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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.

DKE (German Commission for Electrical, Electronic & Information Technologies) · filed 1 Mar 2021 · source

DKE, the German Commission for Electrical, Electronic & Information Technologies of DIN and VDE, welcomes the new EU proposal of Regulation on batteries and waste batteries that should allow to position EU industry leadership as frontrunner in terms of green and technologically advanced batteries.

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.

DKE (German Commission for Electrical, Electronic & Information Technologies) · filed 9 Aug 2021 · source

Standardization in support of the EU legislation has become over the decades a strategic tool for the well-being of the European Internal Market and European companies, as well as European consumers and society, a system copied by partners around the world. We appreciate that this also applies for the European Commission proposal for a GPSR even though it is not a harmonization legislation.

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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