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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.

EAR
Earthsight

NGO · United Kingdom

2
files engaged
of 583 tracked
2
positions filed
in those 583 files
3.2
declared FTE
self-declared
2
EP accreditations
as declared to the register

Declared costs: not declared · in the register since 2020

Files both filed on (2)

Delegated Regulation amending Annex I of Regulation (EU) 2023/1115 (EU Deforestation Regulation) · Illegal logging – evaluation of EU rules (fitness check)

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.

Delegated Regulation amending Annex I of Regulation (EU) 2023/1115 (EU Deforestation Regulation)

Earthsight · filed 13 May 2025 · source

Earthsight submits the comments below to the European Commissions public consultation on the amendment of Annex I to the Deforestation Regulation (EUDR). This amending act is intended to provide technical fixes and clarifications and should not be used to relitigate the scope of commodities covered by the Regulation.

ClientEarth · filed 13 May 2025 · source

We acknowledge and support the Commission's efforts to promote waste recovery and the transition to a circular economy. However, we note that the Delegated Act would extend the existing exception for "waste" products to second-hand and used products.

Illegal logging – evaluation of EU rules (fitness check)

Earthsight · filed 28 Feb 2020 · source

The European Union Timber Regulation is a pioneering piece of legislation and remains a vital tool in the global fight against illegal deforestation and the associated trade in commodities. While there have been laudable steps taken by a few Member States to enforce this law over the years, these instances have remained the exception rather than the rule.

ClientEarth · filed 28 Feb 2020 · source

ClientEarth considers that both the EUTR & FLEGT Regulation have contributed to more legality and transparency in the global timber supply chain and have made progress towards achieving the objectives of the FLEGT Action Plan.

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