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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.

ECE
ECEAE

NGO · Germany

2
files engaged
of 583 tracked
2
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
12
files engaged
of 583 tracked
12
positions filed
in those 583 files
4
declared FTE
self-declared
3
EP accreditations
as declared to the register

Declared costs: not declared · in the register since 2010

Files both filed on (2)

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.

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.

EU Chemicals Strategy for sustainability - Revision of the Cosmetic Products Regulation

Deutscher Tierschutzbund e.V. · filed 28 Oct 2021 · source

The German Animal Welfare Federation welcomes the EU chemicals strategy for sustainability and the revision of the Cosmetic Products Regulation in this light. It has been an essential step towards a progressive and reliable safety assessment when the EU Cosmetics Regulation banned animal testing for cosmetic products and ingredients as well as the marketing of cosmetic products and ingredients that have been tested…

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.

European Chemicals Agency and amending regulations

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

Deutscher Tierschutzbund e.V. · filed 2 Dec 2025 · source

The German Animal Welfare Association welcomes the valuable opportunity to provide feedback on a basic regulation to the European Chemicals Agency (ECHA). The initiative aims to strengthen ECHA’s governance and make it fit for the future, as well as to implement financial sustainability.

Filed in German · English published by the European Commission

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