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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.

SOM
SOMO

NGO · Netherlands

2
files engaged
of 583 tracked
2
positions filed
in those 583 files
0.8
declared FTE
self-declared
0
EP accreditations
as declared to the register

Declared costs: not declared · in the register since 2023

Files both filed on (2)

Revision of the Union Customs Code · Transparency and integrity of Environmental, Social and Governance (ESG) rating activities

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.

Revision of the Union Customs Code

DHL Group · filed 26 Oct 2023 · source

DHL Group welcomes the opportunity to comment on the Commission proposals to reform the EU Customs Union. The input from companies in the logistics sector such as DHL Group is critical. As we continue to cooperate on the IT developments under the current Union Customs Code (UCC) implementation, which is still ongoing, we need to contribute at the earliest possible stage to this proposed fundamental and wide-ranging…

SOMO · filed 7 Nov 2023 · source

SOMO appreciates the opportunity for providing feedback on the Commissions proposal for a new Union Customs Code. EU supply chains need to become much more transparent to effectively address the abuses they are fraught with. EU customs law reforms can substantially contribute to supply chain transparency.

Transparency and integrity of Environmental, Social and Governance (ESG) rating activities

SOMO · filed 6 Jun 2022 · source

As an expert research institution with more than 30 years of experience investigating the impacts of multinational companies, The Centre for Research on Multinational Corporations (SOMO) considers that there is, within the European Commission’s proposals, a fundamental misunderstanding about how ESG rating can contribute the objectives of the European Green Deal.

DHL Group · filed 25 Aug 2023 · source

The growth of the ESG market, fueled by investor demand for ESG data and efficiency, has created a diverse landscape of methodologies among ESG rating providers. In this context, as DHL Group, we value the Commission's proposal to enhance transparency and requirements for ESG ratings. However, while we welcome this step, certain concerns persist due to the absence of streamlined methodologies in the proposal.

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