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.
• In general: EU framework for methodology on PEF and OEF on voluntary basis in a harmonised matter may be useful – mandatory system not first choice, different P(O)EFCRs in Member States to be avoided – therefore WKO proposing to consider option 1 (update of PEFs and OEFs) or 2 (voluntary legal framework), currently not option 3 (legal framework establishing obligation for claims by PEF/OEF) because of costs and…
WKO Position Paper Short Summary - Proposal for a Green Claims Directive: less restrictions for the benefit of consumer orientation more exemptions and support for SMEs, implementation leeway needed substantiation to be simplified radically verification and authority-OK to be deleted national, regional and private labels to be exempted from verification in any case.
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.
— Simplification of the label is absolutely necessary, as information on chemical labels is currently overcrowded. Information on the label shall be limited to the most essential information (e.g. CLP marking). Other information (e.g. additional label elements due to specific rules) should be made available digitally.
Filed in German · English published by the European Commission
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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