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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 (3)

European climate resilience and risk management law · Sustainable aviation fuels (ReFuelEU Aviation Initiative) · Sustainable maritime fuels (FuelEU Maritime Initiative)

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.

European climate resilience and risk management law

German Environment Agency (UBA) · filed 2 Sept 2025 · source

Climate change is already impacting all regions of Europe, posing complex challenges for human well-being, ecosystems, and the economy. Even though significant progress has been made over the past years, the forthcoming European Climate Resilience and Risk Management Framework (ECRRMF) must take a more ambitious approach to ensure resilience and preparedness across Europe by 2050.

Deutsche Umwelthilfe e.V. · filed 2 Sept 2025 · source

We welcome the European Climate resilience and risk management initiative as an important step toward building resilience in the face of growing climate challenges. In this context, we see nature-based solutions as a key element for effective mitigation and adaptation.

Sustainable aviation fuels (ReFuelEU Aviation Initiative)

German Environment Agency (UBA) · filed 21 Apr 2020 · source

The German Environment Agency (UBA) supports the Commission’s initiative. The current crisis offers a unique opportunity to rethink established business models and to promote sustainable growth. It is a necessary step to achieve the Paris Agreement Climate Goals [1].

Deutsche Umwelthilfe e.V. · filed 21 Apr 2020 · source

Environmental Action Germany (Deutsche Umwelthilfe e.V.) welcomes the opportunity to comment on the ReFuelEU initiative. Greenhouse gas emissions from aviation must be reduced urgently. The ReFuelEU inception impact assessment, however, neglects important aspects of sustainability and availability of alternative fuels for aviation.

Sustainable maritime fuels (FuelEU Maritime Initiative)

German Environment Agency (UBA) · filed 23 Apr 2020 · source

The German Environment Agency (UBA) strongly supports the Commission’s initiative. Especially in the light of the current crisis, it offers a unique opportunity to rethink established business models and to promote sustainable growth. It is a necessary step to achieve the Paris Agreement Climate Goals. Shipping needs a long-term regulatory strategy on the path to climate neutrality.

Deutsche Umwelthilfe e.V. · filed 23 Apr 2020 · source

Environmental Action Germany welcomes the opportunity to comment on this EC initiative. We wish to make the following comments: 1. Crop biofuels are more damaging to the climate than fossil fuels. Crop biofuels must be phased out entirely and must not be incentivised for use in shipping. 2. Advanced biofuels based on wastes and residues are not automatically sustainable.

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