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.
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.
Comments on Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on ensuring a level playing field for sustainable air transport The Context of the Proposal mentions that “For sustainability reasons, first generation biofuels such as crop-based biofuels Feed, and food and crop-based biofuels, which have limited scalability potential and raise sustainability concerns, should not be supported.”…
APAG welcomes the Commission’s proposal for the ReFuelEU Aviation Regulation. We are pleased by the horizontal alignment with the Renewable Energy Directive (RED II) on sustainable transport fuels and the choice of a Regulation over a Directive. We are delighted that the European Commission’s proposal aims at promoting truly sustainable biofuels for aviation.
Comments to the whereas, in numeral 12: It is important to note that in Colombia, the oil palm that has been generically classified as causing ILUC, has not produced deforestation, nor does it indirectly produce the use of land with high carbon stocks. In Colombia, several studies have shown that oil palm development has not been a major driver for deforestation.
Comments to the whereas, in numeral 12: It is important to note that in Colombia, the oil palm that has been generically classified as causing ILUC, has not produced deforestation, nor does it indirectly produce the use of land with high carbon stocks.
•The European Oleochemicals & Allied Products Group (APAG) welcomes the Commission’s proposal for the FuelEU Maritime Regulation. As we fully support the European Union’s intention to reduce emissions from shipping and would support a more ambitious approach on biofuels, modeled after the Renewable Energy Directive, including: 1.
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