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.
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.
The IIA correctly states that "CO2 standards give vehicle manufacturers the legal certainty to invest more in related R&D, to produce more zero-emission vehicles so that with increased supply and economy of scale they can become more affordable for citizens”.
Europe is striving to become the first carbon-neutral continent by 2050 and as a key milestone on this path, the European Commission proposes to raise the greenhouse gas (GHG) reduction target for 2030 to at least 55%. Transport is identified as one of the sectors which need to step up efforts urgently. ELENGY supports this very ambitious target.
To stay ahead in the global race for the best climate and energy technology solutions, companies need a clear and reliable fit-for-55 implementation plan providing a clear commitment to Europe as an attractive business, investment and innovation location.
Industry is committed to ambitious but technically and economically realistic targets. The overall trajectory proposed by the European Commission for all vehicle categories (-45 % from 1 January 2030, -65 % from 1 January 2035 and -90 % from 1 January 2040) is very ambitious.
Filed in German · English published by the European Commission
Elengy position Regulation on CO2 standards for heavy duty vehicles Elengy fully supports the objective of a regulation aiming at accelerating the decarbonization of heavy duty transport. Though, Elengy considers that the current Commission proposal is making the underlying assumption that electricity and in the future hydrogen are the only solutions to reduce heavy duty transport carbon intensity, irrespective of…
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