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.
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.
The Directive will have positive effects on repairers, a sector mostly composed of SMEs. Independent repairers have the right expertise, experience, and the necessary tools to offer high-quality repair services. The Directive rightly proposes that repairers should have access to spare parts and technical documentation. However, the Directive will certainly have an impact on retailers and manufacturers.
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.
SMEunited welcomes the initiative by the European Commission to update EU design protection rules. For SMEunited, the updated rules bring breakthroughs in 3 particular areas: 1. Clarifying that designs developed as part of employment relationships belong to the employer, 2. Outlining administrative invalidity proceedings as a more cost-effective and easier alternative to court procedures and 3.
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