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
Industry association · Belgium
Declared costs: €1M+ a year · in the register since 2011
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.
International Road Transport Union (IRU) · filed 27 Feb 2026 · source
CAS/BR10379/SMR Brussels, 26 February 2026 IRU CONTRIBUTION TO THE CALLS FOR EVIDENCE AND CONSULTATIONS ON THE FAIR LABOUR MOBILITY PACKAGE Click here to enter comments IRU contribution to the open calls for evidence and consultations on the Fair Labour Mobility Package initiatives I.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
International Road Transport Union (IRU) · filed 27 Feb 2026 · source
CAS/BR10379/SMR Brussels, 26 February 2026 IRU CONTRIBUTION TO THE CALLS FOR EVIDENCE AND CONSULTATIONS ON THE FAIR LABOUR MOBILITY PACKAGE Click here to enter comments IRU contribution to the open calls for evidence and consultations on the Fair Labour Mobility Package initiatives I.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
International Road Transport Union (IRU) · filed 27 Feb 2026 · source
CAS/BR10379/SMR Brussels, 26 February 2026 IRU CONTRIBUTION TO THE CALLS FOR EVIDENCE AND CONSULTATIONS ON THE FAIR LABOUR MOBILITY PACKAGE Click here to enter comments IRU contribution to the open calls for evidence and consultations on the Fair Labour Mobility Package initiatives I.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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
International Road Transport Union (IRU) · filed 18 Feb 2021 · source
IRU, the voice of the commercial road transport sector, welcomes the opportunity to participate in the initiative of the European Commission (EC) inception impact assessment specifically relating to the “need for specific driving and rest time rules for drivers in occasional transport of passengers”.
International Road Transport Union (IRU) · filed 19 Jul 2023 · source
IRU welcomes the European Commission's proposal for specific derogations on driving and rest time rules applicable to coach tourism drivers in the EU. This acknowledges the specificity of coach tourism as a peoples business, including the fact that the current rules are not suited for group tourism by coach.
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