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 · Germany
Industry association · Denmark
Declared costs: €2.3M+ a year · in the register since 2008
Commission Regulation amending the CLP Regulation (EC) 1272/2008 and correcting Commission Regulation (EU) 2018/669 · Evaluation of the Biocidal Products Regulation
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.
THOR GmbH · filed 8 Feb 2019 · source
With this statement we would like to comment on the proposal to classify titanium dioxide (TiO2) as Carcinogen Category 2 (H351) (inhalation). The observed adverse effects in the lungs of animals chronically exposed to TiO2 were very likely caused by the so-called "lung overload".
Danish Industry · filed 8 Feb 2019 · source
The Confederation of Danish Industry (DI) welcomes the opportunity to provide comments to public consultation on the draft ATP to the CLP, as part of its Better Regulation approach. DI representsmore than 10,000 private enterprises within manufacturing, trade and services covering most sub-sectors.
THOR GmbH · filed 5 Mar 2026 · source
THOR is a global producer of speciality chemicals, delivering high-performance biocide, flame-retardant and personal-care solutions. Founded in England, we operate world-wide, enhancing the safety, durability and functionality of products across construction, coatings, hygiene, automotive, water treatment, personal care, textile sectors and more.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Danish Industry · filed 5 Mar 2026 · source
The Confederation of Danish Industry share the Commissions view that the current BPR framework presents substantial regulatory and practical challenges. We are ready to contribute to identifying and implementing constructive solutions to improve the system, and our members are committed to ensuring high standards to protect the environment.
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