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 · Netherlands
Declared costs: €300K+ a year · in the register since 2016
Industry association · Germany
Declared costs: €400K+ a year · in the register since 2011
Cyber Resilience Act · General Product Safety Regulation · Liability for defective products · Adapting non-contractual civil liability rules to artificial intelligence (AI Liability Directive)
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.
ZVEI e.V. · filed 25 May 2022 · source
The German Electro and Digital Industry Association (ZVEI) welcomes the opportunity to provide feedback to the Impact Assessment of the European Commission. Cybersecurity, as a cross-cutting task is a top priority at ZVEI in all its lead markets: Industry 4.0, energy, mobility, components, building, health and consumer electronics.
ZVEI e.V. · filed 22 Jan 2023 · source
In the light of the proliferation of a fragmented regulatory landscape regarding cybersecurity, the ZVEI is a strong long-time proponent for a horizontal cybersecurity regulation for products within the proven new legislative framework (NLF).
TomTom · filed 23 Jan 2023 · source
TomTom wishes to provide feedback regarding the public consultation for the proposal for a regulation on horizontal cybersecurity requirements for products with digital elements (amending Regulation (EU) 2019/1020) published on the 15th of September 2022, the Cyber Resilience Act.
TomTom · filed 4 Oct 2021 · source
TomTom welcomes the fact that Type-approval for motor vehicles and the General Safety Regulation (GSR) are both listed as “Union harmonization legislation” covering the automotive sector. Obligations on economic operators and their placing on the market of products defined in the GPSD proposal only apply when obligations are not yet covered by Union harmonisation legislation.
ZVEI e.V. · filed 4 Oct 2021 · source
The ZVEI supports the objectives of the European Commission to better protect consumers and create better framework conditions for economic operators through the revision of the existing General Product Safety Directive (2001/95/EC).
ZVEI e.V. · filed 28 Jul 2021 · source
ZVEI welcomes the opportunity to provide input to the European Commission's Inception Impact Assessment on adapting liability rules to the digital age and artificial intelligence (AI). From a ZVEI point of view there is currently no reason for a fundamental revision of the Product Liability Directive (PLD) or the introduction of a new horizontal legislation on liability for AI.
TomTom · filed 9 Dec 2022 · source
TomTom wishes to submit feedback on the Product Liability Directive together with fellow location technology provider HERE Technologies. Our position paper gives feedback on both the Product Liability Directive and the AI Liability Directive. Please refer to our position paper for full details.
TomTom · filed 28 Nov 2022 · source
Considering the parallel cross-sectorial legislative proposal on liability (the revision of the product liability directive from 1985) and the potential overlap between these two pieces of legislation, TomTom would like to submit detailed comments on both files simultaneously during the PLD consultation (closing on 9th December 2022).
ZVEI e.V. · filed 28 Nov 2022 · source
With reference to our statement from July 2021 on the Inception Impact Assessment and our position paper "Liability for AI" from May 2021 submitted in this context, we maintain the position that, in view of the existing technology-neutral and comprehensively applicable product safety and liability law, there are no relevant liability gaps for potential damage caused by AI applications and systems and thus no need…
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