Side by side
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.
Industry association · France
NGO · Germany
Declared costs: not declared · in the register since 2012
Revision of the Energy Tax Directive · Review of energy labelling requirements for solid fuel boilers
Register facts self-declared (snapshot 2 Sept 2026); cost bands are floors. Shared files are shared attention, not evidence of coordination.
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.
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
Deutsche Umwelthilfe e.V. · filed 18 Nov 2021 · source
Environmental Action Germany (Deutsche Umwelthilfe, DUH) notes that the many tax exemptions in the Energy Taxation have led to a very disparate and complex energy tax landscape in Europe, which also hinders the integration of the internal energy market.
Syndicat des énergies renouvelables (SER) · filed 21 Dec 2023 · source
SER (French renewable energy trade association) would like to submit the following inputs : Data more representative of the market should be used for the revision. The Commission should not use data from BAFA, the German financial aid scheme, but use instead data from the Flamme Verte label.
Deutsche Umwelthilfe e.V. · filed 21 Dec 2023 · source
On behalf of Deutsche Umwelthilfe (DUH, Environmental Action Germany), we welcome the revision of the Ecodesign Regulation for solid fuel boilers/SFB (EU 2015/1189). Over a fifth of total PM2.5 in Germany comes from small combustion appliances however, as reporting does not include condensables (condensed particles), actual emissions from this sector are much higher.
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