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.
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.
GSB Wahl GmbH is a small enterprise producing printing inks for various applications. Many of our products contain titanium dioxide. The proposed amendment to the CLP Regulation would have far-reaching consequences for us as TiO2 is not to be replaced by other substances. The opacity is unique and it is therefore absolutely essential.
Filed in German · English published by the European Commission
The European Recycling Industries’ Confederation – EuRIC AISBL – is an umbrella organization for the recycling industries in Europe. Through its Member Recycling Federations from 20 EU and EFTA countries, EuRIC represents over 5,500 companies, both large companies and SMEs, involved in the recycling and trade of various resource streams; EuRIC welcomes the public consultation on the draft 10th ATP regulation, and…
Ladies and Gentlemen, the company for which I am working, is a small company in the printing ink industry. I work as a freelance worker and focus on regulatory matters. Any additional burden on the company should be kept to a minimum, otherwise it jeopardises competitiveness. If necessary and possible, we will try to meet the requirements with the least effort and create DPP somehow ourselves.
Filed in German · English published by the European Commission
The European Recycling Industries Confederation (EuRIC) welcomes the opportunity to give feedback on the future delegated act laying down rules on the operation of the Digital Product Passport (DPP) and the role of service providers. Overall, EuRIC considers the DPP as a good opportunity for advancing recycling and the circular economy.
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