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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.

2
files engaged
of 583 tracked
3
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
EEB
European Environmental Bureau

Environmental organization · Belgium

52
files engaged
of 583 tracked
60
positions filed
in those 583 files
51.8
declared FTE
self-declared
31
EP accreditations
as declared to the register

Declared costs: not declared · in the register since 2009

Files both filed on (2)

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.

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)

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…

European Environmental Bureau · filed 31 Aug 2020 · source

The EEB welcomes the inception impact assessment for the initiative “Legislative proposal on substantiating green claims”. The EEB actively participates in the Product Environmental Footprint (PEF), its Technical Advisory Board (TAB), as well as the pilot and transition phase projects. The EEB supports the need for standard methodologies to assess the impact on the environment of products on the European market.

European Environmental Bureau · filed 17 Jul 2023 · source

The EEB welcomes the long-awaited proposal for a Green Claims Directive. Please see our attachd position paper and the summary below: 1) Why this legislation is important - The proliferation of misleading and unsubstantiated claims as well as greenwashing are hampering the green transition.

Batteries and waste batteries

European Environmental Bureau · filed 7 Jul 2020 · source

The IIA sets up good directions for the development of policies on batteries. It indicates the need for an ambitious regulatory framework proposal, capturing the largely improved environmental performance and social impacts such as responsible sourcing, while promoting the EU's competitiveness and ensuring long term sustainability, also in view of the EU post COVID-19 green recovery.

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.

European Environmental Bureau · filed 1 Mar 2021 · source

The European Environmental Bureau (EEB) welcomes the proposal presented by the EC, including the the switch from a directive to a regulation which is necessary for a consistent implementation across all Member States, improving harmonisation and legal certainty.

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