Side by side
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.
NGO · Germany
Industry association · Belgium
Declared costs: €10M+ a year · in the register since 2009
EU Chemicals Strategy for sustainability - Revision of the Cosmetic Products Regulation · European Chemicals Agency and amending regulations
Register facts self-declared (snapshot 2 Sept 2026); cost bands are floors. Shared files are shared attention, not evidence of coordination.
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.
ECEAE · filed 29 Oct 2021 · source
Animal testing for cosmetic products is still required in some cases by ECHA. According to a recent study, 63 ingredients used solely in cosmetic products have been tested on animals after the Cosmetic Regulation ban on in vivo testing. As the intention of legislators and of EU citizens aimed to ensure that animal testing for cosmetic products is banned completely, this review should close the gaps (i.p.
Cefic · filed 29 Oct 2021 · source
The Association of Synthetic Amorphous Silica Producers (ASASP) recognises the European Commission’s efforts to further improve the protection of human health and the environment and to ensure that regulations become more efficient and predictable and supports the Chemical Strategy for Sustainability (CSS) objective of improving effectiveness, efficiency, and coherence of safety assessments across EU legislation.
ECEAE · filed 14 Sept 2022 · source
Care should be taken to increase the acceptance of non-animal research methods for safety testing and to reduce animal testing. The wording of the laws must be clear and there must be no loopholes. Particularly in the field of testing endocrine disruptors, mixtures and polymers, care must be taken not to increase animal testing.
Filed in German · English published by the European Commission
Cefic · filed 10 Oct 2022 · source
Cefic supports a well-functioning European Chemicals Agency (ECHA) to deliver science based and technical tasks on chemical safety assessment. These tasks will become even more complex and challenging following the implementation of the EU Chemicals Strategy for Sustainability (CSS).
Cefic · filed 10 Oct 2022 · source
EFCTC contribution to the Commission Public Consultation on the proposal for a basic regulation for the European Chemicals Agency INTRODUCTION The European FluoroCarbons Technical Committee is a Cefic Sector Group.
Cefic · filed 2 Dec 2025 · source
1 December 2025 Cefic Input to the Public Consultation on the proposal for a Regulation on the European Chemicals Agency (ECHA Basic Regulation) Cefic supports a well-functioning European Chemicals Agency (ECHA) to deliver science based and technical tasks on chemical safety assessment. Any new task needs to be linked with ECHA’s vision and mission with appropriate human and financial resources allocated.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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