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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
FERTIBERIA

Company · 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
EUR
EuroCommerce

Industry association · Belgium

53
files engaged
of 583 tracked
58
positions filed
in those 583 files
8.3
declared FTE
self-declared
18
EP accreditations
as declared to the register

Declared costs: €800K+ a year · in the register since 2009

Files both filed on (2)

Digital labelling of EU fertilising products · Evaluation of the Regulation 2019/515 on the Mutual Recognition of Goods

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.

Digital labelling of EU fertilising products

FERTIBERIA · filed 17 Sept 2021 · source

Dear Sirs, I represents Fertiberia, the Spanish fertilizer producer. My comments in line with Fertilizers Europe and with ANFFE (National Spanish Association) are: 1) We support digital labelling due to the volume of information required now by the new Regulation and CLP, etc 2) We consider digital labelling permite to save packaging costs, 3) We think digital labelling facilitate the management of changes in the…

EuroCommerce · filed 20 Sept 2021 · source

EuroCommerce, the principal European organisation representing the retail and wholesale sector, welcomes the opportunity to provide feedback to the roadmap for the simplification and digitalisation of labels on chemicals, and specifically the CLP Regulation, the Detergents Regulation and the Fertilising Products Regulation.

Evaluation of the Regulation 2019/515 on the Mutual Recognition of Goods

FERTIBERIA · filed 2 Jan 2024 · source

Our company’s experience when it has applied for mutual recognition of a fertilising product has been rather negative. The evaluation of the mutual recognition file in the relevant administration, for example in France, is very slow and cumbersome with successive requests for information that makes the process very slow and commercially unoperational.

Filed in Spanish · English published by the European Commission

EuroCommerce · filed 26 Jan 2024 · source

Retail and wholesale companies and European consumers have greatly benefited from free trade within the Single Market. Free movement of goods enabled them retailers and wholesalers to provide their customers with a wider choice of products for lower prices.

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