Side by side
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.
Company · Germany
Industry association · Belgium
Declared costs: €1.3M+ a year · in the register since 2009
Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals · Fluorinated gases regulation · 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.
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.
SMEunited · filed 20 May 2021 · source
The EU needs a general simplification of its chemicals legislation and a chemicals policy, which is more inclusive for SMEs. The Commission should give high priority to this aspect during the evaluation of the REACH Regulation. In more detail SMEunited suggests: It should be explored, how to further exploit the obligatory data/cost sharing to reduce burden.
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.
SMEunited · filed 4 Sept 2020 · source
Already in 2017 it was obvious that the availability of crucial f-gases in the internal market would become limited. Prices were exploding, supply could not be guaranteed for many applications. Only between March and October 2017 prices in central Europe increased to ~750% for common cooling agents. This trend continued into 2018 and stabilised then.
GHC Gerling, Holz & Co. Handels GmbH · filed 5 Sept 2020 · source
Dear Sir or Madam, Regulation (EU) No 517/2014 of the European Parliament and of the Council (F Gas-Regulation) aims to protect the environment by reducing emissions of fluorinated greenhouse gases (F Gases). Many F Gases show a high global warming potential (GWP).
GHC Gerling, Holz & Co. Handels GmbH · filed 29 Jun 2022 · source
Feedback of GHC Gerling, Holz & Co. Handels GmbH on Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on HFCs, amending Directive (EU) 2019/1937 and repealing Regulation (EU) No 517/2014 GHC Gerling, Holz & Co. Handels GmbH (GHC) is an importer and distributer of chemical gases, including Hydrofluorocarbons (HFCs) and their alternatives.
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…
SMEunited · filed 15 Sept 2021 · source
The European Commission is considering how to improve communication on chemicals. The focus is currently on detergents and fertilizers. In this context, the labelling requirements for these categories of chemical products could be streamlined and digital labelling could be used.
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