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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.

HA
Holocenic AB

Company · Sweden

2
files engaged
of 583 tracked
2
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
CEF
Cefic

Industry association · Belgium

73
files engaged
of 583 tracked
111
positions filed
in those 583 files
46.7
declared FTE
self-declared
11
EP accreditations
as declared to the register

Declared costs: €10M+ a year · in the register since 2009

Files both filed on (2)

Monitoring, reporting and verification of greenhouse gas emissions from maritime transport · Sustainable maritime fuels (FuelEU Maritime Initiative)

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.

Monitoring, reporting and verification of greenhouse gas emissions from maritime transport

Cefic · filed 26 Nov 2020 · source

The ETS should remain a core policy instrument to establish CO2 abatement at the lowest practicable cost to society. We do not favor inclusion of other sectors such as transport and buildings as an extension of the ETS current scheme, which already has to cope with different sectors with distinct elasticities, and risks on carbon leakage in one system.

Holocenic AB · filed 8 Nov 2021 · source

EU ETS - feedback from Holocenic Holocenic is a Swedish management consulting company working in the energy and transportation sectors towards a green transition. Our mission is to reduce global warming. Holocenic welcomes the proposal to add shipping to the EU ETS because it will be an effective instrument to incentivize emission reduction. However, we have a few remarks below.

Sustainable maritime fuels (FuelEU Maritime Initiative)

Holocenic AB · filed 8 Nov 2021 · source

FuelEU Maritime - Holocenic reply Holocenic is a Swedish management consulting company working in the energy and transportation sectors towards a green transition. Our mission is to reduce global warming. Holocenic welcomes the proposal “Regulation on the use of renewable and low-carbon fuels in maritime transport” as it has the potential to decarbonize shipping in Europe while showing the way for the global…

Cefic · filed 8 Nov 2021 · source

•The European Oleochemicals & Allied Products Group (APAG) welcomes the Commission’s proposal for the FuelEU Maritime Regulation. As we fully support the European Union’s intention to reduce emissions from shipping and would support a more ambitious approach on biofuels, modeled after the Renewable Energy Directive, including: 1.

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