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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.

NCA
The Norwegian Consumer Authority

Public authority · Norway

2
files engaged
of 583 tracked
2
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
DIG
DIGITALEUROPE

Industry association · Belgium

67
files engaged
of 583 tracked
78
positions filed
in those 583 files
26.7
declared FTE
self-declared
26
EP accreditations
as declared to the register

Declared costs: €3.5M+ a year · in the register since 2011

Files both filed on (2)

Substantiation and communication of explicit environmental claims (Green Claims Directive) · Empowering consumers for the green transition

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.

Substantiation and communication of explicit environmental claims (Green Claims Directive)

The Norwegian Consumer Authority · filed 21 Jun 2023 · source

1/8 Submitted electronically on ec.europa.eu Deres ref. Our ref. Case no: 23/2318-3 Executive Officer: Mathilde Furunes Dir.phone: 45971625 Date: 21.06.2023 The Norwegian Consumer Authority's feedback on the proposal for a directive on substantiation and communication of explicit environmental claims 1 INTRODUCTION We refer to the Commission’s proposal for a Directive on substantiation and communication of explicit…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

DIGITALEUROPE · filed 20 Jul 2023 · source

18 July 2023 DIGITALEUROPE feedback on Substantiating Green Claims’ public consultation Executive summary The proposed Green Claims Directive (GCD) is a positive step toward combating greenwashing. However, its effectiveness will depend on enforcement and the establishment of clear methodologies.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Empowering consumers for the green transition

DIGITALEUROPE · filed 27 Jul 2020 · source

DIGITALEUROPE’s members have long led the way with environmental progress, and many have put forward ground-breaking commitments and programmes to deliver innovative products and services in a sustainable way. Our members empower consumers to take part in the circular economy through numerous strategies, including providing transparent information on the sustainability credentials of our products and services…

The Norwegian Consumer Authority · filed 27 May 2022 · source

The Norwegian Consumer Authority is supportive of the proposed changes to the Unfair Commercial Practices Directive and Consumer Rights Directive. It is a comprehensive proposal that is likely to significantly improve consumers' ability to make informed choices, and strengthen the enforcement capabilities of competent authorities in the face of greenwashing.

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