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 · COL
NGO · Germany
Declared costs: not declared · in the register since 2012
Sustainable aviation fuels (ReFuelEU Aviation Initiative) · Sustainable maritime fuels (FuelEU Maritime Initiative)
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.
Deutsche Umwelthilfe e.V. · filed 21 Apr 2020 · source
Environmental Action Germany (Deutsche Umwelthilfe e.V.) welcomes the opportunity to comment on the ReFuelEU initiative. Greenhouse gas emissions from aviation must be reduced urgently. The ReFuelEU inception impact assessment, however, neglects important aspects of sustainability and availability of alternative fuels for aviation.
Fedepalma · filed 18 Nov 2021 · 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.”…
Deutsche Umwelthilfe e.V. · filed 23 Apr 2020 · source
Environmental Action Germany welcomes the opportunity to comment on this EC initiative. We wish to make the following comments: 1. Crop biofuels are more damaging to the climate than fossil fuels. Crop biofuels must be phased out entirely and must not be incentivised for use in shipping. 2. Advanced biofuels based on wastes and residues are not automatically sustainable.
Fedepalma · filed 8 Nov 2021 · source
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.
Fedepalma · filed 8 Nov 2021 · source
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.
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