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.
Consumer organization · France
Public authority · Germany
Declared costs: not declared · in the register since 2015
Regulation on machinery products · Limit values for lead and its inorganic compounds and diisocyanates
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.
OPPBTP · filed 10 Feb 2019 · source
1 For easier ownership by all stakeholders, some concepts could be more explicit in terms of their scope, and promote a better understanding of the definitions (defined application, specific application, machine modification, risk analysis; Intended use).
Filed in French · English published by the European Commission
Deutsche Gesetzliche Unfallversicherung · filed 11 Feb 2019 · source
The IFA proposes the choice of options 2 and 4. However, as the application of the existing Directive has proved its worth in the vast majority of cases, the scope of amendments should be deliberately kept to a minimum in order to allow all users of the Directive the simplest possible transition in the application of a new Regulation.
Deutsche Gesetzliche Unfallversicherung · filed 12 Jul 2021 · source
The German Social Accident Insurance (DGUV) sees a renunciation of well provisional principles in the proposal of a new Regulation on machinery products, for examination in Article 5 ‘High-risk machinery products’, which is absolutely insufficient to deliver ‘high-risk machinery’ to ‘NOT- high-risk machinery’. All further comments therefore on different aspects, please see the attached comment table.
Filed in German · English published by the European Commission
OPPBTP · filed 21 Mar 2022 · source
As regards diisocyanates, in the BTP sector, it is mainly met with the 4,4-diphenylmethane diisocyanate (MDI), which is a component of polyurethane foams (PU) used in the projection insulation works. There are no binding OELs for diisocyanates in France. The MDI has a non-regulatory indicative OEL set by circular at 0,01 ppm or 0.1 mg/m³.
Filed in French · English published by the European Commission
Deutsche Gesetzliche Unfallversicherung · filed 21 Mar 2022 · source
The DGUV [German Statutory Accident Insurance] is the umbrella association for professional associations in this branch and governmental accident insurers. It looks after the joint interests of its members and promotes the work they do for the benefit of insured persons and enterprises.
Filed in German · English published by the European Commission
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