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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.

DKW
DKWU

Industry association · Germany

3
files engaged
of 583 tracked
3
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
ECO
ECOS

NGO · Belgium

55
files engaged
of 583 tracked
64
positions filed
in those 583 files
20.5
declared FTE
self-declared
5
EP accreditations
as declared to the register

Declared costs: not declared · in the register since 2010

Files both filed on (3)

Revision of Regulation (EU)2019/1020 on market surveillance and compliance of products · Towards an EU Product Policy Framework contributing to the Circular Economy · Measures addressing the environmental impact of imaging equipment including consumables

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.

Revision of Regulation (EU)2019/1020 on market surveillance and compliance of products

DKWU · filed 28 Jan 2026 · source

Market surveillance in the office imaging consumables industry has failed to deliver effective enforcement under Regulation (EU) 2019/1020. Despite multiple, well-documented denunciations at Member State and county level of distributors of non-compliant newly build single use plastic cartridges from China flooding the EU market, widespread breaches of CE marking, RoHS, Low-Voltage directive, WEEE and packaging…

ECOS · filed 4 Feb 2026 · source

While Regulation (EU) 2019/1020 on market surveillance and compliance of products has been key in securing the legal framework ruling the market surveillance activities that ensure that non-food products on the EU market meet EU regulatory requirements, it is critical to reinforce checks, adequately resource surveillance authorities and discourage non-compliance also from economic operators such as online…

Towards an EU Product Policy Framework contributing to the Circular Economy

DKWU · filed 8 May 2018 · source

Considering the use of materials remanufacturing is one of the most preferable alternatives because the geometrical form of the product is retained and its associated economic value is preserved. The DKWU Networks main concern in regard to remanufacturing are imaging devices (Printers, Multi Functional Printers (MFPs), Copiers and Fax machines) as well as their consumables (cartridges, drum units, etc.).

ECOS · filed 1 Jun 2018 · source

ECOS welcomes the European Commission’s ongoing efforts to develop an EU circular economy. We strongly encourage the EU to ensure that the circular economy respects planetary boundaries and fair share of use and access to resources, and avoids and minimises negative impacts of resource use including biodiversity loss, climate change, pollution, and reduced/impaired human health.

Measures addressing the environmental impact of imaging equipment including consumables

DKWU · filed 24 Jan 2023 · source

The collection and preparation for re-use of IE cartridges has grown to a very professional business starting in the early 1990. That means that systems now in place matured for over 30 years. In addition, single-use by design IE cartridges produce a lot of e waste (370 Mio. IJ cartridges * 40gr/cartridges + 135 Mio.

ECOS · filed 20 Feb 2023 · source

Environmental NGOs including the Right to Repair Europe and Coolproducts campaigns welcome the publication of the call for evidence for an impact assessment on imaging equipment including the Commission's understanding of the problem and possible solutions. We call for the implementation of Option 4 a combination of ecodesign requirements and energy labelling.

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