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.
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.
T&E welcomes the Commission’s initiative to align the ETS directive with the EU’s 2030 target of at least -55% emissions reduction and to ensure that all sectors contribute, in line with the EU’s international commitment to economy-wide action under the Paris Agreement. However, T&E regrets that the Commission is considering to switch gear on tackling emissions in the road sector.
In our opinion, it is recommended to phase out the free allowances for the aviation earlier than assumed in the draft amendments to the Directive 2003/87/EC It is in perfect to maintain the current level of free allowances in aviation (worth about EUR 800 million in 2019) and the proposal to phase them out by 25 % in 2024, 50 % in 2025, 75 % in 2026 and 100 % in 2027.
Filed in Polish · English published by the European Commission
This response is about the inclusion of 1)shipping and 2)road transport into the ETS: 1.SHIPPING Shipping accounts for around 3.5% of the EU’s total GHG emissions, but has so far avoided regulation on its climate impact. Integrating shipping into the ETS is a positive step in the right direction and will put shipping on the path towards climate neutrality in line with the Paris Agreement.
While every other sector’s climate emissions have decreased since 1990, on average, transport emissions have increased by almost 30% since 1990 (aviation emissions, for one, have more than doubled). Each mode of transport faces varying challenges to reverse this trend and reduce them in the coming decade.
We reject the proposal to levy a tax on kerosene. We believe that it would not only undermine the competitiveness of European carriers on the global market, but more importantly, it would slow down the development of the aviation sector in the EU and limit sector's ability to invest in new technologies such as alternative sustainable fuels.
While every other sector’s climate emissions have decreased since 1990, on average, aviation emissions have more than doubled. If the European Green Deal is to radically reduce the EU’s climate impact, it has to reshape European aviation by using all necessary carbon pricing tools at its disposal, including revising the Emission Trading System (ETS).
On the topic of the implementation of the CORSIA regulations, we grant a full approval for the obligation to adapt the current European regulations and the provisions of individual Member States. An important element in the adaptation of the CORSIA system is the proper division of flights between two separately operating systems with the aim of reducing CO2 emissions in aviation.
The Commission is proposing to reform the EU ETS rules for aviation to try and address some unfair privileges the sector was benefiting from and start applying a more effective price on aviation emissions. But it unfortunately continues to implement Corsia, ICAO’s carbon offsetting scheme despite its confirmed lack of economic and environmental integrity.
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