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.
Industry association · Romania
NGO · Germany
Declared costs: not declared · in the register since 2012
Monitoring, reporting and verification of greenhouse gas emissions from maritime transport · Amendment of the Renewable Energy Directive: revising the values and modifying the methodology laid down in Annexes V-VI
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.
CIROM · filed 26 Nov 2020 · source
CIROM welcomes the opportunity to provide feedback on the Commission Inception Impact Assessment for the “Amendment of the EU Emissions Trading System”. CIROM wishes to highlight that the proposed revision of the EU-wide, economy-wide net target for greenhouse gas (GHG) emissions reduction - of at least 55% by 2030 compared to 1990 - will need to be met through actions from all areas of society.
Deutsche Umwelthilfe e.V. · filed 26 Nov 2020 · source
ETS reform as part of a package to collectively increase climate ambition Deutsche Umwelthilfe (DUH) notes that even with a 2030-climate target of 55%, Europe remains off track to reach the Paris Agreement 1.5°C objective. Emission cuts of at least 65% are required for the EU to fully honor its international commitments.
Deutsche Umwelthilfe e.V. · filed 8 Nov 2021 · source
Immediate social concerns and unclear climate benefits Environmental Action Germany (DUH) welcomes pricing in climate damage costs in the transport and building sectors, where emissions reductions are slow at best. We are concerned, however, that the introduction of a new emissions trading system is not the right instrument.
CIROM · filed 26 Jan 2026 · source
CIROM welcomes the opportunity to comment on the ECs public consultation for the revision of the Annexes V and VI of the Renewable Energy Directive (RED). In view of simplicity and consistency of the legislation RED with Directive EU- ETS 2003/87/EC and Waste Framework Directive, CIROM proposes the insertion of the following recital and new points to the Annex V (bioliquids), part C (Methodology) and Annex VI…
Deutsche Umwelthilfe e.V. · filed 26 Jan 2026 · source
The emission values and methodology of RED do not only dictate the criteria for national inventories but also underpin key decisions made by EU Member States and must therefore accurately reflect real-world climate impacts. In light of the climate crisis, assessments should adopt precautionary assumptions. Assumptions based on overly optimistic projections or omitting relevant emission sources must be avoided.
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