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 · Netherlands
Industry association · Belgium
Declared costs: €5.5M+ a year · in the register since 2008
Circularity requirements for vehicle design and management of end-of-life vehicles · Carbon footprint methodology for electric vehicle batteries
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.
ACEA · filed 19 Nov 2020 · source
The ELV Directive, which came into force 20 years ago largely delivered on its initial objectives due to the significant efforts made by the automotive and the recycling industry. The European Automobile Manufacturers’ Association (ACEA) fully supports the European Commission’s initiative to ensure a better consistency with the objectives of the European Green Deal, including the Circular Economy Action Plan and the…
VDL Bus & Coach · filed 4 Dec 2023 · source
The regulation proposal describes that manufacturers have an extended producer responsibility for their vehicles that are available on the market for the first time within the territory of a Member State. Manufacturers shall, individually or collectively, ensure that end-of-life vehicles are collected or collected (Article 16).
Filed in Dutch · English published by the European Commission
ACEA · filed 4 Dec 2023 · source
The European Automobile Manufacturers' Association (ACEA) is firmly committed to advancing the EU towards a modern, resource-efficient, and competitive economy. We welcome the European Commission's Proposal for a Regulation on circularity requirements for vehicle design and on management of end-of-life vehicles (ELVs), which envisages a transformation towards enhanced sustainability, circularity, and innovation.
VDL Bus & Coach · filed 24 May 2024 · source
While the commercial warranty may provide a general idea of a battery expected Lifespan, we Argue that it does not have an accurate measure for the years of operation (YoP), as detailed in Chapter 2.1. The battery technical features, such as energy density, power, charge rate, and sliding rate, can have a greater impact on its Lifespan.
Filed in Dutch · English published by the European Commission
ACEA · filed 28 May 2024 · source
The automotive industry takes note of the recently published delegated act establishing the methodology for the calculation of the carbon footprint of electric vehicle batteries, as mandated by Article 7 of the Batteries Regulation.
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