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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.

SNR
Syndicat des énergies renouvelables (SER)

Industry association · 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
APP
APPLiA

Industry association · Belgium

46
files engaged
of 583 tracked
53
positions filed
in those 583 files
7.5
declared FTE
self-declared
6
EP accreditations
as declared to the register

Declared costs: €400K+ a year · in the register since 2010

Files both filed on (2)

Revision of the Energy Tax Directive · Ecodesign requirements for air-to-air conditioners, air-to-air heat pumps and comfort fans (review)

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.

Revision of the Energy Tax Directive

APPLiA · filed 25 Mar 2020 · source

a. Demand response One important area that the revision should take into consideration is how demand response instruments could contribute to reducing emissions of net greenhouse gases. Demand response solutions would be able to reduce the pressure on the network by better managing peak demands. To cope with temporary high energy requests, energy suppliers often make use of coal or fossil fuels.

APPLiA · filed 16 Nov 2021 · source

This paper is APPLiA’s proposed contribution to the feedback mechanism launched by the European Commission on the Fit for 55 package proposals. It provides an analysis and the first set of remarks on the provisions of the many legal texts under consultation. In some instances, APPLiA is proposing amendments and/or comments to specific articles/provisions of the Commission.

Syndicat des énergies renouvelables (SER) · filed 18 Nov 2021 · source

The European Commission has put in public consultation a proposal for a directive restructuring the EU framework for the taxation of energy products and electricity. This project calls for comments from the Renewable Energy Union (RES), as set out in the attached document.

Filed in French · English published by the European Commission

Ecodesign requirements for air-to-air conditioners, air-to-air heat pumps and comfort fans (review)

APPLiA · filed 17 Feb 2022 · source

We would like thank the Commission for sharing the call for evidence on airco, comfort fans and local heaters and for providing us with the opportunity to comment on it. While we support the Commission’s intention to update the labels, some of the energy efficiency calculations and the option of removing the least efficient products from the market, we would like to see it done without harming manufacturers…

Syndicat des énergies renouvelables (SER) · filed 18 Feb 2022 · source

The French renewable energy association (SER) is convince of the usefulness of the energy labelling to help consumers to choose less energy consuming products and to help therefore to reduce the energy consumption of the EU.

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