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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

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

UNIFA · filed 19 Sept 2025 · source

The Union of Fertilisation Industries (UNIFA) represents the plant nutrition and soil health industries. Mr UNIFA thanked the European Commission for carrying out an evaluation of this regulation, given that it had recently been implemented, just over 3 years and what was still not complete.

Filed in French · English published by the European Commission

Digital labelling of EU fertilising products

UNIFA · filed 20 Sept 2021 · source

The Union des Industries de la Fertilisation (UNIFA) welcomes the European Commission’s initiative to digitise labels for the fertilising products sector. It is already difficult to declare all the labelling elements required under the current Fertilisers Regulation (EC) No 2003/2003, Regulation (EC) No 1272/2008 (CLP) and the international agreements on the transport of dangerous goods (e.g. ADR/RID).

Filed in French · 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

UNIFA · filed 26 May 2023 · source

Mr LUNIFA welcomed the proposed regulation on the digital labelling of fertilising products. The introduction of this option for fertilising products is beneficial: — for the environment: this reduces the amount of waste (e.g. when changing the information on the label). — for users: they may have more legible and accurate information than on labels of limited format.

Filed in French · English published by the European Commission

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