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.
Public authority · Spain
Industry association · Belgium
Declared costs: €1.3M+ a year · in the register since 2009
Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals · Guidance on the application of the ‘do no significant harm’ principle under the 2028-2034 MFF
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 20 May 2021 · source
The EU needs a general simplification of its chemicals legislation and a chemicals policy, which is more inclusive for SMEs. The Commission should give high priority to this aspect during the evaluation of the REACH Regulation. In more detail SMEunited suggests: It should be explored, how to further exploit the obligatory data/cost sharing to reduce burden.
Ministry for Ecological Transition and Demographic Challenge · filed 1 Jun 2021 · source
The Spanish Ministry for Ecological Transition and Demographic Challenge welcomes the Commission´s initiative to revise the two main chemical´s regulation in Europe. The European Union has to be a global example of sound chemicals management. The sale of chemicals is estimated to double by 2030, making the proper management of chemicals key to achieving the Sustainable Development Goals.
SMEunited · filed 16 Mar 2026 · source
Proving of DNSH is especially for SMEs and other small entities extremely burdensome as the cost benefit analysis commissioned by DG GROW on taxonomy for SMEs has proved. Therefore, the 2nd Platform on Sustainable Finance rightly recommended in its streamline approach of sustainable finance for SMEs that SMEs which work in Europe and fulfil all legal requirements are not doing significant harm as long as they are…
Ministry for Ecological Transition and Demographic Challenge · filed 31 Mar 2026 · source
Spains contribution is attached. The document reflects the extensive experience gained through the implementation of the RRF and highlights the essential role of the DNSH principle in ensuring the environmental integrity of EU funded investments.
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