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.
Industry association · Belgium
Environmental organization · Belgium
Declared costs: not declared · in the register since 2011
Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals · Stepping up EU Action against Deforestation and Forest Degradation
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.
ETRMA · filed 31 May 2021 · source
ETRMA views on the Inception Impact Assessment on the revision of REACH Brussels, 28th of May 2021 Rubber is a versatile material flexible and resistant used for many applications. The industry producing rubber in Europe is organized in two main blocks. The most visible and known is Tyres present in vehicles.
ClientEarth · filed 1 Jun 2021 · source
A. Context, Problem definition We fully support the analysis of issues related to the knowledge gaps, combination effects, communication in the supply chain, evaluation, and enforcement. However it is both surprising and problematic that the description of the current issues with authorisation does not account for the problems that are the direct consequences of the incorrect interpretation of REACH.
ClientEarth · filed 11 Jan 2019 · source
ClientEarth welcomes the Roadmap as an acknowledgement that the Commission needs to amplify its action to address deforestation and forest degradation. However, we are concerned about the proposed reliance on existing policies and tools to step up EU action, as the Roadmap does not expressly recommend filling gaps in the existing framework with new and targeted policy actions / new regulatory measures.
ETRMA · filed 15 Jan 2019 · source
The European Tyre & Rubber Manufacturers Association (ETRMA) and its members are fully committed to ensure sustainable production and supply of natural rubber. This means looking after the people, communities and natural resources touched by natural rubber production and supply. Therefore, ETRMA supports the Commission’s Deforestation Roadmap initiative.
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