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.
Company · Germany
Environmental organization · Belgium
Declared costs: not declared · in the register since 2011
Delegated Regulation amending Annex I of Regulation (EU) 2023/1115 (EU Deforestation Regulation) · Illegal logging – evaluation of EU rules (fitness check)
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.
GD Holz Service GmbH · filed 2 May 2025 · source
(1) There is a mistake in recital 3: In addition, it is necessary to clarify that the relevant products listed under Wood in Annex I to Regulation (EU) 2023/1115 d o n t fall within the scope of that Regulation if they are made solely of bamboo, rattan, and other materials of woody nature. (2) Tree bark is not wood and therefore not a relevant commodity.
ClientEarth · filed 13 May 2025 · source
We acknowledge and support the Commission's efforts to promote waste recovery and the transition to a circular economy. However, we note that the Delegated Act would extend the existing exception for "waste" products to second-hand and used products.
GD Holz Service GmbH · filed 19 Feb 2020 · source
GD Holz Service GmbH is a recognized EUTR Monitoring Organization. We see the EUTR as a potentially valuable tool to protect forests worldwide. However, only a few EU member states set standards that are high enough to meet this goal. In our opinion, some countries take the EUTR very serious whereas others don’t really care. As long as this is happening, the EUTR remains inefficient.
ClientEarth · filed 28 Feb 2020 · source
ClientEarth considers that both the EUTR & FLEGT Regulation have contributed to more legality and transparency in the global timber supply chain and have made progress towards achieving the objectives of the FLEGT Action Plan.
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