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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.

PGM
Polish Glass Manufacturers Federation

Industry association · Poland

3
files engaged
of 583 tracked
3
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 (3)

Revision of the benchmark values for free allocation of emission allowances (2026-2030) · Monitoring, reporting and verification of greenhouse gas emissions from maritime transport · Revision of the Energy Tax Directive

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.

Revision of the benchmark values for free allocation of emission allowances (2026-2030)

Polish Glass Manufacturers Federation · filed 8 Jun 2026 · source

Polish Glass Manufacturers Federation is seriously concerned by the proposed revision of the fuel fallback benchmark and some other benchmarks for 2026 - 2030. The proposed update would lead to a very sharp reduction in the fallback benchmarks, with a drop of around 34% between 2025 and 2026. For companies relying on the heat and fuel benchmarks, this could mean that carbon costs broadly double in only one year.

Cefic · filed 8 Jun 2026 · source

The proposed benchmarks reduction particularly the 50% cut to fallback heat and fuel benchmarks is unrealistic, disproportionate, and disconnected from current technological, infrastructure, and investment realities. These changes would significantly increase carbon costs for an already struggling chemical sector, worsen carbon leakage risks, and reduce the capacity of companies to invest in the climate transition.

Monitoring, reporting and verification of greenhouse gas emissions from maritime transport

Cefic · filed 26 Nov 2020 · source

The ETS should remain a core policy instrument to establish CO2 abatement at the lowest practicable cost to society. We do not favor inclusion of other sectors such as transport and buildings as an extension of the ETS current scheme, which already has to cope with different sectors with distinct elasticities, and risks on carbon leakage in one system.

Polish Glass Manufacturers Federation · filed 8 Nov 2021 · source

Polish Glass welcomes the opportunity to provide feedback on the Commission proposal to review the EU -ETS. Modification of Carbon Leakage measures In order to achieve ambitious reductions, industry will have to invest massively in low-carbon technology. Unfortunately, the high carbon prices, and the lack of a level playing field with non-EU countries, makes this really challenging.

Revision of the Energy Tax Directive

Cefic · filed 1 Apr 2020 · source

Revision of Directive 2003/96/EC restructuring the Community framework for the taxation of energy products and electricity (Energy Taxation Directive or ‘ETD’ or ‘Directive’) Cefic comments 1. Managing the different global speeds.

Polish Glass Manufacturers Federation · filed 18 Nov 2021 · source

Zwiazek Pracodawcow Polskie Szklo, the Polish Glass Manufacturers Federation, welcomes the opportunity to provide feedback on the Commission proposal regarding Energy Taxation Directive (ETD). To reach carbon neutrality, glass manufacturing companies are investing massively in new technologies and R&D. This investment effort will take place in a context of high CO2 prices and energy prices.

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