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 · Switzerland
Industry association · Belgium
Declared costs: €3.5M+ a year · in the register since 2011
Substantiation and communication of explicit environmental claims (Green Claims Directive) · Batteries and waste batteries
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.
Global Alliance on Health and Pollution · filed 31 Aug 2020 · source
The Global Alliance on Health and Pollution (GAHP) is a Swiss foundation and network of 60+ governments, UN and other international organisations, academia and civil society that promotes greater awareness of the fact that although pollution is responsible for 16% of deaths worldwide, almost entirely in low and middle income countries (LMICs), it receives relatively little policy attention and only a tiny fraction…
DIGITALEUROPE · filed 20 Jul 2023 · source
18 July 2023 DIGITALEUROPE feedback on Substantiating Green Claims’ public consultation Executive summary The proposed Green Claims Directive (GCD) is a positive step toward combating greenwashing. However, its effectiveness will depend on enforcement and the establishment of clear methodologies.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
DIGITALEUROPE · filed 6 Jul 2020 · source
DIGITALEUROPE appreciates the opportunity to comment on the inception IA. In the past, we have extensively commented on the ongoing revision of the Batteries Directive (Directive). The inception IA document remains vague on the relationship between the envisaged “new regulatory instrument” and the existing regulatory framework for batteries. Based on the public consultation for the eco-design prep.
Global Alliance on Health and Pollution · filed 9 Jul 2020 · source
The Global Alliance on Health and Pollution (GAHP) is an Swiss foundation and network of 60+ governments, UN and other international organisations, academia and civil society that promotes greater awareness of the fact that although pollution is responsible for 16% of deaths worldwide, almost entirely in low and middle income countries (LMICs), it receives relatively little policy attention and only a tiny fraction…
Global Alliance on Health and Pollution · filed 26 Feb 2021 · source
GAHP is particularly concerned about the unsafe recycling of lead-acid batteries in LMICs and the informal smelting of the recovered lead plates, which is often the first stage of producing secondary lead material used domestically and/or exported for battery manufacturing or other uses.
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