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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.

ANE
2
files engaged
of 583 tracked
2
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
UNI
UNIFE

Industry association · Belgium

26
files engaged
of 583 tracked
29
positions filed
in those 583 files
2.5
declared FTE
self-declared
2
EP accreditations
as declared to the register

Declared costs: €500K+ a year · in the register since 2008

Files both filed on (2)

Combined transport: support framework for intermodal transport of goods; calculation of external costs savings and generation of aggregated data · Single European railway area: use of railway infrastructure capacity

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.

Combined transport: support framework for intermodal transport of goods; calculation of external costs savings and generation of aggregated data

Asociación de Empresas Ferroviarias Privadas · filed 30 Jan 2024 · source

Updating the intermodal transport support framework is essential. The proposal aims to provide a coherent intermodal transport support framework as, so far and according to the REFIT evaluation, this framework has had an insufficient impact. The proposal includes three provisions to promote intermodal transport in general: All intermodal transport is exempt from authorisations and quotas.

Filed in Spanish · English published by the European Commission

UNIFE · filed 1 Feb 2024 · source

UNIFE, the association representing the European rail supply industry, would like to welcome the update of the Combined Transport Directive included in the Greening Freight package. The amendment of Directive 92/106/EEC is a step towards reaching the goals of the Sustainable and Smart Mobility Strategy and the European Green Deal objectives with regards to rail freight transport, set by the European Commission.

Single European railway area: use of railway infrastructure capacity

Asociación de Empresas Ferroviarias Privadas · filed 5 Apr 2022 · source

The Association of Private Railway Undertakings wishes to point out to the Commission the importance of international traffic in a country such as Spain which is at one end of the European continent and is highly dependent in its external trade on trade with the rest of Europe.

Filed in Spanish · English published by the European Commission

UNIFE · filed 5 Apr 2022 · source

UNIFE feedback to Cross-border rail traffic – better management and coordination initiative UNIFE - the association of the European rail supply industry - welcomes the European Commission (EC) decision to proactively work on a proposal aiming at a better management and coordination of cross-border rail traffic.

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