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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.

PVT
PVThin

Trade union · Belgium

2
files engaged
of 583 tracked
2
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
EEB
European Environmental Bureau

Environmental organization · Belgium

52
files engaged
of 583 tracked
60
positions filed
in those 583 files
51.8
declared FTE
self-declared
31
EP accreditations
as declared to the register

Declared costs: not declared · in the register since 2009

Files both filed on (2)

Substantiation and communication of explicit environmental claims (Green Claims Directive) · Restriction of hazardous substances - evaluation

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)

PVThin · filed 28 Aug 2020 · source

Pvthin – the international trade body promoting thin-film photovoltaic (PV) technologies - welcomes the European Commission’s initiative on ‘green claims’ and the overarching objective to harmonise these claims in the EU. The thin-film PV industry would support this approach as a continuation of the work on EU Product Environmental Footprint Category Rules (PEFCR) for PV (2013-2018 Pilot).

European Environmental Bureau · filed 31 Aug 2020 · source

The EEB welcomes the inception impact assessment for the initiative “Legislative proposal on substantiating green claims”. The EEB actively participates in the Product Environmental Footprint (PEF), its Technical Advisory Board (TAB), as well as the pilot and transition phase projects. The EEB supports the need for standard methodologies to assess the impact on the environment of products on the European market.

European Environmental Bureau · filed 17 Jul 2023 · source

The EEB welcomes the long-awaited proposal for a Green Claims Directive. Please see our attachd position paper and the summary below: 1) Why this legislation is important - The proliferation of misleading and unsubstantiated claims as well as greenwashing are hampering the green transition.

Restriction of hazardous substances - evaluation

PVThin · filed 8 Oct 2018 · source

Please find attached the input provided by PVThin, the international industry coalition whose objective and purpose is to strengthen global energy security, help create sustainable energy infrastructures, as well as promote the social, economic and environmental benefits of thin-film solar photovoltaic technologies.

European Environmental Bureau · filed 12 Oct 2018 · source

It is of utmost importance to phase out the use of hazardous substance in products. This is the overarching principle. In the same time a coherence with the Circular Economy STrategy must be achieved. The EEBs report looks into this subject in detail…

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