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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.

GAC
Global Affairs Canada

Public authority · Canada

2
files engaged
of 583 tracked
2
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
BV
Bitkom e.V.

Industry association · Germany

53
files engaged
of 583 tracked
61
positions filed
in those 583 files
7
declared FTE
self-declared
2
EP accreditations
as declared to the register

Declared costs: €1M+ a year · in the register since 2008

Files both filed on (2)

Substantiation and communication of explicit environmental claims (Green Claims Directive) · Cyber Resilience Act

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.

Substantiation and communication of explicit environmental claims (Green Claims Directive)

Bitkom e.V. · filed 18 Jul 2023 · source

Bitkom e.V. (Germany's digital association) welcomes the efforts of the European Commission to create more transparency in competition when it comes to environmental claims and to avoid greenwashing. However, in our view, the present proposal for a directive on substantiation and communication of explicit environmental claims (Green Claims Directive) does not appear to be suitable for achieving the objectives…

Global Affairs Canada · filed 20 Jul 2023 · source

July 20, 2023 European Commission Brussels, Belgium Subject: Government of Canada Comments on the European Commission Proposal for a Directive of the European Parliament and of the Council on substantiation and communication of explicit environmental claims (Green Claims Directive) To Whom It May Concern, The Government of Canada welcomes the opportunity to submit feedback on the European Commission’s Proposal for a…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Cyber Resilience Act

Global Affairs Canada · filed 25 May 2022 · source

Canada appreciates the opportunity offered by the European Commission to provide feedback on the Commission’s new European Cyber Resilience Act (CRA). Canada strongly supports the legitimate objective of strengthening the cybersecurity of digital products, and recognizes the increased threat to security and privacy caused by the rising number of these products.

Bitkom e.V. · filed 20 Jan 2023 · source

Bitkom appreciates the opportunity to provide feedback on the Commissions proposal for a Cyber Resilience Act. Please find our position paper attached. We welcome the proposal to create a more efficient legal framework to improve cybersecurity in Europe. Nevertheless, some important aspects should be optimized and clarified during the legislative process.

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