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.
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.
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
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
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
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
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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