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.
Academic / research · Norway
Industry association · Belgium
Declared costs: €3.5M+ a year · in the register since 2011
Substantiation and communication of explicit environmental claims (Green Claims Directive) · Empowering consumers for the green transition
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.
Consumption Research Norway, OsloMet · filed 31 Aug 2020 · source
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.
DIGITALEUROPE · filed 20 Jul 2023 · source
18 July 2023 DIGITALEUROPE feedback on Substantiating Green Claims’ public consultation Executive summary The proposed Green Claims Directive (GCD) is a positive step toward combating greenwashing. However, its effectiveness will depend on enforcement and the establishment of clear methodologies.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
DIGITALEUROPE · filed 27 Jul 2020 · source
DIGITALEUROPE’s members have long led the way with environmental progress, and many have put forward ground-breaking commitments and programmes to deliver innovative products and services in a sustainable way. Our members empower consumers to take part in the circular economy through numerous strategies, including providing transparent information on the sustainability credentials of our products and services…
Consumption Research Norway, OsloMet · filed 31 Aug 2020 · source
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.
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