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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.

VBC
VDL Bus & Coach

Company · Netherlands

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

Files both filed on (2)

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.

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

Japan Business Council in Europe · filed 1 Dec 2023 · source

Being a cross sector association with member companies operating in different industries and stages in the supply chain (electronics, chemicals, polymer, automotive , machinery, semiconductor, steel, nonferrous metal, textiles, ceramics, and glass products), Japan Business Council in Europe (JBCE) welcomes the opportunity to contribute to the Commission 's proposal regarding End of life Vehicles (ELV) revision of EU…

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

Carbon footprint methodology for electric vehicle batteries

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

Japan Business Council in Europe · filed 28 May 2024 · source

As a cross-sector association with member companies operating in different industries and at different stages of the supply chain (electronics, chemicals, polymers, automotive, HVACR, machinery, semiconductors, wholesale trade, precision instruments, pharmaceuticals, steel, non-ferrous metals, textiles, ceramics and glass products), JBCE welcomes the opportunity to contribute to the draft delegated regulation1 act…

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