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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.

SMS
SOS Mal de Seine

NGO · France

3
files engaged
of 583 tracked
3
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register

Files both filed on (2)

Sustainable aviation fuels (ReFuelEU Aviation Initiative) · Sustainable maritime fuels (FuelEU Maritime Initiative)

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.

Sustainable aviation fuels (ReFuelEU Aviation Initiative)

Deutsche Umwelthilfe e.V. · filed 21 Apr 2020 · source

Environmental Action Germany (Deutsche Umwelthilfe e.V.) welcomes the opportunity to comment on the ReFuelEU initiative. Greenhouse gas emissions from aviation must be reduced urgently. The ReFuelEU inception impact assessment, however, neglects important aspects of sustainability and availability of alternative fuels for aviation.

SOS Mal de Seine · filed 22 Jul 2021 · source

Today, on the dawn of our proven knowledge of global warming, global aviation sounds hatred on people. A small part of the population spends their time on travelling in the air to distract, discover, consume, work for globalisation, while another look at the sky, climb water, etc.

Filed in French · English published by the European Commission

Sustainable maritime fuels (FuelEU Maritime Initiative)

Deutsche Umwelthilfe e.V. · filed 23 Apr 2020 · source

Environmental Action Germany welcomes the opportunity to comment on this EC initiative. We wish to make the following comments: 1. Crop biofuels are more damaging to the climate than fossil fuels. Crop biofuels must be phased out entirely and must not be incentivised for use in shipping. 2. Advanced biofuels based on wastes and residues are not automatically sustainable.

SOS Mal de Seine · filed 22 Jul 2021 · source

Maritime transport across Europe does not bring people together; it divides them in this race for globalised globalisation. It suspends a huge sword of Damoclès over European waters by the huge risk of shipwreck, collision or fire of thousands of ships sailing every day, every second.

Filed in French · English published by the European Commission

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