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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

Files both filed on (2)

Revision of Regulation (EU)2019/1020 on market surveillance and compliance of products · Towards an EU Product Policy Framework contributing to the Circular Economy

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…

ZERO - Associação Sistema Terrestre Sustentável · filed 2 Feb 2026 · source

Effective market surveillance should be strengthened through a set of targeted actions. Member States market surveillance authorities need sufficient staff and technical resources to apply rules more consistently across the EU, supported by the creation of an EU-wide Market Surveillance Authority.

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.).

ZERO - Associação Sistema Terrestre Sustentável · filed 25 May 2018 · source

- ‘Products & services’ are the entry point for material loops: 80% of environmental impacts are determined at design stage and if injecting single use & toxic materials through products we spoil the whole potential for circularity. It is no brainer that products and services need to be better designed for circularity. It’s impossible to make a good recipe with rotten ingredients.

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