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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.

FED
Fedepalma

Industry association · COL

2
files engaged
of 583 tracked
3
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)

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.

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.

Sustainable aviation fuels (ReFuelEU Aviation Initiative)

Transport & Environment · filed 19 Apr 2020 · source

Overview T&E supports the introduction of a mandate for specific sustainable advanced fuels in the aviation sector, but only if certain conditions are met for such a mandate to provide both a clear environmental benefit and investor certainty.

Transport & Environment · filed 5 Nov 2021 · source

Dear Madam or Sir, Please find attached T&E's position paper on the ReFuelEU Aviation Regulation, which includes our recommendations for SAF targets. We believe that the text has a solid basis, especially when it comes to its scope applying to all departing flights and its exclusion of food and feed crop-based biofuels.

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.”…

Sustainable maritime fuels (FuelEU Maritime Initiative)

Transport & Environment · filed 23 Apr 2020 · source

We welcome the EC initiative to develop an effective EU regulation to drive the uptake of sustainable alternative fuels in EU shipping. We agree with the EC assessment that creating a predictable demand in the shipping industry is essential for the investment and mass scale deployment of sustainable alternative fuels.

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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