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.
Other · Netherlands
Industry association · Germany
Declared costs: €4M+ a year · in the register since 2008
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.
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.
Bundesverband der Deutschen Industrie e.V. · filed 27 Aug 2020 · source
The BDI supports the further development of the Product Environmental Footprint (PEF) method as a voluntary procedure for evaluating the environmental impact of products. The further development should be brought in line with the ISO standards for calculation and reporting or communication. The methods for calculating (eco)toxicity need to be technically revised.
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.
Bundesverband der Deutschen Industrie e.V. · filed 11 Jul 2023 · source
Environmental claims are playing an increasingly important role in shaping consumers' opinions and purchasing decisions. The sustainability of products and services has become a competitive factor. Products declared as "green" or sustainable are now experiencing greater growth in the EU domestic market than other products.
Bundesverband der Deutschen Industrie e.V. · filed 17 Dec 2021 · source
The Federation of German Industries (BDI) supports the Commission's goals of creating a level playing field for GHG calculations in the transport (freight and passenger services) and logistics sector with a uniform framework for calculating GHG emissions, while facilitating behavioural changes by users.
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.
Bundesverband der Deutschen Industrie e.V. · filed 15 Nov 2023 · source
The Federation of German Industries (BDI) welcomes the efforts of the European Commission for a transparent and harmonised calculation of transport-related greenhouse gas emissions. To provide incentives for climate protection in passenger and freight transport and effectively reflect emissions of logistics chains, a technology-neutral design of the regulatory approach is required across all modes of transport and…
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