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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
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)

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

Transport & Environment · filed 28 Nov 2023 · source

Transport & Environment, Europes leading clean transport campaign group, welcomes the Commissions proposal for a revised End of Life Vehicles law. This law is fundamental to ensure circularity of cars and greening of their production. The revised legislation should be as much about what goes into making a new car (low carbon and recycled materials) as about how its recycled at the end of its life.

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

Transport & Environment · filed 1 Jul 2020 · source

Lithium-ion batteries will be the backbone of the economy’s decarbonisation, notably the EU transport. Unlike combustion engines that burn oil and release harmful emissions, batteries can be reused and recycled at the end of their lives. Batteries are the best technology we have today to make our road transport emissions-free.

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.

Transport & Environment · filed 1 Mar 2021 · source

This submission is made on behalf of four European NGOs: ECOS, EEB (The European Environmental Bureau), Deutsche Umwelthilfe (DUH – Environmental Action Germany, and Transport & Environment, all with an interest in the development of an environmentally sustainable battery value chain in Europe.

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