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 · RUS
Industry association · Belgium
Declared costs: €1.3M+ a year · in the register since 2009
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.
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.
SMEunited · filed 27 Aug 2020 · source
Putting some order in the world of green claims is definitely useful and important. However, there is a big risk that the use of certain methodologies, such as PEF / OEF, could make life much more difficult for craft and SMEs in terms of higher costs and administrative work.
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.
SMEunited · filed 24 May 2023 · source
SMEunited supports addressing a feasible substantiation of green claims and creating a harmonised legal framework. SMEunited calls for simple, workable and proportionate substantiation criteria in the Directive on Green Claims. The Directive must not result in the use of green claims being reserved for financially strong market players. Therefore, SMEunited calls for changing the Directive in several ways.
SMEunited · filed 15 Sept 2021 · source
The European Commission is considering how to improve communication on chemicals. The focus is currently on detergents and fertilizers. In this context, the labelling requirements for these categories of chemical products could be streamlined and digital labelling could be used.
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.
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