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 · Poland
Declared costs: €700K+ a year · in the register since 2016
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.
The Polish Union of the Cosmetics Industry · filed 29 Oct 2021 · source
The Polish Union of the Cosmetics Industry supports the goals of the Green Deal and the Chemicals Strategy for Sustainability. Safety is highest priority of the cosmetics industry. The revision of the regulation 1223/2009/EC should ensure, that this regulation would continue to be the consumer-oriented, strongest cosmetics sector regulatory system for cosmetics in the world, based on science-based sectoral risk…
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
The Polish Union of the Cosmetics Industry · filed 10 Oct 2022 · source
The Polish Union of Cosmetics Industry hereby presents comments to the Call for Evidence regarding a „Proposal for a basic regulation of the European Chemicals Agency” with a particular focus on the Scientific Committee on Consumer Safety (SCCS).
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