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.
Company · Germany
Company · Germany
Declared costs: €1.8M+ a year · in the register since 2009
Commission Regulation amending the CLP Regulation (EC) 1272/2008 and correcting Commission Regulation (EU) 2018/669 · Digital Product Passport (DPP) service providers
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.
GSB-Wahl GMBH · filed 7 Feb 2019 · 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
Merck · filed 7 Feb 2019 · source
Merck is deeply convinced that from a scientific point of view there is no comprehensible reasoning for the proposed classification as a CMR substance, hence Merck’s position is “no classification of titanium dioxide”.
GSB-Wahl GMBH · filed 15 Nov 2024 · source
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
Merck · filed 9 Dec 2024 · source
Merck Life Science response to EU public consultation on Digital Product Passports rules for service providers public consultation: Merck Life Science would like to provide feedback on several key requirements that are essential for the successful implementation of Digital Product Passports (DPP). We supply scientists with the tools to carry out their work.
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