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.
ECOS supports the provision of environmental information to consumers environmentally relevant, reliable, comparable and verifiable, through the development of an EU legal framework requiring companies to substantiate claims via the Environmental Footprint methods.
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)
The Green Claims Directive is urgently needed, and ECOS supports its adoption. It represents a crucial initial step that can and should be strengthened further. Nonetheless, even in its current form, it will significantly enhance legal measures against greenwashing. Voluntary environmental claims are made because they give a market advantage to those who make them.
ECOS welcomes the Commission’s initiative to empower consumers to play an active role in the green transition. Despite the clear preference of European consumers for more sustainable products, the absence of reliable information deprives from them of the opportunity to make informed purchasing decisions and fails to translate that preference into market demand and potentially market transformation.
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.
ECOS welcomes the European Commission’s proposal on strengthening the role of consumers in the green transition, notably the ban on unsubstantiated generic claims, new information requirements on product durability and repairability, and stronger regulation of labels and information tools.
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