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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.

3
files engaged
of 583 tracked
4
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
EUR
EuroCommerce

Industry association · Belgium

53
files engaged
of 583 tracked
58
positions filed
in those 583 files
8.3
declared FTE
self-declared
18
EP accreditations
as declared to the register

Declared costs: €800K+ a year · in the register since 2009

Files both filed on (2)

Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals · Digital labelling of EU fertilising products

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.

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

GHC Gerling, Holz & Co. Handels GmbH · filed 1 Jun 2021 · source

To whom it may concern, We are a manufacturer, importer, distributor and user of chemicals and thus, fulfil all roles under REACH. The safe, responsible and sustainable use of chemicals is our highest principle. REACH (Regulation (EC) No 1907/2006) is a milestone in chemical regulation and sets a high level of protection of human health and the environment. It can be said with confidence, that REACH is a success.

EuroCommerce · filed 1 Jun 2021 · source

EuroCommerce supports the objectives of the Chemicals Strategy for Sustainability to better protect citizens and the environment against hazardous chemicals and encourage innovation for the development of safe and sustainable alternatives, and – as one of its actions – a targeted revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals (REACH) regulation.

Digital labelling of EU fertilising products

GHC Gerling, Holz & Co. Handels GmbH · filed 27 Jul 2021 · source

To whom it may concern, labels are overloaded with information. A simplification would be very welcome. However, this initiative should not be limited to CLP regulation, Detergents regulation and Fertilising Products Regulation, but include all EU-regulation and maybe even consider national regulations, which demand information on or next to the CLP-hazard label.For example, the Biocide Product Regulation (Article…

EuroCommerce · filed 20 Sept 2021 · source

EuroCommerce, the principal European organisation representing the retail and wholesale sector, welcomes the opportunity to provide feedback to the roadmap for the simplification and digitalisation of labels on chemicals, and specifically the CLP Regulation, the Detergents Regulation and the Fertilising Products Regulation.

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