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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.

FG
Fertilisants Germiflor

Company · France

2
files engaged
of 583 tracked
2
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
EBI
European Biostimulants Industry Council (EBIC)

Industry association · Belgium

10
files engaged
of 583 tracked
11
positions filed
in those 583 files
1.8
declared FTE
self-declared
0
EP accreditations
as declared to the register

Declared costs: €500K+ a year · in the register since 2014

Files both filed on (2)

Evaluation of the Fertilising Products Regulation · Digital labelling of EU fertilising products

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.

Evaluation of the Fertilising Products Regulation

Fertilisants Germiflor · filed 23 Jun 2025 · source

Regulation (EU) 2019/1009 was intended to simplify access to the European fertilising products market. In practice, its implementation has been transformed into an excessively complex system, particularly penalising organic and organo-mineral fertilisers incorporating animal by-products (ABP).

Filed in French · English published by the European Commission

European Biostimulants Industry Council (EBIC) · filed 19 Sept 2025 · source

The European Biostimulants Industry Council (EBIC) acknowledges the huge benefits brought by the Fertilising Products Regulation (FPR) [Regulation (EU) 2019/1009] through the inclusion of plant biostimulants in its scope, by establishing Product Function Category 6 (PFC 6) according to the function(s) of plant biostimulants, and by allowing plant biostimulants to access the Single Market under harmonised rules.

Digital labelling of EU fertilising products

Fertilisants Germiflor · filed 11 May 2023 · source

Good morning. The principle is well overall. However, I find it aberrant to use digital labelling, even though it is necessary to print information on the packaging or affix a NFC or other chip which will be complicated to reprocess for selective sorting. Or a code that can erase and see access for useless digital etiquettes. This is a double investment for manufacturers.

Filed in French · English published by the European Commission

European Biostimulants Industry Council (EBIC) · filed 26 May 2023 · source

EBIC welcomes the Commission proposal on optional digital labelling. EBIC calls for the introduction of a criterion for professional users versus non-professional users, so that digitisation for products intended for professional users can become a reality. As it stands, the proposal on digital labelling does not go far enough, and most EBIC members would not invest in creating digital labels.

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