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.
EUROBAT, the Association of European Automotive and Industrial Battery Manufacturers, welcomes the European Commissions initiative to strengthen the circular economy and to reinforce the single market for waste and secondary raw materials through the proposed Circular Economy Act.
Position of the Chamber of Commerce of Non-ferrous Metals and Recycling (IGMNiR) representing manufacturers and recyclers in copper, aluminium, zinc, lead, tin and other metal chains. Our members operate competing installations and invest in high-quality recycling.
Filed in Polish · English published by the European Commission
IGMNIR, Poland_Position Paper Protecting workers from exposure to chemicals (lead) Economic Chamber of Non-Ferrous Metals and Recycling („IGMNiR”) associates the largest companies in Poland that produce primary lead, secondary lead and the largest producers of lead batteries.
EUROBAT is the leading association for European automotive and industrial battery manufacturers, covering all battery technologies, and has more than 50 members. The members and staff work with all policymakers, industry stakeholders, NGOs and media to highlight the important role batteries play for decarbonised mobility and energy systems as well as all other numerous applications. EUROBAT welcomes the call…
EUROBAT, the Association of European Automotive and Industrial Battery Manufacturers, welcomes the proposal revising the CMRD and the lowering of the occupational exposure limit (OEL) and biological limit value (BLV) for lead and its compounds. Since 2021, Germany enforces a 15 µgPb/dL BLV. Conversely, 11 Member States still implement the maximum 70 µgPb/dL authorised by the current version of the CMRD.
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