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
Industry association · Denmark
Declared costs: €2.3M+ a year · in the register since 2008
Commission Regulation amending the CLP Regulation (EC) 1272/2008 and correcting Commission Regulation (EU) 2018/669 · Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals
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.
hubergroup Deutschland GmbH · filed 1 Feb 2019 · source
The hubergroup produces inks for a wide range of applications. A very large number of our products contain titanium dioxide. Therefore, the planned classification would have far-reaching consequences for our group of companies.
Filed in German · English published by the European Commission
Danish Industry · filed 8 Feb 2019 · source
The Confederation of Danish Industry (DI) welcomes the opportunity to provide comments to public consultation on the draft ATP to the CLP, as part of its Better Regulation approach. DI representsmore than 10,000 private enterprises within manufacturing, trade and services covering most sub-sectors.
hubergroup Deutschland GmbH · filed 25 May 2021 · source
Hubergroup, an European printing inks and chemicals manufacturer with a global presence, welcomes the opportunity to comments on the REACH revision inception impact assessment. We fundamentally agree on the main objectives included in the Chemicals strategy for sustainability (CSS), although we are concerned with the method of implementation and the speed of the action proposed.
Danish Industry · filed 31 May 2021 · source
DI welcomes the possibility to submit our feedback. In general, DI - advices the Commission to strive for a coherent regulation of chemical risks across regulations and to avoid overlapping regulation for chemicals - acknowledges that REACH is the data generating regulation and supports the wish from the Commission to let data on e.g.
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