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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.

FFV
Facing Finance e.V.

NGO · Germany

2
files engaged
of 583 tracked
2
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
TE
49
files engaged
of 583 tracked
59
positions filed
in those 583 files
21.7
declared FTE
self-declared
26
EP accreditations
as declared to the register

Declared costs: not declared · in the register since 2010

Files both filed on (2)

Circular Economy Act · Sustainability requirements for batteries

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.

Circular Economy Act

Facing Finance e.V. · filed 3 Nov 2025 · source

In different studies we have analyzed how financial market participants such as banks and ESG rating providers consider plastics and circularity, showing that they currently lack an integration of plastics criteria (https://www.facing-finance.org/en/2025/09/plastic-money-are-banks-turning-a-blind-eye-to-the-plastic-crisis/ …

Transport & Environment · filed 6 Nov 2025 · source

The Circular Economy Act (CEA) will be key to scaling Europes recycling industry across batteries, steel, aluminium and beyond, whilst also promoting greater materials recovery from other waste streams. Building up local recycling companies and getting recycling production going will be key to building a sustainable electric vehicle industry, whilst driving industrial opportunities in Europe and creating resilient…

Sustainability requirements for batteries

Facing Finance e.V. · filed 6 Feb 2019 · source

We welcome the initiative to introduce responsible sourcing standards for the production of batteries, as the minerals used for battery production can have a significant impact on the communities and the environment they are sourced from.

Transport & Environment · filed 6 Feb 2019 · source

The main objective should be to reduce the overall environmental footprint of the whole battery supply chain from the upstream materials sourcing to the downstream battery and car manufacturing. Only ethically sourced materials and sustainable battery manufacturing can underpin EU decarbonisation. Some downstream companies have already launched initiatives to improve mining standards and local benefit sharing, e.g.

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