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.
Company · Germany
Consumer organization · Belgium
Declared costs: not declared · in the register since 2008
Simplifying and reducing the burden of the rules on medical devices and in vitro diagnostic medical devices, and support of the European Medicines Agency for the expert panels on medical devices and the list of Union harmonisation legislation · Digital labelling of EU fertilising products
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.
orochemie GmbH + Co. KG · filed 1 Oct 2025 · source
One of the problems with the MDR is the extremely high cost of certification and the assessment of technical documentation. The costs have at least doubled since the switch from the MDD to the MDR. The significant increase in external costs is due to increased internal costs due to the increased documentation burden.
Filed in German · English published by the European Commission
BEUC - The European Consumer Organisation · filed 28 Jul 2026 · source
BEUC welcomes the opportunity to comment on the revision of the EU framework for medical devices and IVDs. This revision provides an opportunity to strengthen shortage prevention, coordination, and transparency in a sector that directly affects consumers health and daily lives. However, several elements of the European Commissions proposal risk weakening hardwon patient safety gains and should be reconsidered.
orochemie GmbH + Co. KG · filed 20 Sept 2021 · source
A clear simplification of the labelling rules would be the legalisation of multilingual folding or tag labels in times of globalisation. Multilingual folding/tow tags in all EU languages would: — simplify supply chains; — support sustainability (saving of air-conditioned storage areas, etc.) — shorten transport routes (the same product can also be sent to and used in a neighbouring country) — Promote the free…
Filed in German · English published by the European Commission
BEUC - The European Consumer Organisation · filed 20 Sept 2021 · source
BEUC welcomes the Commission’s intention to improve the means of communicating essential information on chemical products to consumers. As observed in the Inception Impact Assessment (IIA), product labels are too often overloaded with information, making them difficult to read and understand for consumers.
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