Side by side
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.
Industry association · Poland
NGO · Germany
Declared costs: not declared · in the register since 2012
Monitoring, reporting and verification of greenhouse gas emissions from maritime transport · Revision of the Energy Tax Directive · Deployment of alternative fuels infrastructure · Sustainable maritime fuels (FuelEU Maritime Initiative)
Register facts self-declared (snapshot 2 Sept 2026); cost bands are floors. Shared files are shared attention, not evidence of coordination.
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.
Deutsche Umwelthilfe e.V. · filed 26 Nov 2020 · source
ETS reform as part of a package to collectively increase climate ambition Deutsche Umwelthilfe (DUH) notes that even with a 2030-climate target of 55%, Europe remains off track to reach the Paris Agreement 1.5°C objective. Emission cuts of at least 65% are required for the EU to fully honor its international commitments.
Baltic Ports Organization · filed 8 Nov 2021 · source
The Baltic Ports Organization (BPO) welcomes "Fit for 55" proposal. However; there are a number of points that need to be addressed in order to make the "Fit for 55" package fit for purpose and assure the continuous competitiveness of the European port sector. Under the EU plan, shipping is set to be added to EU’s ETS gradually from 2023 and phased in over a three-year period.
Deutsche Umwelthilfe e.V. · filed 8 Nov 2021 · source
Immediate social concerns and unclear climate benefits Environmental Action Germany (DUH) welcomes pricing in climate damage costs in the transport and building sectors, where emissions reductions are slow at best. We are concerned, however, that the introduction of a new emissions trading system is not the right instrument.
Baltic Ports Organization · filed 8 Nov 2021 · source
The Baltic Ports Organization (BPO) welcomes "Fit for 55" proposal. However; there are a number of points that need to be addressed in order to make the "Fit for 55" package fit for purpose and assure the continuous competitiveness of the European port sector. A revision of the Energy Taxation Directive proposes to remove tax exemption on bunker fuels sold within and for use in European Economic Area (EEA).
Deutsche Umwelthilfe e.V. · filed 18 Nov 2021 · source
Environmental Action Germany (Deutsche Umwelthilfe, DUH) notes that the many tax exemptions in the Energy Taxation have led to a very disparate and complex energy tax landscape in Europe, which also hinders the integration of the internal energy market.
Baltic Ports Organization · filed 8 Nov 2021 · source
The Baltic Ports Organization (BPO) welcomes "Fit for 55" proposal. However; there are a number of points that need to be addressed in order to make the "Fit for 55" package fit for purpose and assure the continuous competitiveness of the European port sector.
Deutsche Umwelthilfe e.V. · filed 18 Nov 2021 · source
The revision of the AFIR offers the opportunity to set an important course for a change of engines towards a sustainable transport sector. We support the rapid development of the infrastructure in order to enable a faster conversion to electric motor operation.
Deutsche Umwelthilfe e.V. · filed 23 Apr 2020 · source
Environmental Action Germany welcomes the opportunity to comment on this EC initiative. We wish to make the following comments: 1. Crop biofuels are more damaging to the climate than fossil fuels. Crop biofuels must be phased out entirely and must not be incentivised for use in shipping. 2. Advanced biofuels based on wastes and residues are not automatically sustainable.
Baltic Ports Organization · filed 8 Nov 2021 · source
While the Baltic Ports Organization (BPO) welcomes "Fit for 55" package the EC, there are a number of points that need to be addressed in order to make the "Fit for 55" package fit for purpose and assure the continuous competitiveness of the European port sector.
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