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 · Germany
Industry association · Belgium
Declared costs: €400K+ a year · in the register since 2008
Commission Regulation amending the CLP Regulation (EC) 1272/2008 and correcting Commission Regulation (EU) 2018/669 · Circularity requirements for vehicle design and management of end-of-life vehicles
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.
TSR Recycling GmbH & Co. KG · filed 8 Feb 2019 · source
The TSR Group, headquartered in Germany, is a European leader in the recycling of metals and established partners for international business, small and medium-sized enterprises, micro enterprises and local authorities.
Filed in German · English published by the European Commission
European Aluminium · filed 8 Feb 2019 · source
European Aluminium, representing the aluminium industry in Europe, does not support the proposed classification of TiO2 as a carcinogen by inhalation. At this time, the criteria applied to mixtures containing TiO2 require further development and there are still several important issues and implications that need to be considered further, both at technical and legislative level.
European Aluminium · filed 13 Nov 2020 · source
In the context of the revision of the End of Life Vehicle Directive European Aluminium would like to share its top priorities. The following points are focusing on issues that can improve the recycling of End of Life Vehicles (ELVs) in general and the recycling of aluminium from these vehicles in particular. 1. There is no need for minimum recycled content rates for materials like aluminium. 2.
European Aluminium · filed 1 Dec 2023 · source
European Aluminium welcomes the publication of the long-awaited proposal for a Regulation on circularity requirements for vehicle design and on management of end-of-life vehicles (ELV) and looks forward to engaging with policymakers for the shaping of an effective and forward-looking ELV Regulation.
TSR Recycling GmbH & Co. KG · filed 4 Dec 2023 · source
TSR Recycling welcomes the European Commission’s proposal for a new regulation on end-of-life vehicles and its objective of improving the recovery of end-of-life vehicles and strengthening the EU internal market. TSR Recycling operates around 100 steel and metal treatment plants in 10 European countries.
Filed in German · English published by the European Commission
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