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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.

MC
Ministerio de Consumo

Public authority · Spain

2
files engaged
of 583 tracked
2
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
ZAW
ZAW

Industry association · Germany

8
files engaged
of 583 tracked
8
positions filed
in those 583 files
0.5
declared FTE
self-declared
0
EP accreditations
as declared to the register

Declared costs: €50K+ a year · in the register since 2009

Files both filed on (2)

Empowering consumers for the green transition · Consumer credits

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.

Empowering consumers for the green transition

Ministerio de Consumo · filed 31 Aug 2020 · source

A. Problems: 1 Consumers often lack reliable and relevant information at the point of sale on: • sustainability of products, e.g. environmental characteristics, expected or expected useful life, etc.; • the availability of repair services, spare parts and repair manuals; And • software updates/updates.

Filed in Spanish · English published by the European Commission

ZAW · filed 6 May 2022 · source

The advertising industry supports the overall objective of the European Commission, which the present draft also pursues, to empower consumers for the green transition through better protection against unfair practices and better information. It is in the interest of both consumers and businesses to prevent misleading claims and to encourage the exchange of credible information.

Filed in German · English published by the European Commission

Consumer credits

Ministerio de Consumo · filed 31 Aug 2020 · source

A. Problems: 1 Inadequate scope (emergence of new non-bank traders such as loan platforms and new forms of consumer credit such as microloans, which are less than EUR 200 not covered by the Directive). 2 Content and form of information: The requirements for providing information in advertising and at the pre-contractual stage do not reflect the increasing use of digital devices (tablets, smartphones) in credit…

Filed in Spanish · English published by the European Commission

ZAW · filed 1 Sept 2021 · source

The ZAW welcomes the opportunity to comment on the European Commission's proposal for a Consumer Credit Directive, which will have a significant impact on the advertising industry, in particular due to the mandatory standard information for advertising. You will find our statement in the annex.

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