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 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.
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.
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.
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 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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