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.
Many traders are taking advantage of consumers’ growing interest in environmental matters because of the climate crisis and are using green claims to differentiate themselves. Many claims are not or cannot be substantiated. This triggers confusion and mistrust among consumers and jeopardizes their active contribution to the transition towards a green economy.
Based on the current status, as seen from the field of consumption studies, we agree with the identified need to create more clarity within a very confusing area of legislation and labelling. However, it is paradoxical that reducing complexity is often met with a desire to introduce new schemes or strengthen existing schemes, such as in the area of product labelling.
BEUC, the European Consumer organisation, very much welcomes the publication of the Green Claims Directive as an important step in fighting greenwashing and ending misleading unsubstantiated claims from being displayed on products and services. Consumers are confronted with a systemic greenwashing problem.
BEUC strongly welcomes the announcement that the European Commission will be taking initiatives to empower consumers in the green transition through new information rights, protecting them from misleading practices and strengthening the enforcement of their rights. Such initiatives are urgently needed to allow consumers to play a more important role in achieving the sustainable consumption.
We want to express our enthusiasm for Empowering the consumer for the green transition initiative. Greenwashing as a marketing strategy, lack of correct information, as well as early and planned obsolescence are important barriers to address in transitioning to a more sustainable production and consumption system. We do however have some comments that we hope will be helpful in the further work, see enclosed file.
BEUC welcomes the proposal on empowering consumers for the green transition in which the Commissions proposed some targeted amendments to the Unfair Commercial Practices Directive (UCPD) and the Consumer Rights Directive (CRD). However, we still see some need for improvement.
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