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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.

2
files engaged
of 583 tracked
2
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
ACE
ACEA

Industry association · Belgium

46
files engaged
of 583 tracked
55
positions filed
in those 583 files
19.5
declared FTE
self-declared
11
EP accreditations
as declared to the register

Declared costs: €5.5M+ a year · in the register since 2008

Files both filed on (2)

Batteries and waste batteries · General Product Safety Regulation

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

ACEA · filed 9 Jul 2020 · source

ACEA believes that any collection target would be inefficient to recycle more batteries. Therefore no changes are necessary to the actual legislation.Efficient and well-working collection and recycling processes, not only for automotive batteries and traction batteries, but for vehicles as such, are already implemented in many Member States.

Confederation of the European Bicycle Industry (CONEBI) · filed 26 Feb 2021 · source

CONEBI represents the European Bicycle, Pedal Assist E-Bike, Parts & Accessories Industries via its 15 national industry members. In the EU there are about 900 companies providing more than 120,000 direct/indirect jobs. Via the CONEBI’s national industry members, more than 500 small, medium and large companies are represented in CONEBI.

General Product Safety Regulation

ACEA · filed 1 Sept 2020 · source

The European Automobile Manufacturers’ Association (ACEA) believes that the GPSD is still broadly fit for purpose and does not require a major overhaul. At the most, it could be revised in a targeted manner to update some of the definitions with a view to clarifying their applicability.

Confederation of the European Bicycle Industry (CONEBI) · filed 1 Oct 2021 · source

CONEBI, the Confederation of the European Bicycle Industry, would like to hereby provide its comments on the European Commission’s proposal for a new General Product Safety Regulation (GPSR). For us this legislation is of particular relevance because bicycles as well as certain bicycle parts and accessories fall within the scope of this legislation. Attached you can find our full feedback.

ACEA · filed 4 Oct 2021 · source

Dear Sir, Ma'am, Please find below ACEA Position and feedback to the consultation. Logically, vehicles can clearly be identified by the individual VIN-Number and it is in the interest of vehicle manufacturers that our customer's are aware of the product manufacturer or recall actions triggers for used goods.

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