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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
TE
49
files engaged
of 583 tracked
59
positions filed
in those 583 files
21.7
declared FTE
self-declared
26
EP accreditations
as declared to the register

Declared costs: not declared · in the register since 2010

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

Transport & Environment · filed 28 Nov 2023 · source

Transport & Environment, Europes leading clean transport campaign group, welcomes the Commissions proposal for a revised End of Life Vehicles law. This law is fundamental to ensure circularity of cars and greening of their production. The revised legislation should be as much about what goes into making a new car (low carbon and recycled materials) as about how its recycled at the end of its life.

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

Transport & Environment · filed 24 May 2024 · source

T&E welcomes the Commissions draft act on the methodology for calculating the carbon footprint of electric vehicle batteries. Prioritising direct connection to renewable energy, thus rewarding clean manufacturing, and opting for a battery approach for the functional unit are key principles and should be kept.

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