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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
77
files engaged
of 583 tracked
87
positions filed
in those 583 files
15
declared FTE
self-declared
0
EP accreditations
as declared to the register

Declared costs: €2.8M+ a year · in the register since 2010

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)

Wirtschaftskammer Österreich · filed 28 Aug 2020 · source

• In general: EU framework for methodology on PEF and OEF on voluntary basis in a harmonised matter may be useful – mandatory system not first choice, different P(O)EFCRs in Member States to be avoided – therefore WKO proposing to consider option 1 (update of PEFs and OEFs) or 2 (voluntary legal framework), currently not option 3 (legal framework establishing obligation for claims by PEF/OEF) because of costs and…

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.

Wirtschaftskammer Österreich · filed 5 Jul 2023 · source

WKO Position Paper Short Summary - Proposal for a Green Claims Directive: less restrictions for the benefit of consumer orientation more exemptions and support for SMEs, implementation leeway needed substantiation to be simplified radically verification and authority-OK to be deleted national, regional and private labels to be exempted from verification in any case.

Digital labelling of EU fertilising products

Wirtschaftskammer Österreich · filed 3 Sept 2021 · source

— 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

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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