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
NGO · Belgium
Declared costs: not declared · in the register since 2010
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.
Transport & Environment · filed 26 Nov 2020 · source
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.
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.:
Transport & Environment · filed 8 Nov 2021 · source
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.
Transport & Environment · filed 13 Jul 2017 · source
EU shipping MRV has 3 main objectives: 1. Provide accurate and transparent bottom-up ship emissions data 2. Address market barriers for uptake of efficient ships 3. Incentivise operational efficiency ships by providing clear metrics for real transport work By moving first, the adoption of the EU MRV incentivised the IMO to start work on a global Data Collection System (DCS) and as such, this clear leadership by the…
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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