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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.

BIL
Belron International Limited

Industry association · United Kingdom

2
files engaged
of 583 tracked
2
positions filed
in those 583 files
1.5
declared FTE
self-declared
0
EP accreditations
as declared to the register

Declared costs: €200K+ a year · in the register since 2021

RTR
8
files engaged
of 583 tracked
10
positions filed
in those 583 files
1.4
declared FTE
self-declared
1
EP accreditations
as declared to the register

Declared costs: €50K+ a year · in the register since 2020

Files both filed on (2)

Common rules promoting the repair of goods · Industrial property: legal protection of designs. Recast

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.

Common rules promoting the repair of goods

Belron International Limited · filed 5 Apr 2022 · source

Belron® is the world’s leading vehicle glass repair, replacement, and recalibration service provider, operating in over 25 countries in Europe with brands such as Carglass®, Autoglass® and Safelite®. Belron's feedback on the consultation is contained in it's attached submission.

Right to Repair Europe · filed 5 Apr 2022 · source

Right to Repair (R2R) Europe welcomes the Commission’s initiative to directly address repair and reuse in the context of sustainable consumption of goods. Considering that e-waste is one of the fastest growing waste streams in the world, and that the amount of household appliances failing within 5 years of purchase is skyrocketing, this is an area that requires urgent and focused policy attention.

Right to Repair Europe · filed 25 May 2023 · source

Right to Repair Europe welcomes the Commissions proposal for a directive on Common Rules Promoting the Repair of Goods, and this opportunity to provide feedback on the proposal. Although this proposals intent to grant Europeans a right to repair their products is a step in the right direction, the policy options outlined in the proposal do not grant a universal right to repair.

Industrial property: legal protection of designs. Recast

Belron International Limited · filed 31 Jan 2023 · source

Belron® is the worlds leading vehicle glass repair, replacement service provider, with a significant footprint in Europe with brands such as Carglass® and Autoglass®. Belron operates in over 25 markets (including Germany, France, Belgium, Netherlands, Luxembourg, Austria, Italy, Spain, Portugal, Switzerland, Sweden, Denmark and Norway) and has over 13,000 employees in the EU.

Right to Repair Europe · filed 31 Jan 2023 · source

The Right to Repair campaign supports the proposed revision of EU rules on industrial design regarding the introduction of a repair clause. The repair clause would harmonise EU rules on aftermarket spare parts, as such rules are currently fragmented across member states.

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