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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.

HDG
hubergroup Deutschland GmbH

Company · Germany

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

Industry association · Belgium

26
files engaged
of 583 tracked
31
positions filed
in those 583 files
2
declared FTE
self-declared
8
EP accreditations
as declared to the register

Declared costs: €800K+ a year · in the register since 2009

Files both filed on (2)

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.

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.

Commission Regulation amending the CLP Regulation (EC) 1272/2008 and correcting Commission Regulation (EU) 2018/669

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

EUROFER · filed 8 Feb 2019 · source

EUROFER Feedback with regards to: “Ref. Ares(2019)141469 - 10/01/2019 The European Steel Association (EUROFER) is pleased to submit the following comments on the ‘Hazardous chemicals — new rules on classification, labelling and packaging’, in particular with regards to Cobalt Harmonised Classification and Labelling (CLH).

Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

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.

EUROFER · filed 1 Jun 2021 · source

The European steel industry, represented by EUROFER, welcomes the European Commission’s Inception Impact Assessment for the revision of EU legislation on Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), which aims to clarify the interface between the REACH and other legislation and improving the overall REACH process.

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