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
T&E welcomes the Commission’s initiative to align the ETS directive with the EU’s 2030 target of at least -55% emissions reduction and to ensure that all sectors contribute, in line with the EU’s international commitment to economy-wide action under the Paris Agreement. However, T&E regrets that the Commission is considering to switch gear on tackling emissions in the road sector.
This response is about the inclusion of 1)shipping and 2)road transport into the ETS: 1.SHIPPING Shipping accounts for around 3.5% of the EU’s total GHG emissions, but has so far avoided regulation on its climate impact. Integrating shipping into the ETS is a positive step in the right direction and will put shipping on the path towards climate neutrality in line with the Paris Agreement.
While every other sector’s climate emissions have decreased since 1990, on average, aviation emissions have more than doubled. If the European Green Deal is to radically reduce the EU’s climate impact, it has to reshape European aviation by using all necessary carbon pricing tools at its disposal, including revising the Emission Trading System (ETS).
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
The Commission is proposing to reform the EU ETS rules for aviation to try and address some unfair privileges the sector was benefiting from and start applying a more effective price on aviation emissions. But it unfortunately continues to implement Corsia, ICAO’s carbon offsetting scheme despite its confirmed lack of economic and environmental integrity.
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