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
Other · Austria
Declared costs: €2.8M+ a year · in the register since 2010
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.
Wirtschaftskammer Österreich · filed 11 May 2021 · source
Communication in the supply chain: The current system should become more efficient. The interface with worker protection needs to be improved. The quality and availability of SGMs has improved significantly in recent years. We therefore do not see a need for more information, but rather simplification. Authorisation: This is a major challenge for our businesses.
Filed in German · English published by the European Commission
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.
Wirtschaftskammer Österreich · filed 3 Sept 2020 · source
As early as 2017, it became clear that the availability of the main F-gases in the internal market will be limited. Prices were exploded and supply could no longer be guaranteed for many applications. Only between March and October 2017 did the prices of common refrigerants in Central Europe increase by ~750 %. This trend continued until 2018 and then stabilised.
Filed in German · English published by the European Commission
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…
Wirtschaftskammer Österreich · filed 3 Sept 2021 · source
— Simplification of the label is absolutely necessary, as information on chemical labels is currently overcrowded. Information on the label shall be limited to the most essential information (e.g. CLP marking). Other information (e.g. additional label elements due to specific rules) should be made available digitally.
Filed in German · English published by the European Commission
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