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.
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 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.
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 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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