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.
We applaud the increased climate ambitions of the Union, but we have to emphasise that setting a goal of climate neutrality by 2050 still is to take unacceptable risks. Emissions have to stop much earlier. The consequences of being wrong about how high atmospheric CO2 levels can be before irreversible effects set in are Catastrophic. EU climate policy should follow the precise principle (cf.
Filed in Swedish · English published by the European Commission
Sandbag welcomes the opportunity to provide feedback on the update of the EU ETS under the FF55 package. Our analyses show that the proposed changes are not enough to guarantee that emissions will stay below the cap and that they could exceed it by 45% in 2030.
Option 1 (“full legal scope for the EU ETS”) is the best of the proposed option. CORSIA does not reduce CO2 emissions at all but only future climate compensation. The damage is already distorted, the concentration of CO2 in the atmosphere has increased with all the disastrous consequences it will entail. Climate compensation does not prevent these consequences.
Filed in Swedish · English published by the European Commission
Sandbag welcomes the opportunity to give feedback on the Inception Impact Assessment on updating the EU ETS rules for aviation. In the context of the European Green Deal and the enhanced ambition for 2030, changes to the EU ETS for aviation should not result in a step backwards in terms of tackling CO2 emissions, but a step forward.
We are concerned about this proposal, as it sends the wrong signal as to the Union’s determination in the transition to a zero-emission economy. Allowing investment in new fossil energy infrastructure would lead to an inherent conflict of objectives in REPowerEU. The initiative aims to reduce dependence on fossil energy and diversify energy supply.
Filed in Swedish · English published by the European Commission
We welcome immediate action to reduce Europe’s dependency on Russian fossil fuels in the face of its aggression against Ukraine. However, the European Commission’s proposal reflects the impossibility of meeting this objective while keeping conflicting incentives in force.
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