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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.

CEC
CECRA

Company · Belgium

4
files engaged
of 583 tracked
4
positions filed
in those 583 files
1
declared FTE
self-declared
0
EP accreditations
as declared to the register

Declared costs: €50K+ a year · in the register since 2012

ECO
ECOS

NGO · Belgium

55
files engaged
of 583 tracked
64
positions filed
in those 583 files
20.5
declared FTE
self-declared
5
EP accreditations
as declared to the register

Declared costs: not declared · in the register since 2010

Files both filed on (3)

Batteries and waste batteries · Common rules promoting the repair of goods · 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.

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.

Batteries and waste batteries

ECOS · filed 9 Jul 2020 · source

Batteries are an essential product to ensure decarbonisation in the EU and its demand is set to grow substantially in the upcoming years. As an environmental civil society organisation, we strongly welcome the initiative of the European Commission to update the legislation that ensures a circular and sustainable value chain for all batteries produced in the EU and placed on the single market.

CECRA · filed 26 Feb 2021 · source

Conc. Art. 59: We are pleased that independent operators will be granted access to the battery management system for industrial rechargeable batteries and electric vehicle storage batteries with a capacity of more than 2 kWh so that they can assess and determine its condition as well as the remaining lifetime.

ECOS · filed 1 Mar 2021 · source

ECOS welcomes the European Commission’s proposal for a new Regulation on batteries and waste batteries (replacing the current Battery Directive) and is pleased to contribute to the consultation on this matter. Together with other European NGOs, namely the EEB (The European Environmental Bureau), Deutsche Umwelthilfe (DUH – Environmental Action Germany), and Transport & Environment, we have developed a joint paper…

Common rules promoting the repair of goods

CECRA · filed 5 Apr 2022 · source

Vehicles are designed and equipped with very advanced technology in order to last in time for many years (in average 13 years). Vehicles are already reliable and durable products which provide value for money to consumers and prevent the overuse of resources and waste.

ECOS · filed 5 Apr 2022 · source

ECOS, 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.

Type approval of motor vehicles regarding access to in-vehicle generated data

ECOS · filed 21 Jun 2022 · source

ECOS welcomes the Commission’s initiative to further regulate access to vehicle data. This is key to avoid vendor lock-in while Europe transitions to electrified mobility and to facilitate services such as smart charging needed for the electricity grid to handle the rise of electric vehicles (EVs).

CECRA · filed 29 Jun 2022 · source

CECRA welcomes the initiative of the European Commission for sectoral legislation on access to vehicle data, functions and resources. With the introduction of the draft Data-Act on February 23rd, 2022 “COM (2022) 68 final; 2022/0047 (COD)” on access to data, the Commission has setup a positive framework to build on the sectoral legislation for the Automotive sector.

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