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.
While the IIA raises several issues within a possible ETS extension, the Regulatory Assistance Project (RAP) focuses here on just four, all related to the buildings sector. 1. Simply extending the ETS to the buildings sector is not an effective answer.
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.
The Regulatory Assistance Project would like to submit one recent study on rebalancing energy prices. It contains examples of how to lower energy prices for residential heating and may be useful for the Commission in promoting such strategies in line with the objective from the Action Plan for Affordable Energy to lower taxation of electricity and remove non-energy cost components from electricity bills.
CONSULTATION RESPONSE October 2025 Cefic Consultation Response – Electrification Action Plan Persistent high energy costs have reached an unsustainable level for the chemical industry. As the largest industrial consumer of electricity (149 TWh, 2023), the high costs compared to other regions present an existential challenge. A rising number of chemical site closures attests to that.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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