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.
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.
ACEA POLICY PAPER ON GREENING CORPORATE FLEETS FOR LIGHT DUTY VEHICLES BRUSSELS, 5 SEPTEMBER 2025 www.acea.auto 1 CON EXECUTIVE SUMMARY The corporate fleet market for passenger cars and vans is highly complex. An artificial acceleration of market demand completely ignores the still absent regulatory frameworks necessary to achieve such high electrification rates in the EU.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The EKO-AUTO association representing the ELV industry draws attention to several aspects concerning the forced electrification of the corporate fleet of companies or institutions. Assuming that 60-70 % of CO2 emissions come from the transport sector and assuming that the majority of the fleet is made up of vehicles owned by economic operators and institutions, we can agree with the direction of reducing emissions…
Filed in Polish · English published by the European Commission
The ELV Directive, which came into force 20 years ago largely delivered on its initial objectives due to the significant efforts made by the automotive and the recycling industry. The European Automobile Manufacturers’ Association (ACEA) fully supports the European Commission’s initiative to ensure a better consistency with the objectives of the European Green Deal, including the Circular Economy Action Plan and the…
The Polish EKO-AUTO Vehicle Deconstruction Station Association was the only organisation in Poland to consult extensively on the draft Regulation. Between 3 and 20 October 2023, meetings were held throughout the country with the owners and staff of the dismantling centre (ELV). It should be stressed that the provisions of the draft Regulation are crucial for the continued operation of dismantling centres in Europe.
Filed in Polish · English published by the European Commission
The European Automobile Manufacturers' Association (ACEA) is firmly committed to advancing the EU towards a modern, resource-efficient, and competitive economy. We welcome the European Commission's Proposal for a Regulation on circularity requirements for vehicle design and on management of end-of-life vehicles (ELVs), which envisages a transformation towards enhanced sustainability, circularity, and innovation.
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