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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

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

Enel · filed 13 Nov 2020 · source

Enel SpA, a multinational company in the energy sector and active in the e-mobility value chain, highly appreciates the EC initiative to revise the Directive 2000/53/EC on end-of-life vehicles (ELV) to prevent waste from vehicles, promote reuse, recycling and other forms of recovery of ELVs and their components so as to reduce the disposal of waste and improve the environmental performance of all economic operators…

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.

Batteries and waste batteries

Enel · filed 7 Jul 2020 · source

Dear Members of DG ENV.Unit B3 – Waste Management & Secondary Materials Enel SpA, a multinational company in the energy sector highly appreciates the EC initiative to ensure a competitive, circular, sustainable, and safe value chain for all batteries placed on the Union 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.

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