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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
77
files engaged
of 583 tracked
87
positions filed
in those 583 files
15
declared FTE
self-declared
0
EP accreditations
as declared to the register

Declared costs: €2.8M+ a year · in the register since 2010

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)

Wirtschaftskammer Österreich · filed 28 Aug 2020 · source

• In general: EU framework for methodology on PEF and OEF on voluntary basis in a harmonised matter may be useful – mandatory system not first choice, different P(O)EFCRs in Member States to be avoided – therefore WKO proposing to consider option 1 (update of PEFs and OEFs) or 2 (voluntary legal framework), currently not option 3 (legal framework establishing obligation for claims by PEF/OEF) because of costs and…

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…

Wirtschaftskammer Österreich · filed 5 Jul 2023 · source

WKO Position Paper Short Summary - Proposal for a Green Claims Directive: less restrictions for the benefit of consumer orientation more exemptions and support for SMEs, implementation leeway needed substantiation to be simplified radically verification and authority-OK to be deleted national, regional and private labels to be exempted from verification in any case.

Batteries and waste batteries

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…

Wirtschaftskammer Österreich · filed 9 Jul 2020 · source

The Austrian Chamber of Commerce expresses its gratitude for the opportunity to comment on the initiative “Modernisation of the EU rules on batteries”. • Concerning sustainability and competitiveness in the management of waste batteries is to be welcomed • The intended strengthening of secondary raw materials markets is also positive.

Filed in German · English published by the European Commission

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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