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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.

SG
sonnen GmbH

Company · Germany

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)

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.

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.

Batteries and waste batteries

Enel · filed 7 Jul 2020 · source

Dear Members of DG ENV.Unit B3 – Waste Management & Secondary Materials Enel SpA, a multinational company in the energy sector highly appreciates the EC initiative to ensure a competitive, circular, sustainable, and safe value chain for all batteries placed on the Union 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.

Revision of the Network Code on Requirements for Grid Connection of Generators

Enel · filed 7 Aug 2026 · source

Dear Members of the European Commission, Enel Group, an international power company, highly appreciates the possibility to provide feedback on Network code on requirements for grid connection of generators revision. For further details on our position, please refer to the document attached to this feedback. Best Regards.

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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