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 · Germany
Declared costs: not declared · in the register since 2012
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.
Verband Deutscher Reeder · filed 26 Nov 2020 · source
The German Shipowners’ Association (VDR) welcomes the opportunity to provide input to the revision of the EU Emission Trading System Directive of the European Commission. You will find our feedback on the roadmap on the revision of the EU ETS Directive regarding shipping in the attached document.
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.:
Verband Deutscher Reeder · filed 8 Nov 2021 · source
If Europe wants to play a role in helping the shipping industry to make this propulsion revolution a reality, support needs to be given to shipping in overcoming the multiple hurdles to fully decarbonise. For a possible decision of Europe to integrate shipping in the EU Emission Trading System (ETS) this means that specific conditions need to be met when structuring the underlying regulation of the ETS.
Verband Deutscher Reeder · filed 12 Jul 2017 · source
The shipping industry is encouraged by the positive statements from the European Commission which acknowledge the significant progress made by IMO Member States towards addressing GHG emissions from international shipping. With the full support of the industry, IMO Member States have agreed inter alia to develop a comprehensive strategy for the further reduction of GHG emissions from 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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