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.
The Japanese Shipowners' Association (JSA) is strongly opposed to the EU’s intent to extend the EU Emissions Trading System (ETS) to the maritime sector and introduce regional regulations which impact on international shipping. The reasons for our opposition are as attached.:
Even though ECSA's first preference always is an international regulation for shipping at IMO level, the sector should contribute its fair share to address the climate crisis at EU level as well. European shipowners firmly support a dedicated fund to be set up under the EU ETS to stabilise the carbon price.
The Japanese Shipowners’ Association would welcome the European Commission to revise EU MRV regulation. Recital 34 of the EU MRV Regulation states that a global MRV system is preferable as it could be regarded as more effective due to its broader scope and that where an agreement on a global MRV system is reached the Commission should review the regulation with a view to aligning it to the global MRV system.
The European Community Shipowners’ Associations (ECSA) and the International Chamber of Shipping (ICS) welcome the revision of Regulation (EU) 2015/757, thereafter the MRV Regulation, attempting to align the EU MRV with the global IMO Data Collection System (IMO DCS). ECSA nonetheless regrets that the European Commission did not opt for a full alignment with the IMO DCS.
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