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.
Business Finland is the Finnish innovation funding, trade, investment, and travel promotion organization, fully owned by the Finnish government. We recognize the strategic importance of the EU emission trading system. The ETS as a market-based instrument has proven effective and cost-efficient in driving down industrial and energy-sector emissions.
The ETS should remain a core policy instrument to establish CO2 abatement at the lowest practicable cost to society. We do not favor inclusion of other sectors such as transport and buildings as an extension of the ETS current scheme, which already has to cope with different sectors with distinct elasticities, and risks on carbon leakage in one system.
Business Finland is the Finnish innovation funding, trade, investment, and travel promotion organization and is fully owned by the Finnish government. We fully recognize the strategic importance of the EED directive, support the decarbonisation of the energy sector and understand the importance of energy efficiency in achieving climate objectives.
Cefic supports Europe’s ambition to become climate neutral by 2050 requiring breakthrough technologies and enabling frameworks for the very large investments required. The Green Deal recognises that Energy Intensive Industries (EIIs) are indispensable for Europe’s transition. The chemical industry provides all other sectors including efficiency solutions to multiple value chains such as the construction sector.
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