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.
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
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…
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.
The European Recycling Industries’ Confederation (EuRIC) welcomes the Inception Impact Assessment on the revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals (REACH) and its main objective to transition towards a clean Circular Economy.
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