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
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).
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 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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