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.
NGO · Austria
Industry association · Belgium
Declared costs: €400K+ a year · in the register since 2011
Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals · Calculation, verification and reporting of data on the separate collection of SUP beverage bottles
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.
Plastics Recyclers Europe · filed 31 May 2021 · source
A different methodological framework for the application for authorization should be allowed, whereby the applicants would be allowed to compare different waste management options for the waste containing the substances in question under the analysis of alternatives. The substitution plan could feature aspects such as the development of technology to remove the substance from the input material.
GLOBAL 2000 · filed 1 Jun 2021 · source
An addendum from GLOBAL 2000: The 0.1 % limit for SVHCs is too high for many substances, such as endocrine disruptors or carcinogenic substances. It is well known that EDCS can be harmful even in the lowest doses, often even more harmful than in higher doses. Therefore, there should be no 0.1 % limit, but SVHCs should have to be declared IMMER.
Filed in German · English published by the European Commission
GLOBAL 2000 · filed 1 Jun 2021 · source
Thank you for the opportunity to make proposals to improve REACH. Global 2000, the Austrian environmental protection organisation, sees the following potential improvements for REACH: Article 33 should be revised: — Companies have to reply IMMER to consumer-Inn enquiries, even if no SVHC is included (otherwise, consumer does not know whether companies simply did not reply, if query was lost, etc.) — time limit of 45…
Filed in German · English published by the European Commission
Plastics Recyclers Europe · filed 16 Jun 2021 · source
Plastics Recyclers Europe (PRE), the association representing the plastics recycling industry, welcomes the drafted implementing decision laying down rules for the application of Directive (EU) 2019/904 (SUPD) as regards the calculation, verification, and reporting of data on the separate collection of waste single-use plastic beverage bottles.
GLOBAL 2000 · filed 17 Jun 2021 · source
GLOBAL 2000 (Friends of the Earth Austria) is pleased to have the opportunity to comment on this draft Implementing Act. The long-awaited draft plays an overriding role for the circular economy and in what form resources and the environment will be conserved. It is the great task of our time to curb our extremely high consumption of resources and the littering of nature.
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