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.
The VDA represents the interests of the entire German automotive industry: manufacturers of passenger cars, trucks and buses, as well as suppliers and the manufacturers of trailers and bodies. In the Sustainable and Smart Mobility Strategy (SSMS) published by the Commission on December 9, 2020, the Commission committed to beginning preparatory work on a possible legislative proposal to revise the Weights and…
Trailer Dynamics GmbH explicitly welcomes the EU initiative to increase the total weight of ZEV vehicles to 44 tonnes across Europe. The electrification of the respective vehicles (tracetor or trailer) is associated with an inevitable extra weight due to the e-components, in particular of the battery.
Filed in German · English published by the European Commission
The forecast predicts a growing haulage capacity in Europe with the need for fossil-free transportation modes. In Europe about three third of goods are transported on roads by light and heavy duty vehicles. Stringent CO2 reduction targets for Heavy Duty Vehicles (HDV) will contribute to the objective to reduce overall CO2 emissions by 55% by 2030 and to reach climate neutrality until 2050.
Trailer Dynamics explicitly supports the adaptations of EU Directive 2019/1242. In particular, we welcome the definition of the eTrailer with active zero-emission propulsion as a zero-emission heavy-duty vehicle. The decarbonisation of heavy goods through eTrailers can thus become a reality.
Filed in German · English published by the European Commission
VDA welcomes the opportunity to contribute comments on the proposed revision of Regulation (EU) 2019/1242 for CO2 standards of HDV. German heavy-duty vehicle manufacturers and suppliers are strongly committed to rapidly reducing CO2 emissions in the public passenger and road freight transport sector and to making newly registered commercial vehicles fossil-free by 2040.
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