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.
Company · Canada
Declared costs: €25K+ a year · in the register since 2018
Industry association · Germany
Declared costs: €1.5M+ a year · in the register since 2011
Cyber Resilience Act · Type approval of motor vehicles regarding access to in-vehicle generated data
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.
TÜV-Verband e. V. · filed 24 May 2022 · source
The TÜV Association welcomes the Commission’s intention of establishing binding cybersecurity requirements for a broad range of products and services. To date, the EU is lacking an all-encompassing approach to cybersecurity. Cybersecurity provisions in current legislation are either limited to specific product groups or are only applicable on a voluntary basis.
TÜV-Verband e. V. · filed 2 Dec 2022 · source
The TÜV Association welcomes the European Commissions intention of establishing binding cybersecurity requirements for a broad range of connected products with digital elements. Given the ever-increasing number of cybersecurity incidents across the Union, it is of paramount importance to provide consumers and businesses with secure products both at the time of purchase and over their entire lifecycle.
BlackBerry · filed 23 Jan 2023 · source
Dear European Commission, BlackBerry is a global leader in cybersecurity. For close to 40 years, BlackBerry has invented and built trusted security solutions to give people, governments, and businesses the ability to stay secure, mobile and productive. We have reviewed the draft cyber-resilience act and provide comments in the attached.
TÜV-Verband e. V. · filed 21 Jun 2022 · source
TÜV Verband e.V. in line with CITA aisbl welcomes the initiative of the European Commission to tackle the issues of accessing vehicle data, functions and resources. Due to significant impacts of the Data Act on the mobility ecosystem, we support the intention of the EU Commission, in line with recital 3 of the Data Act, to adopt specific provisions within the EU type-approval regulations for the automotive sector.
BlackBerry · filed 2 Aug 2022 · source
This consultation should seek to identify means to align the horizontal and sectorial EU with the UNECE Regulations 155 and 156 on cyber security and software update management system. Specifically, directives 2014/53/EU and (EU) 2019/2144 should fully align with the network and cyber security provisions laid down by the aforementioned UN vehicle regulations.
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