and plug-in hybrid) expected on the road in 2030 to align with transport decarbonisation goals. Consumers should have access to the EU single market for chargers.

ASFE - Paraffinic Fuels for Europe · filed 4 May 2020 · source

ASFE – the voice of paraffinic fuels in Europe – welcomes the initiative to revise the Directive on Alternative Fuel Infrastructure, as this piece of legislation has the potential to be the regulatory cornerstone for the deployment of alternative fuels in Europe.

Transport & Environment · filed 18 Nov 2021 · source

Transport & Environment (T&E) welcomes the Commission’s (EC) proposal for a regulation on the deployment of alternative fuels infrastructure. In particular the change of the legislative instrument from directive to a regulation T&E considers an important step in the right direction. (detailed feedback in attachment).

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