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.
The Energy Taxation Directive was approved in 2003 and has needed a revision for several years. As it deals with member states taxation it needs unanimous approval. A taxation on fossil fuel content is often a cost-effective way to achieve decreased emissions. It has been poorly used, and while many members states, as is the Commission, look at a carbon tax, we have not seen it in practise.
The Energy Taxation Directive was approved in 2003 and has needed a revision for several years. As it deals with member states taxation it needs unanimous approval. A taxation on fossil fuel content is often a cost-effective way to achieve decreased emissions. It has been poorly used, and while many members states, as is the Commission, look at a carbon tax, we have not seen it in practise.
Environmental Action Germany (Deutsche Umwelthilfe, DUH) notes that the many tax exemptions in the Energy Taxation have led to a very disparate and complex energy tax landscape in Europe, which also hinders the integration of the internal energy market.
The 2030-secretariate is committed to achieving a 70% CO2 reduction in the Swedish transport sector by 2030 and is thus strongly in favour of heightened ambitions for fuels, vehicles and mobility in the European market. We are eagerly awaiting the EU Smart and Sustainable Mobility Strategy in December - outside the scope of this feed-back, but an area where the Commission needs to step up its act.
The car CO2 standards represent the primary EU policy instrument driving the transition to zero-emission road transport. Current standards are not in line with the Paris Agreement, and several elements of the regulation limit its effectiveness. These shortcomings must now be addressed, and the overall ambition significantly increased to set road transport on a rapid path to zero emissions within the next few years.
The Swedish 2030 secret is an independent Think tank committed to the decree of the transport sector. We are not searched into any specific technological solution, the GHG reduction is what matters.Grow sooner than later — we cannot wait until electric vehicles dominate the light vehicle market in the mid 2030 's. The introduction of CO2 demands on new cars and vans on the European market has been successful.
Filed in Swedish · English published by the European Commission
DUH welcomes the opportunity to submit feedback on the European Commission (EC) proposal for revised car CO2 standards. Road transport emissions have been rising over the last 30 years. Without fast and significant reductions in passenger car emissions, the EU won’t be able to meet its own climate targets, let alone the 1.5°C limit.
Environmental Action Germany (Deutsche Umwelthilfe e.V.) welcomes the opportunity to comment on the ReFuelEU initiative. Greenhouse gas emissions from aviation must be reduced urgently. The ReFuelEU inception impact assessment, however, neglects important aspects of sustainability and availability of alternative fuels for aviation.
The Swedish 2030 secretariat is an independent Think tank committed to the decarbonization of the transport sector. We are not looked into any specific technological solution, the GHG reduction is what matters. Rather sooner than later. The sustainability debate for aviation is quite recent, and it is welcome to see a stronger sustainability focus on aviation. The RefuelAviation Directive is an important step.
The sustainability debate for aviation is quite recent, and it is welcome to see a stronger sustainability focus on aviation. The RefuelAviation Directive is an important step. The RefuelAviation Directive is one of two new directives with a focus on strategic parts of the transport sector and are developed without any prior directives to “build on”.
Environmental Action Germany welcomes the opportunity to comment on this EC initiative. We wish to make the following comments: 1. Crop biofuels are more damaging to the climate than fossil fuels. Crop biofuels must be phased out entirely and must not be incentivised for use in shipping. 2. Advanced biofuels based on wastes and residues are not automatically sustainable.
The Swedish 2030-secretariat is an independent Think tank, committed to decarbonization of transport, but not locked into an specific technological solutions. GHG reduction is the target, sooner rather than later. The maritime sector dominates world trade. It is an energy efficient means of transport, but the scale of operations makes it a large contributor to global emissions.
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