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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.

FER
FER

Industry association · Spain

2
files engaged
of 583 tracked
2
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
CEF
Cefic

Industry association · Belgium

73
files engaged
of 583 tracked
111
positions filed
in those 583 files
46.7
declared FTE
self-declared
11
EP accreditations
as declared to the register

Declared costs: €10M+ a year · in the register since 2009

Files both filed on (2)

Circularity requirements for vehicle design and management of end-of-life vehicles · Batteries and waste 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.

Circularity requirements for vehicle design and management of end-of-life vehicles

FER · filed 2 Dec 2023 · source

FER is the association of the recovery and recycling sector in Spain. Within FER there are large representation of car dismantler and 100% of the vehicle shredders and post- shredders industry in Spain. FER welcomes to this initiative of the COM to improve de circular economy of the vehicles. We attach the position of the Spanish recycling sector, and we are specially concern about two points: 1.

Cefic · filed 4 Dec 2023 · source

Cefic welcomes the proposed Regulation addressing circularity requirements for vehicle design and the management of end-of-life vehicles (ELV) aiming to replace the 3R type-approval and ELV Directives. As raw material supplier at the top of this value chain, the chemical industry would like to provide feedback on cross cutting aspects of the proposal: Performance and information requirements on substances of…

Batteries and waste batteries

FER · filed 26 Feb 2021 · source

FER (Spanish Federation of Recovery and Recycling) welcomes this proposal of a new Battery Regulation. We attached our contibution. Our members are Non-hazardous and hazardous waste managers, waste carriers, Shredders, Post-Shredder/Media separation, Used Tyres treatment or Preparing for re-use/ Pallets.

Cefic · filed 28 Feb 2021 · source

Cefic representing the chemical industry sector in Europe welcomes the European Commission’s legislative proposal for a more comprehensive regulation on Batteries and its objectives including enabling the strengthening of the European production capacities with a common set of rules, contributing to fair and transparent trade/supply chains, enhancing innovation and standardization aspects in support of safety and…

Cefic · filed 1 Mar 2021 · source

Cefic representing the chemical industry sector in Europe welcomes the European Commission’s legislative proposal for a more comprehensive regulation on Batteries and its objectives including enabling the strengthening of the European production capacities with a common set of rules, contributing to fair and transparent trade/supply chains, enhancing innovation and standardization aspects in support of safety and…

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