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.
Company · Germany
Industry association · Belgium
Declared costs: €1.3M+ a year · in the register since 2009
Substantiation and communication of explicit environmental claims (Green Claims Directive) · Digital labelling of EU fertilising products
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.
SMEunited · filed 27 Aug 2020 · source
Putting some order in the world of green claims is definitely useful and important. However, there is a big risk that the use of certain methodologies, such as PEF / OEF, could make life much more difficult for craft and SMEs in terms of higher costs and administrative work.
SMEunited · filed 24 May 2023 · source
SMEunited supports addressing a feasible substantiation of green claims and creating a harmonised legal framework. SMEunited calls for simple, workable and proportionate substantiation criteria in the Directive on Green Claims. The Directive must not result in the use of green claims being reserved for financially strong market players. Therefore, SMEunited calls for changing the Directive in several ways.
K+S AG · filed 20 Jul 2023 · source
As K+S, we see ourselves as pioneers in environmentally friendly and sustainable mining. Our constant efforts to set global standards resulted in several developments of new techniques and processes to better protect the environment and reduce our products footprints and these efforts are on-going.
SMEunited · filed 15 Sept 2021 · source
The European Commission is considering how to improve communication on chemicals. The focus is currently on detergents and fertilizers. In this context, the labelling requirements for these categories of chemical products could be streamlined and digital labelling could be used.
K+S AG · filed 17 May 2023 · source
The Commission aims to improve the communication of labelling information and provide economic operators the flexibility to opt for the rules that are most appropriate for their specific products. In principle, this approach is heavily supported by industry including K+S as it may help save resources and costs, contribute to sustainability and facilitate communication.
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