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.
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 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.
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, 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.
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.
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.
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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