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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.

UM
UBQ Materials

Company · ISR

2
files engaged
of 583 tracked
2
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
PRE
Plastics Recyclers Europe

Industry association · Belgium

16
files engaged
of 583 tracked
20
positions filed
in those 583 files
4.8
declared FTE
self-declared
6
EP accreditations
as declared to the register

Declared costs: €400K+ a year · in the register since 2011

Files both filed on (2)

Circularity requirements for vehicle design and management of end-of-life vehicles · EU-wide end-of-waste criteria for plastic waste

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.

Circularity requirements for vehicle design and management of end-of-life vehicles

Plastics Recyclers Europe · filed 19 Nov 2020 · source

Plastics Recyclers Europe (PRE) represents the interest of the plastics recycling industry. Several of PRE members are specialized in treating the shredder light fraction resulting from the ELV treatment to produce plastics recyclate for use in the traditional plastics compounding and converting industries. A fraction of this material is already being used in the automotive supply chain.

UBQ Materials · filed 21 Sept 2023 · source

We strongly support the EU proposal to address recycled plastic content targets in new passenger cars and light commercial vehicles. In line with Europe's aim to become a leader in the innovation space, we believe that the EU can advance its objectives to reduce plastic pollution by providing technical leadership to qualify first-of-kind technologies alongside traditional recycling technology solutions.

Plastics Recyclers Europe · filed 1 Dec 2023 · source

PRE advocates for the recyclability of plastic packaging by design and the inclusion of recycled content in parts and components for new vehicles placed on the market. Therefore, PRE welcomes the requirements of the EC proposal for all vehicles to be designed according to their end-of-life management.

EU-wide end-of-waste criteria for plastic waste

UBQ Materials · filed 26 Jan 2026 · source

UBQ Position: Strengthening the EU Plastics Pilot (COM/2025/805) UBQ Materials welcomes the European Commissions commitment to reinforcing the circular economy and the single market for secondary raw materials. We support strengthening the single market for waste and secondary raw materials using a broad definition of secondary materialsexplicitly including thermoplastic compositesand extending beyond conventional…

Plastics Recyclers Europe · filed 26 Jan 2026 · source

Plastics Recyclers Europe (PRE) welcomes the European Commissions initiative to establish EU-wide end-of-waste (EoW) criteria for plastic waste. PRE has long supported harmonised EoW criteria as a key tool to strengthen the internal market for plastic recyclates, reduce administrative burden, and provide legal certainty for recyclers operating across borders.

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