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.
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.
The EEB welcomes the inception impact assessment for the initiative “Legislative proposal on substantiating green claims”. The EEB actively participates in the Product Environmental Footprint (PEF), its Technical Advisory Board (TAB), as well as the pilot and transition phase projects. The EEB supports the need for standard methodologies to assess the impact on the environment of products on the European market.
The EEB welcomes the long-awaited proposal for a Green Claims Directive. Please see our attachd position paper and the summary below: 1) Why this legislation is important - The proliferation of misleading and unsubstantiated claims as well as greenwashing are hampering the green transition.
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.
The EEB welcomes the initiative “Empowering the consumer for the green transition”. Preventing greenwashing and early obsolescence are necessary priorities in the Green Deal, as well as Europe’s post Covid19 recovery. Consumer legislation should support the forthcoming sustainable products initiative, and its objective “to make sustainable goods, services and business models the norm”.
The amendments proposed to the Unfair Commercial Practices Directive (UCPD) and the Consumer Rights Directive (CRD) are a step in the right direction to counter the lack of reliable information on products’ durability and reparability, early obsolescence and greenwashing.
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