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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
EEB
European Environmental Bureau

Environmental organization · Belgium

52
files engaged
of 583 tracked
60
positions filed
in those 583 files
51.8
declared FTE
self-declared
31
EP accreditations
as declared to the register

Declared costs: not declared · 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

European Environmental Bureau · filed 19 Nov 2020 · source

The EEB welcomes the Commissions' objective to revise the ELV Directive, aiming at achieving reductions of negative social, economic and environmental impacts of the sector, and equally important to bring the sector closer to the approach of circular economy.

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.

European Environmental Bureau · filed 4 Dec 2023 · source

Motor vehicles constitute a significant repository of valuable materials. This makes the automotive industry a pivotal player in saving resources and curbing carbon emissions through circular economy practices. In this context, the EEB welcomes the proposal for a Regulation on Vehicle Design and End of Life Management (VDEoL), notably: The extension of the scope to cover vehicles beyond passenger cars Requirements…

Batteries and waste batteries

European Environmental Bureau · filed 7 Jul 2020 · source

The IIA sets up good directions for the development of policies on batteries. It indicates the need for an ambitious regulatory framework proposal, capturing the largely improved environmental performance and social impacts such as responsible sourcing, while promoting the EU's competitiveness and ensuring long term sustainability, also in view of the EU post COVID-19 green recovery.

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.

European Environmental Bureau · filed 1 Mar 2021 · source

The European Environmental Bureau (EEB) welcomes the proposal presented by the EC, including the the switch from a directive to a regulation which is necessary for a consistent implementation across all Member States, improving harmonisation and legal certainty.

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