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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.

ICT
International Council of Tanners

Industry association · United Kingdom

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

Industry association · Belgium

46
files engaged
of 583 tracked
55
positions filed
in those 583 files
19.5
declared FTE
self-declared
11
EP accreditations
as declared to the register

Declared costs: €5.5M+ a year · in the register since 2008

Files both filed on (2)

Delegated Regulation amending Annex I of Regulation (EU) 2023/1115 (EU Deforestation Regulation) · Circularity requirements for vehicle design and management of end-of-life vehicles

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.

Delegated Regulation amending Annex I of Regulation (EU) 2023/1115 (EU Deforestation Regulation)

International Council of Tanners · filed 12 May 2025 · source

The International Council of Tanners (ICT) is the global organisation for the leather producing industry. ICT is deeply concerned about the implications of the EU Deforestation Regulations (EU-DR) for the global leather supply chain. Leather manufacturers have no influence on the first stages of the supply chain, where deforestation occurs, and are not involved in the sourcing and tracing of livestock.

ACEA · filed 12 May 2025 · source

The European Automobile Manufacturers' Association (ACEA) in general welcomes the EU Commission's efforts to provide further guidance and clarity on the implementation of the EU Deforestation Regulation (EUDR). However, key issues remain, adding additional/unnecessary burdens and leading to legal uncertainties for our industry.

Circularity requirements for vehicle design and management of end-of-life vehicles

ACEA · filed 19 Nov 2020 · source

The ELV Directive, which came into force 20 years ago largely delivered on its initial objectives due to the significant efforts made by the automotive and the recycling industry. The European Automobile Manufacturers’ Association (ACEA) fully supports the European Commission’s initiative to ensure a better consistency with the objectives of the European Green Deal, including the Circular Economy Action Plan and the…

International Council of Tanners · filed 4 Dec 2023 · source

The International Council of Tanners welcomes the efforts by the European Union to reduce the environmental impact of End of Life Vehicles. However, we are concerned that there has been no focus on the use of truly circular materials, such as leather, in place of problem materials, like plastic.

ACEA · filed 4 Dec 2023 · source

The European Automobile Manufacturers' Association (ACEA) is firmly committed to advancing the EU towards a modern, resource-efficient, and competitive economy. We welcome the European Commission's Proposal for a Regulation on circularity requirements for vehicle design and on management of end-of-life vehicles (ELVs), which envisages a transformation towards enhanced sustainability, circularity, and innovation.

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