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
Company · Spain
Declared costs: €700K+ a year · in the register since 2012
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.
Iberdrola S.A. · filed 8 Jul 2020 · source
Iberdrola is glad to provide feedback to this consultation sharing with the Commission and views on the critical importance of setting a forward looking framework on sustainable batteries based on their exponential growth as a driver for climate neutrality (notably in electrification of transport as shown is chart attached).
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.
Iberdrola S.A. · filed 24 Aug 2026 · source
Iberdrola welcomes the Commission's initiative to revise the Network Code on Requirements for Generators, recognising the challenge of adapting connection requirements to a system shaped by renewable generation, storage, electric vehicles and new stability needs.
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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