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.
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
The Austrian Chamber of Commerce welcomes the initiative to simplify EU rules on medical devices and in vitro diagnostic medical devices. The implementation of the MDR and IVDR has led to high requirements for all economic operators. There has been a huge increase in both the bureaucratic and financial burden on entrepreneurs. In general, the requirements are very complex and require a high level of expertise.
Filed in German · English published by the European Commission
— Simplification of the label is absolutely necessary, as information on chemical labels is currently overcrowded. Information on the label shall be limited to the most essential information (e.g. CLP marking). Other information (e.g. additional label elements due to specific rules) should be made available digitally.
Filed in German · English published by the European Commission
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
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