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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.

EUR
EurEau

Industry association · Belgium

25
files engaged
of 583 tracked
27
positions filed
in those 583 files
1.2
declared FTE
self-declared
4
EP accreditations
as declared to the register

Declared costs: €100K+ a year · in the register since 2012

Files both filed on (2)

Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals · Revision of EU rules on textile labelling

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.

Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

Gammacolor srl · filed 7 May 2021 · source

Buongiorno, starting with the summary < < The European Green Deal sets the objective of zero pollution for a toxic-free environment. > >. We are again making the mistake not to distinguish PERICOLO from RISK. Toxic/hazardous substances will always exist. It is the risk that needs to be managed to minimise the hazard.

Filed in Italian · English published by the European Commission

Gammacolor srl · filed 11 May 2021 · source

The commitment to the Green Deal must not be a European exclusive, otherwise we would only harm our economy and industry. The competent authorities must absolutely dialogue with the Asian ones, due to their not very green and safe vision when they export goods, unlike when they import them, where they are very careful. It cannot always pay the EU industry, especially SMEs.

Gammacolor srl · filed 18 May 2021 · source

The latest REACh update of 2018 concluded that it is effective but that there are opportunities for further improvement, simplification and burden reduction. On the reduction of burdens, we have already said countlessly that it is not these actions that make the registration process sustainable, but the SIMPLIFICATION must be done and not just with words. A simplification / improvement would be a check on the SIEFs.

Gammacolor srl · filed 25 May 2021 · source

I am pleased with such a large participation in this important public consultation on REACh. 10 years ago in the various surveys, the comments could be counted on the fingers of one hand, we were very few. I do not know how much the Commission will value our comments, which I want to clarify are not complaints, but serious analyzes and possible solutions. Thanks to everyone we continue to have our say!

EurEau · filed 29 May 2021 · source

EurEau is the European association of water service providers with 34 national member organisations in 29 countries. ~ Drinking water suppliers have been raising concerns about persistent, mobile and toxic (PMT) and very persistent, very mobile (vPvM) substances as they can still be detected decades after their withdrawal from the market.

Revision of EU rules on textile labelling

EurEau · filed 11 Sept 2023 · source

EurEau welcomes this initiative. The revision should be used to steer textile consumption patterns in a more sustainable direction by increasing transparency on environmental impacts and, hence, make sustainable practices more visible. Textile life cycles strongly affect the quality and quantity of water resources.

Gammacolor srl · filed 21 Sept 2023 · source

It must be precise and standardised without leaving room for interpretation, as is the case for certain aspects of the textile/fashion world, one of which has been confused with azo dyes. Here, apart from the REACh Regulation, which explains it very well, many NGOs that are unreliable, but with great media resonance, have always used the term azotic or azo as a synonym of a serious danger to health.

Filed in Italian · English published by the European Commission

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