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.
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.
T&E welcomes the Commission’s initiative to align the ETS directive with the EU’s 2030 target of at least -55% emissions reduction and to ensure that all sectors contribute, in line with the EU’s international commitment to economy-wide action under the Paris Agreement. However, T&E regrets that the Commission is considering to switch gear on tackling emissions in the road sector.
This response is about the inclusion of 1)shipping and 2)road transport into the ETS: 1.SHIPPING Shipping accounts for around 3.5% of the EU’s total GHG emissions, but has so far avoided regulation on its climate impact. Integrating shipping into the ETS is a positive step in the right direction and will put shipping on the path towards climate neutrality in line with the Paris Agreement.
While every other sector’s climate emissions have decreased since 1990, on average, transport emissions have increased by almost 30% since 1990 (aviation emissions, for one, have more than doubled). Each mode of transport faces varying challenges to reverse this trend and reduce them in the coming decade.
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.
EU car CO2 standards are a modern day climate and industrial policy, pushing investment into automotive transformation and securing supply of affordable electric cars to achieve zero carbon transport in Europe. T&E’s analysis shows that the 2020/21 standard of 95g/km will result in plug-in sales of 10% this year and 15% in 2021, making Europe a leading electric car market.
T&E welcomes the opportunity to input into the design of the impact assessment regarding van CO2 standards, and advocates to: (1) Assess CO2 emission reduction targets of 20% for 2025, 31% for 2027 (brought forward from 2030), at least 60% for 2030, at least 86% for 2033 and 100% for 2035 (i.e.
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.
Transport & Environment feedback on car CO2 standards. Transport & Environment (T&E) welcomes the Commission’s (EC) proposal for a revision of the EU CO2 standards for cars. The 2020/21 EU car CO2 standards have resulted in an unprecedented drop in CO2 emissions from new cars (18%) compared to 2019, driven by the production and sale of a growing offer of EVs (reaching 16% in the first half of 2021).
Linked to the surge in home deliveries, vans are the EU’s fastest growing source of road transport emissions. Unlike for cars, the EU's van CO₂ standards have failed to put electric vans on the market in any real numbers. Only 2% of van sales were electric in 2020, compared to 11% for cars. The Commission’s Fit for 55 proposal that all new vans must be zero emission from 2035 is welcome.
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