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
NGO · Germany
Declared costs: not declared · in the register since 2012
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.
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
Deutsche Umwelthilfe e.V. · filed 4 Dec 2023 · source
DUH welcomes the EUs intention to ensure end-of-life vehicles (ELVs) are managed sustainably and re-quiring the car industry to adopt a sustainable design and production of cars as part of the Regulation on Circularity Requirements for Vehicle Design and on Management of End-of-Life Vehicles (VDEoL).
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
Deutsche Umwelthilfe e.V. · filed 28 May 2024 · source
DUH welcomes the Commissions draft act on the methodology for the calculation and verification of the carbon footprint of electric vehicle batteries. The most energy- and carbon-intensive part of battery manufacturing is the production chain of battery cells, responsible for as much as 75% of energy consumption.
2 organizations on one sheet: every file each filed on, their register declarations, and a working link to each submission. Free: we ask for your name and email, and PolicySpeak may contact you about the product (privacy policy). The per-file record stays downloadable without signing up on each file’s page.