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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.

TL
Topsector Logistics

Other · Netherlands

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

Industry association · Belgium

46
files engaged
of 583 tracked
55
positions filed
in those 583 files
19.5
declared FTE
self-declared
11
EP accreditations
as declared to the register

Declared costs: €5.5M+ a year · in the register since 2008

Files both filed on (2)

Substantiation and communication of explicit environmental claims (Green Claims Directive) · Accounting of greenhouse gas emissions of transport services

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)

Topsector Logistics · filed 30 Aug 2020 · source

Topsector Logistics The European Green Deal has more forcefully put logistics emissions on the policy agenda of the European Commission. As Topsector Logistics in The Netherlands, we applaud this. As we will explain below, we have been active in reducing transport and logistics emissions in The Netherlands and believe we can contribute to the achievement of the ambitious goals set out.

ACEA · filed 31 Aug 2020 · source

ACEA welcomes LCA analyses as they are important procedures that can help to reduce a motor vehicle’s impact on the environment and believes that the studies made should be scientifically sound and compare equivalent systems. LCA can be a useful tool to address environmental issues and is applied as internal environmental system for systematically managing environmental improvements in the automotive industry.

Accounting of greenhouse gas emissions of transport services

Topsector Logistics · filed 18 Aug 2023 · source

The practical implementation of the accounting of greenhouse gas emissions of transport services has been a focal point for Topsector Logistics (https://topsectorlogistiek.nl/over-topsector-logistiek/) in the last decade. We are pleased to see that the Commission has taken an approach in the proposed regulation that aligns with our practical experience.

ACEA · filed 14 Nov 2023 · source

ACEA supports the move towards a harmonized emissions calculation framework in the EU. We believe that this will enhance the accuracy and comparability of emissions data and support companies in their sustainability efforts. However, it is essential that these new rules are carefully designed to align with existing regulations and avoid unnecessary duplication.

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