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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.

IGM
IGMNIR

Industry association · Poland

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

Files both filed on (2)

Circular Economy Act · Limit values for lead and its inorganic compounds and diisocyanates

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.

Circular Economy Act

KGHM Polska Miedź S.A. · filed 14 Oct 2025 · source

In connection with the European Commissions commencement of work on the assumptions for the new Circular Economy Act, KGHM Polska Miedź S.A. presents its position below. The main objective of the new regulations should be to support and develop existing waste management models, increasing the availability of secondary raw materials and removing barriers that limit the competitiveness of enterprises during the…

IGMNIR · filed 5 Nov 2025 · source

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

Limit values for lead and its inorganic compounds and diisocyanates

IGMNIR · filed 21 Mar 2022 · source

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.

KGHM Polska Miedź S.A. · filed 21 Mar 2022 · source

KGHM Polska Miedź S.A. (KGHM) is one of the world’s leading companies in the mining and production of copper and silver. The company also produces other accompanying metals, which results from the properties of the exploited polymetallic deposit. The lead production process is an extremely important element/stage in the copper production process at KGHM.

Filed in Polish · English published by the European Commission

KGHM Polska Miedź S.A. · filed 26 Apr 2023 · source

Following the public consultation announced by the European Commission on the revision of Council Directive 98/24/EC and European Parliament and Council Directive 2004/37/EC concerning OEL and BLV for lead and its inorganic compounds and diisocyanates we enclose the position of KGHM Polska Miedź S.A. on this matter and the comments of our company with respect to the Impact Assessment document.

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