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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.

SSB
Svebio, Swedish Bioenergy Association

Industry association · Sweden

3
files engaged
of 583 tracked
3
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
BDI
Bundesverband der Deutschen Industrie e.V.

Industry association · Germany

56
files engaged
of 583 tracked
68
positions filed
in those 583 files
20.6
declared FTE
self-declared
15
EP accreditations
as declared to the register

Declared costs: €4M+ a year · in the register since 2008

Files both filed on (3)

Monitoring, reporting and verification of greenhouse gas emissions from maritime transport · Revision of the Energy Tax Directive · CO2 emission standards for cars and vans

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.

Monitoring, reporting and verification of greenhouse gas emissions from maritime transport

Bundesverband der Deutschen Industrie e.V. · filed 24 Nov 2020 · source

A successful, cost efficient translation of Europe´s political climate ambition into action depends on a holistic and consistent mix of policy instruments. The revision of the ETS Directive should be closely tied in with the revision of the ESR, the ETD and RED, the State Aid Guidelines (EEAG) or any possible CBAM proposal.

Svebio, Swedish Bioenergy Association · filed 26 Nov 2020 · source

Answer from Svebio - Swedish Bioenergy Association We strongly support extension of carbon pricing to the sectors outside ETS. But we are not convinced that inclusion in ETS of the heating and transport sectors are the right way to do this. We would instead prefer introducing carbon taxes on sectors outside ETS. It is a simpler and more straightforward incentive than carbon emission trading.

Bundesverband der Deutschen Industrie e.V. · filed 8 Nov 2021 · source

To stay ahead in the global race for the best climate and energy technology solutions, companies need a clear and reliable fit-for-55 implementation plan providing a clear commitment to Europe as an attractive business, investment and innovation location.

Revision of the Energy Tax Directive

Svebio, Swedish Bioenergy Association · filed 15 Nov 2021 · source

The European Commission misses the opportunity to introduce a common minimum tax rate for carbon dioxide emissions. This is remarkable given that the proposed directive is part of the Green deal. Our proposal is a minimum carbon dioxide tax of 25 €/ton CO2 for all sectors outside ETS. This would be a better incentive than the proposed ETS-system for buildings and transport.

Bundesverband der Deutschen Industrie e.V. · filed 18 Nov 2021 · source

To stay ahead in the global race for the best climate and energy technology solutions, companies need a clear and reliable fit-for-55 implementation plan providing a clear commitment to Europe as an attractive business, investment and innovation location.

CO2 emission standards for cars and vans

Bundesverband der Deutschen Industrie e.V. · filed 25 Nov 2020 · source

The IIA correctly states that "CO2 standards give vehicle manufacturers the legal certainty to invest more in related R&D, to produce more zero-emission vehicles so that with increased supply and economy of scale they can become more affordable for citizens”.

Svebio, Swedish Bioenergy Association · filed 8 Nov 2021 · source

The EU regulation has to change from zero tail-pipe to well-to-wheels and conventional biofuels from crops are much needed also for cars. The EU climate target for the transport sector is far too low, only 13 percent in emission reduction by 2030 compared to the Swedish target of 70 percent reduction.

Bundesverband der Deutschen Industrie e.V. · filed 8 Nov 2021 · source

To stay ahead in the global race for the best climate and energy technology solutions, companies need a clear and reliable fit-for-55 implementation plan providing a clear commitment to Europe as an attractive business, investment and innovation location.

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