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
NGO · Belgium
Declared costs: not declared · in the register since 2008
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.
WWF European Policy Office · filed 13 May 2025 · source
The proposed approach to maintain the initial list of relevant commodities and products in the EUDR scope and to exclude certain products only on the basis that they are not made of relevant commodities will support the implementation of the legislation.
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.
WWF European Policy Office · filed 28 Feb 2020 · source
WWF feedback The intention of both the EUTR and the FLEGT regulation is to fight illegal logging and related trade. A fitness check of the regulations therefore needs to address this overarching objective thoroughly and equally from an economic, social and environmental perspective. EUTR Apparently the fitness check will mainly focus on the implementation of the EUTR over the last years.
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