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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.

ECF
European Caravan Federation (ECF)

Industry association · Germany

2
files engaged
of 583 tracked
2
positions filed
in those 583 files
0.5
declared FTE
self-declared
0
EP accreditations
as declared to the register

Declared costs: under €10K a year · in the register since 2016

CEF
Cefic

Industry association · Belgium

73
files engaged
of 583 tracked
111
positions filed
in those 583 files
46.7
declared FTE
self-declared
11
EP accreditations
as declared to the register

Declared costs: €10M+ a year · in the register since 2009

Files both filed on (2)

Circularity requirements for vehicle design and management of end-of-life vehicles · Type-approval of motor vehicles and engines with respect to their emissions and battery durability (Euro 7)

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.

Circularity requirements for vehicle design and management of end-of-life vehicles

European Caravan Federation (ECF) · filed 4 Dec 2023 · source

The ECF supports the move to a better environmentally friendly industry and is working with its partners on many aspects to improve this including the materials used in the manufacture to enable a reduction in our effect on the environment. However, we feel the inclusion of trailers in the End-of-life vehicle Regulation will have a very minimal benefit with an out of proportion cost to the industry.

Cefic · filed 4 Dec 2023 · source

Cefic welcomes the proposed Regulation addressing circularity requirements for vehicle design and the management of end-of-life vehicles (ELV) aiming to replace the 3R type-approval and ELV Directives. As raw material supplier at the top of this value chain, the chemical industry would like to provide feedback on cross cutting aspects of the proposal: Performance and information requirements on substances of…

Type-approval of motor vehicles and engines with respect to their emissions and battery durability (Euro 7)

Cefic · filed 24 Apr 2020 · source

Increasing the efficiency of the Internal Combustion Engine (ICE) has been the core driver of emissions reduction of passenger transport to date. In fact, average tailpipe CO2 emissions from petrol cars dropped by more than 30% between 2000 and 2016, largely due to increased performance of engines. At the same time, the fuel used in the car, also played an important part in making today’s cars cleaner.

European Caravan Federation (ECF) · filed 3 Jun 2020 · source

The European Caravan Federation (ECF) is the umbrella organisation representing the national organisations of the European Caravanning Industry. Membership of the ECF consists of 13 caravanning federations and numerous national members of the caravanning industry within the EU member states.

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