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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.

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

Deutsche Umwelthilfe e.V. · filed 4 Dec 2023 · source

DUH welcomes the EUs intention to ensure end-of-life vehicles (ELVs) are managed sustainably and re-quiring the car industry to adopt a sustainable design and production of cars as part of the Regulation on Circularity Requirements for Vehicle Design and on Management of End-of-Life Vehicles (VDEoL).

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

Deutsche Umwelthilfe e.V. · filed 31 May 2021 · source

The Deutsche Umwelthilfe e.V. (DUH) strongly supports the ambition in the Chemicals Strategy for Sustainability to introduce 1) endocrine disruptors, 2) persistent, mobile and toxic and 3) very persistent and very mobile substances as important categories of chemical substances of very high concern within REACH.

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