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.
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.
Puertos del Estado shares the urgent need for the reduction of emissions from the maritime transport, and fully support the implementation of market based measured like the extension of the EU ETS to the maritime sector. That said, we would like to express our concern about the impact of this measure on maritime transit traffic (“transhipment”). On that sense, the following aspects need to be considered.
The following comments stick to the content of the inception document and are only intended to be helpful for the further development of the initiative. They do not compromise any final position on a future legislative proposal. Overall, the initiative is timely and the inception document well focused.
•The European Oleochemicals & Allied Products Group (APAG) welcomes the Commission’s proposal for the FuelEU Maritime Regulation. As we fully support the European Union’s intention to reduce emissions from shipping and would support a more ambitious approach on biofuels, modeled after the Renewable Energy Directive, including: 1.
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