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.
Dear Madam/Sir: Brussels Consulting Kft. and its clients believe that the “Sustainable consumption of goods” initiative and the right of consumers to repair are important steps for increasing the circularity of electronics and electronic equipments. We would like to point out that a key concept to bear in mind is that of the “smallest unit of practical repair”.
Bitkom e.V. is the German Digital Association and represents more than 2000 member companies from the digital economy. Bitkom members employ more than 2 million employees in Germany. Members include more than 1000 medium-sized businesses, more than 500 start-ups and almost all global players. Thank you for the opportunity to comment and our detailed feedback can be found in the attached file.
Filed in German · English published by the European Commission
For Bitkom and its members, the safety of the products placed on the market is the top priority. Therefore the General Product Safety Directive (GPSD) has a high priority for us and we appreciate the opportunity to provide feedback on the roadmap for its revision. Since its enforcement the GPSD has made a significant contribution to the safety of consumer products.
Brussels Consulting Kft. submits the following concerning the Commission’s draft: • Overall, we support Commission’s proposal and we believe that the proposed (new) requirements are appropriate. • We recognise similar high-level requirements in existing US law, and we suggest that the Commission took a look at them if hadn’t already (e.g. Consumer Product Safety Improvement Act).
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