Side by side
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.
Industry association · United Kingdom
NGO · Germany
Declared costs: not declared · in the register since 2012
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.
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.
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.
Deutsche Umwelthilfe e.V. · filed 13 May 2025 · source
Statement by Deutsche Umwelthilfe on the Amendment of Regulation (EU) 2023/1115 with regard to the List of Relevant Commodities and Products Deutsche Umwelthilfe (DUH) supports a broad product scope that includes all major commodities associated with deforestation. A narrowing of the current scope would reduce the Regulations overall effectiveness and should be avoided. 1.
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.
Deutsche Umwelthilfe e.V. · filed 4 Dec 2023 · source
DUH welcomes the EUs intention to ensure end-of-life vehicles (ELVs) are managed sustainably and re-quiring the car industry to adopt a sustainable design and production of cars as part of the Regulation on Circularity Requirements for Vehicle Design and on Management of End-of-Life Vehicles (VDEoL).
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