Side by side
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.
Company · France
NGO · Poland
Declared costs: €200K+ a year · in the register since 2020
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.
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.
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
Polish Chamber of Chemical Industry · filed 19 Sept 2025 · source
Proponowany tekst podsumowania The Polish Chamber of Chemical Industry (PIPC), representing the largest fertilizer companies in Poland, welcomes the opportunity to provide input to the evaluation of the EU Fertilising Products Regulation (EU 2019/1009). Our comments focus on ensuring a level playing field, strengthening market transparency, and maintaining high safety and environmental standards.
Polish Chamber of Chemical Industry · filed 17 Sept 2021 · source
In connection with the ongoing consultation process presented by the European Commission on the roadmap for simplifying and digitising labelling requirements, on behalf of the chemical industry, we would like to point out that, in our view, the initiative to simplify and digitise chemical labels, although well founded, requires a very cautious and differentiated approach.
Filed in Polish · English published by the European Commission
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
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