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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.

PP
PJSC Phosagro

Company · RUS

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

Industry association · Belgium

73
files engaged
of 583 tracked
111
positions filed
in those 583 files
46.7
declared FTE
self-declared
11
EP accreditations
as declared to the register

Declared costs: €10M+ a year · in the register since 2009

Files both filed on (2)

Substantiation and communication of explicit environmental claims (Green Claims Directive) · 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.

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.

Substantiation and communication of explicit environmental claims (Green Claims Directive)

Cefic · filed 31 Aug 2020 · source

Cefic welcomes the opportunity to provide feedback on the initiative undertaken by the European Commission about a new regulatory initiative on substantiating green claims regarding Environmental performance of products & businesses in line with Better regulation principles and criteria (effectiveness, efficiency, relevance, coherence, EU-added value) The European chemical industry represented by Cefic, is highly…

PJSC Phosagro · filed 24 May 2023 · source

PhosAgro is the leading producer of environmentally safe phosphate fertilisers. We welcome the occasion to submit our feedback on the initiative aimed at introducing minimum requirements for substantiating and communicating of explicit environmental claims. We appreciate every effort to supply consumers with reliable, verified and exact information.

Cefic · filed 13 Jul 2023 · source

Cefic welcomes the European Commission proposal on the Green Claims Directive and supports the overall objectives of this ambitious initiative. We want to collaborate with the European Commission and the entire value chain to make the Green Claims Directive effective in product differentiation and providing accurate information to consumers while ensuring a level playing field for all players across the industry…

Digital labelling of EU fertilising products

Cefic · filed 20 Sept 2021 · source

Cefic, the European Chemical Industry Council (www.cefic.org) welcomes the possibility to comment on the EU Commission Inception Impact Assessment on “Simplification and digitalization of labels on chemicals (CLP, Detergents, Fertilising Products)”. This feedback focuses on the CLP regulation.

PJSC Phosagro · filed 23 May 2023 · source

PhosAgro is the leading producer of environmentally safe phosphate fertilisers. We welcome the occasion to provide feedback on a proposal for a regulation on the digital labelling of fertilising products. We support the initiative to modify the EU Fertilising Products Regulation (EU) 2019/1009 so as to introduce new labelling requirements to create a voluntary digital label in annex III.

Cefic · filed 26 May 2023 · source

Fertilisers Efficiency Enhancers (FEE), a sector group of the European Chemical Industry Council (Cefic), welcomes the opportunity to provide input to the proposal for a Regulation regarding the digital labelling of EU fertilising products.

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