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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
CEF
Cefic

Industry association · Belgium

73
files engaged
of 583 tracked
111
positions filed
in those 583 files
46.7
declared FTE
self-declared
11
EP accreditations
as declared to the register

Declared costs: €10M+ a year · in the register since 2009

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.

Cefic · filed 13 May 2025 · source

APAG & CESIO (Cefic sector groups representing the European oleochemicals and surfactants industries) welcome the clarifications provided by the Delegated Act to introduce targeted and limited technical fixes. We noticed two discrepancies in the draft delegated act: 1. HS code 382311 (stearic acid, industrial) is not listed in the draft delegated act, while being listed in the original Annex I list.

Cefic · filed 13 May 2025 · source

GME, the Gelatine Manufacturers of Europe (GME), is the leading association of Europe's foremost gelatine manufacturers. GME's mission is to serve the European gelatine industry, to support the products gelatine and collagen peptides and also to inform and communicate with customers, authorities and the media.

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

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.

Cefic · filed 4 Dec 2023 · source

Cefic welcomes the proposed Regulation addressing circularity requirements for vehicle design and the management of end-of-life vehicles (ELV) aiming to replace the 3R type-approval and ELV Directives. As raw material supplier at the top of this value chain, the chemical industry would like to provide feedback on cross cutting aspects of the proposal: Performance and information requirements on substances of…

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