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.
Company · Japan
Industry association · United Kingdom
Monitoring, reporting and verification of greenhouse gas emissions from maritime transport · Carbon dioxide emissions from maritime transport: global data collection system for ship fuel oil consumption data
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.
International Chamber of Shipping · filed 26 Nov 2020 · source
Comments by International Chamber of Shipping (ICS) Our full comments can be found here: https://www.ics-shipping.org/wp-content/uploads/2020/11/Inception-Impact-Assessment-for-the-proposed-Amendment-of-the-EU-Emissions-Trading-System-Directive-2003-87-EC-1.pdf The International Chamber of Shipping (ICS) appreciates this opportunity to comment on the Inception Impact Assessment for the proposed Amendment of the EU…
The Japanese Shipowners' Association · filed 27 Oct 2021 · 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.:
International Chamber of Shipping · filed 18 Jul 2017 · source
ICS welcomes revising the EU Shipping MRV Regulation in order align the EU MRV with the global IMO Data Collection System (DCS). The shipping industry is encouraged by the positive statements from the European Commission acknowledging the significant progress made by IMO Member States towards addressing GHG emissions from international shipping.
The Japanese Shipowners' Association · filed 19 Jul 2017 · source
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.
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