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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.

ENE
Energizer

Company · United States

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

Industry association · Belgium

46
files engaged
of 583 tracked
55
positions filed
in those 583 files
19.5
declared FTE
self-declared
11
EP accreditations
as declared to the register

Declared costs: €5.5M+ a year · in the register since 2008

Files both filed on (3)

Substantiation and communication of explicit environmental claims (Green Claims Directive) · Empowering consumers for the green transition · General Product Safety Regulation

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.

Substantiation and communication of explicit environmental claims (Green Claims Directive)

Energizer · filed 26 Aug 2020 · source

Energizer agrees that the provision of reliable, comparable and verifiable information on environmental impacts of different products is essential for making informed purchases and investments. Energizer is thus in favour of a coherent policy framework that empowers consumers to not only make more sustainable choices, but to trust the green claims on the devices they purchase.

ACEA · filed 31 Aug 2020 · source

ACEA welcomes LCA analyses as they are important procedures that can help to reduce a motor vehicle’s impact on the environment and believes that the studies made should be scientifically sound and compare equivalent systems. LCA can be a useful tool to address environmental issues and is applied as internal environmental system for systematically managing environmental improvements in the automotive industry.

Empowering consumers for the green transition

Energizer · filed 26 Aug 2020 · source

Energizer agrees that a clear and long-term perspective on consumer rights is necessary in order to empower consumers to be active participants in the green and digital transitions, to protect vulnerable consumers, to enforce consumer rights, and to ensure international cooperation.

ACEA · filed 1 Sept 2020 · source

ACEA, the European Automobile Manufacturers' Association, welcomes the opportunity to contribute to the initial roadmap consultation regarding the consumer policy and how strengthening the role of consumers in the green transition. In particular ACEA welcome policy option 2: a new stand-alone consumer protection instrument.

General Product Safety Regulation

Energizer · filed 31 Aug 2020 · source

Energizer is in favour of updating the General Product Safety Directive to ensure that it is fit for purpose and continues to protect consumers in the digital era. As integral components in many household devices, batteries have a critical role to play in guaranteeing the performance of consumer products and as such it is paramount to ensure their safety.

ACEA · filed 1 Sept 2020 · source

The European Automobile Manufacturers’ Association (ACEA) believes that the GPSD is still broadly fit for purpose and does not require a major overhaul. At the most, it could be revised in a targeted manner to update some of the definitions with a view to clarifying their applicability.

ACEA · filed 4 Oct 2021 · source

Dear Sir, Ma'am, Please find below ACEA Position and feedback to the consultation. Logically, vehicles can clearly be identified by the individual VIN-Number and it is in the interest of vehicle manufacturers that our customer's are aware of the product manufacturer or recall actions triggers for used goods.

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