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 · Japan
Industry association · Germany
Declared costs: €1M+ a year · in the register since 2008
Substantiation and communication of explicit environmental claims (Green Claims Directive) · Common rules promoting the repair of goods
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.
Bitkom e.V. · filed 18 Jul 2023 · source
Bitkom e.V. (Germany's digital association) welcomes the efforts of the European Commission to create more transparency in competition when it comes to environmental claims and to avoid greenwashing. However, in our view, the present proposal for a directive on substantiation and communication of explicit environmental claims (Green Claims Directive) does not appear to be suitable for achieving the objectives…
JP4EE (JEMA, JEITA, CIAJ and JBMIA) · filed 21 Jul 2023 · source
The Japanese electric and electronic industrial associations JEMA, JEITA, CIAJ and JBMIA (JP4EE) welcomes this opportunity to offer feedback concerning the European Commissions proposal for a "DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on substantiation and communication of explicit environmental claims (Green Claims Directive)".
JP4EE (JEMA, JEITA, CIAJ and JBMIA) · filed 25 May 2023 · source
The Japanese electric and electronic industrial associations JEMA, JEITA, CIAJ and JBMIA (JP4EE) welcomes this opportunity to offer feedback concerning the European Commissions proposal for a "DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on common rules promoting the repair of goods and amending Regulation (EU) 2017/2394, Directives (EU) 2019/771 and (EU) 2020/1828".
Bitkom e.V. · filed 25 May 2023 · source
Bitkom e.V. is the German Digital Association and represents more than 2000 member companies from the digital economy. Bitkom members employ more than 2 million employees in Germany. Members include more than 1000 medium-sized businesses, more than 500 start-ups and almost all global players. Thank you for the opportunity to comment and our detailed feedback can be found in the attached file.
Filed in German · English published by the European Commission
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