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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.

IPH
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)

Sustainable aviation fuels (ReFuelEU Aviation Initiative) · Sustainable maritime fuels (FuelEU Maritime Initiative)

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.

Sustainable aviation fuels (ReFuelEU Aviation Initiative)

International PtX Hub Berlin · filed 21 Apr 2020 · source

The International PtX Hub Berlin recognises the EU Commission’s Initiative „ReFuelEU Aviation – Sustainable Aviation Fuels“ and is prepared to contribute to its conceptual design, implementation, management and monitoring, in particular with respect to synthetic E-fuels from sustainable Power to X (PtX) processes, both within the EU and beyond.

Deutsche Umwelthilfe e.V. · filed 21 Apr 2020 · source

Environmental Action Germany (Deutsche Umwelthilfe e.V.) welcomes the opportunity to comment on the ReFuelEU initiative. Greenhouse gas emissions from aviation must be reduced urgently. The ReFuelEU inception impact assessment, however, neglects important aspects of sustainability and availability of alternative fuels for aviation.

Sustainable maritime fuels (FuelEU Maritime Initiative)

Deutsche Umwelthilfe e.V. · filed 23 Apr 2020 · source

Environmental Action Germany welcomes the opportunity to comment on this EC initiative. We wish to make the following comments: 1. Crop biofuels are more damaging to the climate than fossil fuels. Crop biofuels must be phased out entirely and must not be incentivised for use in shipping. 2. Advanced biofuels based on wastes and residues are not automatically sustainable.

International PtX Hub Berlin · filed 24 Apr 2020 · source

The International PtX Hub Berlin recognises the EU Commission’s Initiative „ FuelEU Maritime – Green European Maritime Space “ and is prepared to contribute to its conceptual design, implementation, management and monitoring, in particular with respect to synthetic E-fuels from sustainable Power to X (PtX) processes, both within the EU and beyond.

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