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.
Residential burning with solid fuels is the predominant source of health and climate damaging pollutants. The sector is responsible for 58% of fine particles (PM2.5), 37% of black carbon (BC) and 85% of benzo(a)pyrene (BaP) emitted in the EU [1]. This is despite only a small proportion of households heating with wood.
On behalf of Deutsche Umwelthilfe (DUH, Environmental Action Germany), we welcome the revision of the Ecodesign Regulation for solid-fuel local space heaters/SFLSH (EU 2015/1185). Over a fifth of total PM2.5 in Germany comes from small combustion appliances however, as reporting does not include condensables (condensed particles), actual emissions from this sector are much higher.
The Call for Evidence explains: solid fuel boilers remain significant contributors to energy consumption, greenhouse gas and pollutant emissions. Pollution, mostly from particulate matter, is very high in densely populated areas with a large share of solid fuel boilers, amplifying the threat to public health.
On behalf of Deutsche Umwelthilfe (DUH, Environmental Action Germany), we welcome the revision of the Ecodesign Regulation for solid fuel boilers/SFB (EU 2015/1189). Over a fifth of total PM2.5 in Germany comes from small combustion appliances however, as reporting does not include condensables (condensed particles), actual emissions from this sector are much higher.
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