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.
Company · Italy
NGO · Germany
Declared costs: not declared · in the register since 2012
Ecodesign requirements for solid fuel local space heaters (review) · Review of energy labelling requirements for solid fuel boilers
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.
Famar Brevetti srl · filed 12 Dec 2023 · source
Italian manufacturers strongly believe in the effectiveness of the Ecodesign Regulation 2015/1185., A revision may be beneficial, but the approach should not change, and Ecodesign should focus on identifying and defining more ambitious yet achievable limits to improve efficiency and emissions of the solid fuel Local Space Heaters (LSHs) stock.
Deutsche Umwelthilfe e.V. · filed 14 Dec 2023 · source
On behalf of Deutsche Umwelthilfe (DUH, Environmental Action Germany), we welcome the revision of the Ecodesign Regulation for solid-fuel local space heaters/SFLSH (EU 2015/1185). Over a fifth of total PM2.5 in Germany comes from small combustion appliances however, as reporting does not include condensables (condensed particles), actual emissions from this sector are much higher.
Famar Brevetti srl · filed 21 Dec 2023 · source
Dear Mr Martinez, Dear Ladies and Gentlemen, Manufacturers strongly believe in the effectiveness of the Ecodesign and Energy labelling Regulations for solid fuel boilers. Manufacturers believe that a revision could be beneficial, but the approach should not change: Ecodesign should focus on identifying and defining achievable limits, solid fuel boilers are a minor source of energy consumption and pollution and…
Deutsche Umwelthilfe e.V. · filed 21 Dec 2023 · source
On behalf of Deutsche Umwelthilfe (DUH, Environmental Action Germany), we welcome the revision of the Ecodesign Regulation for solid fuel boilers/SFB (EU 2015/1189). Over a fifth of total PM2.5 in Germany comes from small combustion appliances however, as reporting does not include condensables (condensed particles), actual emissions from this sector are much higher.
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