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 Automobile Recycling Forum association highlights one of the negative effects of accelerating fleet replacement with zero-emission vehicles. Electric vehicles are qualified as zero-emission vehicles, despite being powered by the dominant coal-based energy in Poland, which is why they are not entirely zero-emission. This is obvious and well known, but we want to pay attention to another threat.
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 Association of the Forum for the Recycling of Automobilhodów (FORS), based in Warsaw, is the largest and oldest Polish NGO representing the ELV recycling industry. We have almost 200 members, most of which are operators operating dismantling centres for end-of-life vehicles. We have been operating for more than 25 years.
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.
Take this comparison with you
2 organizations on one sheet: every file each filed on, their register declarations, and a working link to each submission. Free: we ask for your name and email, and PolicySpeak may contact you about the product (privacy policy). The per-file record stays downloadable without signing up on each file’s page.
