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.
Lithium-ion batteries will be the backbone of the economy’s decarbonisation, notably the EU transport. Unlike combustion engines that burn oil and release harmful emissions, batteries can be reused and recycled at the end of their lives. Batteries are the best technology we have today to make our road transport emissions-free.
The Natural Resource Governance Institute works in mineral-rich countries globally to promote accountability. We welcome the Battery Regulation proposal including its requirement for economic operators to establish due diligence policies in line with international standards for rechargeable industrial and electric vehicles batteries.
This submission is made on behalf of four European NGOs: ECOS, EEB (The European Environmental Bureau), Deutsche Umwelthilfe (DUH – Environmental Action Germany, and Transport & Environment, all with an interest in the development of an environmentally sustainable battery value chain in Europe.
T&E strongly believes that the development and adoption of sector-specific standards is crucial to help companies in their materiality assessment, reducing costs and making the reporting processes easier, while ensuring investors have access to meaningful information and auditors exercise is simplified.
NRGI envisions a world where natural resources enable fair, prosperous and sustainable societies, instead of undermining them. Given that Environmental, Social and Governance reporting is essential to this goal we have closely followed the development of the European sustainability reporting standards.
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