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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.

GKG
2
files engaged
of 583 tracked
2
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
CEF
Cefic

Industry association · Belgium

73
files engaged
of 583 tracked
111
positions filed
in those 583 files
46.7
declared FTE
self-declared
11
EP accreditations
as declared to the register

Declared costs: €10M+ a year · in the register since 2009

Files both filed on (2)

Circularity requirements for vehicle design and management of end-of-life vehicles · Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

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.

Circularity requirements for vehicle design and management of end-of-life vehicles

GERHARDI Kunststofftechnik GmbH · filed 1 Dec 2023 · source

I would like to ask you to bear in mind or assess the following points: A single varietal grouping of waste streams from the different sectors (packaging, construction, electrical, car, etc.) must be possible (open loop) in order to build a sufficient amount of technological, environmental and economic recycling.

Filed in German · English published by the European Commission

Cefic · filed 4 Dec 2023 · source

Cefic welcomes the proposed Regulation addressing circularity requirements for vehicle design and the management of end-of-life vehicles (ELV) aiming to replace the 3R type-approval and ELV Directives. As raw material supplier at the top of this value chain, the chemical industry would like to provide feedback on cross cutting aspects of the proposal: Performance and information requirements on substances of…

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

GERHARDI Kunststofftechnik GmbH · filed 28 May 2021 · source

Implementation of laws and regulations has to be assessed differently in the EU Member States. First, uniform enforcement must be established before laws and regulations are strengthened or expanded. Otherwise, there is a distortion of competition which bans further regulatory initiatives and is contrary to the EU internal market article.

Filed in German · English published by the European Commission

Cefic · filed 31 May 2021 · source

Cefic welcomes the opportunity to provide first insights and suggestions for the REACH Revision Inception Impact Assessment public consultation. REACH is the most comprehensive regulatory framework securing safe use of chemicals. Recent European Commission’s reviews concluded that the system is fit for purpose, delivering on its objectives, and serves as a global model for chemical legislation.

Cefic · filed 31 May 2021 · source

The Microbial Control Executive Council (MCEC) welcomes the opportunity provided by the European Commission to submit views about the forthcoming revision of the EU legislation on registration, evaluation, authorisation and restriction of chemicals (REACH).

Cefic · filed 31 May 2021 · source

The European Melamine Producers Association (EMPA) welcomes the opportunity provided by the European Commission to share views regarding the revision of the REACH Regulation, expected for Q4 2022. With the publication of the Chemicals Strategy for Sustainability in October 2020, the European Commission proposed many actions to review and update the current policy framework on chemicals.

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