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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.

SEM
SEMI

Industry association · 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

Files both filed on (2)

Regulation on machinery products · 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.

Regulation on machinery products

SEMI · filed 8 Feb 2019 · source

SEMI, the association representing the global electronics manufacturing industry, welcomes the opportunity to comment on the revision of the Machinery Directive. AI technologies are already used in semiconductor manufacturing: Using artificial intelligence (AI) tools, today’s semiconductor fabs combine equipment know-how and manufacturing statistics to manage massive fault detection data, increase manufacturing…

Japan Business Council in Europe · filed 11 Feb 2019 · source

We welcome the continuous work and intention of EU Commission to improve the Machinery Directive. JBCE would like to thank the European Commission for the opportunity to provide input to the consultation on the inception Impact Assessment in relation to the revision of the Machinery Directive.

Japan Business Council in Europe · filed 6 Aug 2021 · source

Proposal for a Regulation on Machinery Products JBCE's position Japan Business Council in Europe (JBCE) welcomes the proposal for the Regulation on Machinery Products, new legislative framework (NLF) and to reduce the costs of transposition with the choice of a Regulation.

Restriction of hazardous substances - evaluation

SEMI · filed 11 Oct 2018 · source

SEMI, representing the electronics manufacturing industry, welcomes the opportunity to give feedback on the roadmap. We see the following areas of improvement: i) RoHS and REACH inconsistencies; ii) global aspect of RoHS; iii) retention of Large-Scale Stationary Industrial Tools (LSSIT) and Large-Scale Fixed Installations (LSFI) exclusions, and importation of used equipment; and iv) the issues surrounding…

Japan Business Council in Europe · filed 11 Oct 2018 · source

JBCE would like to thank the European Commission for the opportunity to provide input to the consultation on the roadmap for the review of the RoHS Directive. We support that this evaluation will assess effectiveness, efficiency, relevance and coherence, however, there are a few areas which we would like the evaluation to incorporate: • Providing sufficient consultation period A sufficient consultation period should…

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