Side by side
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.
Company · Germany
NGO · Belgium
Declared costs: not declared · in the register since 2010
Batteries and waste batteries · Revision of the Network Code on Requirements for Grid Connection of Generators
Register facts self-declared (snapshot 2 Sept 2026); cost bands are floors. Shared files are shared attention, not evidence of coordination.
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.
ECOS · filed 9 Jul 2020 · source
Batteries are an essential product to ensure decarbonisation in the EU and its demand is set to grow substantially in the upcoming years. As an environmental civil society organisation, we strongly welcome the initiative of the European Commission to update the legislation that ensures a circular and sustainable value chain for all batteries produced in the EU and placed on the single market.
sonnen GmbH · filed 1 Mar 2021 · source
We welcome the European Union’s efforts to increase the overall sustainability of batteries. We support the level of ambition of the regulation as well as its layout, to regulate every single step in the life cycle of a battery. We understand that, in order to be as effective as possible, the regulation aims to be extensive in scope, covering a wide range of battery applications.
ECOS · filed 1 Mar 2021 · source
ECOS welcomes the European Commission’s proposal for a new Regulation on batteries and waste batteries (replacing the current Battery Directive) and is pleased to contribute to the consultation on this matter. Together with other European NGOs, namely the EEB (The European Environmental Bureau), Deutsche Umwelthilfe (DUH – Environmental Action Germany), and Transport & Environment, we have developed a joint paper…
ECOS · filed 24 Aug 2026 · source
ECOS welcomes the proposed revision of the Network Code on Requirements for Generators (RfG). It will improve the large-scale integration of electric vehicles (EV) and EV chargers capable of reverse power transfer (a.k.a. vehicle-to-grid, or V2G), as well as other low-power, mass-market products such as storage.
sonnen GmbH · filed 25 Aug 2026 · source
Network code on requirements for grid connection of generators – revision 1 Art. 6(11): Nachweis in beide Wirkleistungsrichtungen (ESM / V2G) Bezug: Art. 6(11) in Verbindung mit Art. 49, Art. 15, Art. 17, Art. 18 und Art. 22. 1. Problem Art. 6(11) verlangt, dass Speichersysteme (ESM) sowie V2G-Fahrzeuge und V2G-Ladestationen die Anforderungen sowohl beim Einspeisen als auch beim Laden erfüllen.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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