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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
MED
MEDEF

Industry association · France

44
files engaged
of 583 tracked
50
positions filed
in those 583 files
6.2
declared FTE
self-declared
4
EP accreditations
as declared to the register

Declared costs: €900K+ a year · in the register since 2009

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.

MEDEF · filed 21 Jul 2023 · source

Contribution du MEDEF relative au projet de directive sur les allégations écologiques Les entreprises, en proposant des produits et des services plus respectueux de l’environnement, ont un rôle majeur à jouer dans la transition écologique. Mais elles ne pourront le faire seules, sans l’adhésion de leurs clients et consommateurs finaux.

Filed in French · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

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.

MEDEF · filed 28 May 2022 · source

As part of the new Consumer Agenda launched in June 2020, the European Commission has chosen to revise Directives 2011/83/EC on consumer rights and 2005/29/EC on unfair commercial practices. MEDEF wishes to comment in the attached document.

Filed in French · English published by the European Commission

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.

MEDEF · filed 4 Oct 2021 · source

The French Business Movement (MEDEF) welcomes the publication of this draft Regulation, which partly addresses the major issues raised by MEDEF in its contribution to the new Consumer Agenda of September 2020. We are particularly interested in two main objectives pursued by this revision: — the alignment of product safety and compliance rules in the EU and the alignment of the responsibilities of each economic…

Filed in French · English published by the European Commission

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