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 · Spain
NGO · Belgium
Declared costs: not declared · in the register since 2010
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.
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.
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.
ECOS · filed 4 Dec 2023 · source
ECOS, the Environmental Coalition on Standards, is an international NGO with a network of members and experts advocating for environmentally friendly technical standards, policies and laws. The old End-of-Life Vehicles Directive has been in force since 2000 with only minor changes and is in urgent need of a fundamental update to meet today's requirements in terms of circular economy and net zero emission targets.
ECOS · filed 9 Jul 2020 · source
Batteries are an essential product to ensure decarbonisation in the EU and its demand is set to grow substantially in the upcoming years. As an environmental civil society organisation, we strongly welcome the initiative of the European Commission to update the legislation that ensures a circular and sustainable value chain for all batteries produced in the EU and placed on the single market.
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.
ECOS · filed 1 Mar 2021 · source
ECOS welcomes the European Commission’s proposal for a new Regulation on batteries and waste batteries (replacing the current Battery Directive) and is pleased to contribute to the consultation on this matter. Together with other European NGOs, namely the EEB (The European Environmental Bureau), Deutsche Umwelthilfe (DUH – Environmental Action Germany), and Transport & Environment, we have developed a joint paper…
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