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.
NGO · Germany
Industry association · Belgium
Declared costs: €300K+ a year · in the register since 2010
Ecodesign requirements for solid fuel local space heaters (review) · Review of energy labelling requirements for solid fuel boilers
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.
Parents for Future Germany · filed 7 Dec 2023 · source
Solid fuel local space heaters have contributed to reducing energy costs in the 2022 crisis and reduced the need for energy imports. However, these furnaces are not suitable for reducing greenhouse gas emissions. As indigenous energy wood is persistently insufficient, it is very likely that healthy trees will be imported from poorly controlled supplier countries.
Filed in German · English published by the European Commission
Bioenergy Europe · filed 12 Dec 2023 · source
Bioenergy Europe would like to submit the following inputs concerning the revision of Ecodesign requirements for Solid-fuel Local Space Heaters (LSHs) First of all, a new calculation for seasonal efficiency is needed. When measuring efficiency, renewability must be taken into consideration to ensure a fair evaluation and comparability for all appliances in the market.
Parents for Future Germany · filed 14 Dec 2023 · source
The idea is tempting that with the fuel wood we make ourselves independent of the countries supplying fossil fuels. Solid fuel boilers can make little contribution to achieving climate neutrality in the EU. Wood is not in itself carbon neutral. Even with a 1 to 1 replanting, it takes decades for the CO2 generated by the combustion to be sequestered again. Wood is not a freely available raw material.
Filed in German · English published by the European Commission
Bioenergy Europe · filed 20 Dec 2023 · source
Bioenergy Europe would like to submit the following inputs concerning the revision of Ecodesign requirements for Solid-fuel Boilers. Solid fuel boilers are proven technologies that have shown significant improvements in energy efficiency through the years, using less feedstock in a better way and therefore reducing emissions.
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