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.
Trade union · Netherlands
Trade union · Belgium
Declared costs: €700K+ a year · in the register since 2009
Fair labour mobility package: Skills portability 1: digitalised cross-border portability of qualifications and skills · Minimum requirements on minimum breaks and daily and weekly rest periods in the occasional passenger transport sector
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.
FNV · filed 20 Feb 2026 · source
FNV: General views on Skills Portability 1. Labour shortages in several industries highlight the need for better labour market where mobility can contribute to improved employability. The aim of the initiative should be to enhance employability and job quality and to ensure that the skills and qualifications of Europes workforce are fully valued. 2.
European Transport Workers' Federation · filed 27 Feb 2026 · source
The European Transport Workers Federation ETF is the pan-European organization representing over 5 million transport workers, operating on land, sea or air. ETF's points are better detailed in the document attached. ETF, in principle, stands behind the objective of the Skills Portability Initiative.
FNV · filed 17 Feb 2021 · source
The work of a coach driver has already been extensively discussed. It must therefore be clear now that there are no real rest periods during the period of service. It is therefore extremely important, even vital, to regulate rest and leisure opportunities very well.
Filed in Dutch · English published by the European Commission
European Transport Workers' Federation · filed 18 Feb 2021 · source
The European Transport Workers' Federation (ETF) considers that any change to the current EU legal framework on driving and rest time rules in bus and coach will come against the policy objectives of the Regulation. It will fail to improve working conditions in the sector, and will negatively impact the safety of drivers, passengers, and all other road users.
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