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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
EEB
European Environmental Bureau

Environmental organization · Belgium

52
files engaged
of 583 tracked
60
positions filed
in those 583 files
51.8
declared FTE
self-declared
31
EP accreditations
as declared to the register

Declared costs: not declared · 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

European Environmental Bureau · filed 19 Nov 2020 · source

The EEB welcomes the Commissions' objective to revise the ELV Directive, aiming at achieving reductions of negative social, economic and environmental impacts of the sector, and equally important to bring the sector closer to the approach of circular economy.

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

European Environmental Bureau · filed 4 Dec 2023 · source

Motor vehicles constitute a significant repository of valuable materials. This makes the automotive industry a pivotal player in saving resources and curbing carbon emissions through circular economy practices. In this context, the EEB welcomes the proposal for a Regulation on Vehicle Design and End of Life Management (VDEoL), notably: The extension of the scope to cover vehicles beyond passenger cars Requirements…

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

European Environmental Bureau · filed 1 Jun 2021 · source

The REACH Regulation is an essential tool for chemicals control in Europe. However, it needs to be improved to support the implementation and the level of ambition of the Chemicals Strategy for Sustainability (CSS).

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