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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.

2
files engaged
of 583 tracked
2
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register

Files both filed on (2)

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.

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.

Ecodesign requirements for solid fuel local space heaters (review)

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

Deutsche Umwelthilfe e.V. · filed 14 Dec 2023 · source

On behalf of Deutsche Umwelthilfe (DUH, Environmental Action Germany), we welcome the revision of the Ecodesign Regulation for solid-fuel local space heaters/SFLSH (EU 2015/1185). Over a fifth of total PM2.5 in Germany comes from small combustion appliances however, as reporting does not include condensables (condensed particles), actual emissions from this sector are much higher.

Review of energy labelling requirements for solid fuel boilers

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

Deutsche Umwelthilfe e.V. · filed 21 Dec 2023 · source

On behalf of Deutsche Umwelthilfe (DUH, Environmental Action Germany), we welcome the revision of the Ecodesign Regulation for solid fuel boilers/SFB (EU 2015/1189). Over a fifth of total PM2.5 in Germany comes from small combustion appliances however, as reporting does not include condensables (condensed particles), actual emissions from this sector are much higher.

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