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 · Belgium
Declared costs: not declared · in the register since 2010
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
ECOS · filed 4 Dec 2023 · source
ECOS, the Environmental Coalition on Standards, is an international NGO with a network of members and experts advocating for environmentally friendly technical standards, policies and laws. The old End-of-Life Vehicles Directive has been in force since 2000 with only minor changes and is in urgent need of a fundamental update to meet today's requirements in terms of circular economy and net zero emission targets.
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
ECOS · filed 28 May 2024 · source
ECOS welcomes the draft Delegated Act on a methodology for calculating the carbon footprint of electric vehicle batteries. ECOS considers the methodology an integral part of further reducing vehicle and battery-related emissions and we are pleased to see it has been delivered swiftly.
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