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.
We appreciate the chance to provide comments on the new standard data protection clauses for the transfer of personal data to third countries pursuant to Article 46 GDPR. We acknowledge the great value of the updated framework, which will help companies when relying on third country transfers and hope our detailed comments may contribute to the further enhancement of the SDPC.
BEUC thanks the Commission for the opportunity to comment on the draft standard contractual clauses for transferring personal data to non-EU countries. In attachment our response. We remain available for answering any questions the Commission may have. BEUC's Digital Team
Please, find the detailed joint-feedback as attachment. Following the key messages: 1. It is strongly recommended to extend the understanding of enforcement by integrating complementing tools, such as Codes of Conduct, into the evaluation by the European Commission. Codes of Conduct strongly support harmonization across Europe, by allowing for particularizing ambiguous interpretations in sector-specific manners.
Thank you very much for the opportunity to provide feedback. BEUC welcomes the Commissions intention to propose a regulation that harmonises procedural rules on cross-border cases under the General Data Protection Regulation (GDPR). Please find BEUC's recommendations in attachment. We remain at your disposal for any question or comment you may have.
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