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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.

VDB
3
files engaged
of 583 tracked
3
positions filed
in those 583 files
0.8
declared FTE
self-declared
0
EP accreditations
as declared to the register

Declared costs: €200K+ a year · in the register since 2012

Files both filed on (3)

CO2 emission standards for cars and vans · Sustainable aviation fuels (ReFuelEU Aviation Initiative) · Sustainable maritime fuels (FuelEU Maritime Initiative)

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.

CO2 emission standards for cars and vans

Verband der Deutschen Biokraftstoffindustrie e.V. · filed 26 Nov 2020 · source

Policies to reduce the GHG emissions of newly registered cars are one of the most important instruments within the transport sector. Within this instrument ambitious performance standards for passenger cars are needed. However, it must be noted that 1. policy measures must have a significant and measurable effect on GHG emissions 2. besides setting ambitious goals, it is above all important to achieve them.

Deutsche Umwelthilfe e.V. · filed 26 Nov 2020 · source

The car CO2 standards represent the primary EU policy instrument driving the transition to zero-emission road transport. Current standards are not in line with the Paris Agreement, and several elements of the regulation limit its effectiveness. These shortcomings must now be addressed, and the overall ambition significantly increased to set road transport on a rapid path to zero emissions within the next few years.

Deutsche Umwelthilfe e.V. · filed 8 Nov 2021 · source

DUH welcomes the opportunity to submit feedback on the European Commission (EC) proposal for revised car CO2 standards. Road transport emissions have been rising over the last 30 years. Without fast and significant reductions in passenger car emissions, the EU won’t be able to meet its own climate targets, let alone the 1.5°C limit.

Sustainable aviation fuels (ReFuelEU Aviation Initiative)

Verband der Deutschen Biokraftstoffindustrie e.V. · filed 21 Apr 2020 · source

Addressing climate protection in the field of aviation is an excellent initiative of the European Commission. So far, this mode of transport has contributed virtually nothing to decarbonising Europe. This is mainly due to a lack of regulation. In order to reduce GHG emissions in aviation effectively, a binding mandate is needed.

Deutsche Umwelthilfe e.V. · filed 21 Apr 2020 · source

Environmental Action Germany (Deutsche Umwelthilfe e.V.) welcomes the opportunity to comment on the ReFuelEU initiative. Greenhouse gas emissions from aviation must be reduced urgently. The ReFuelEU inception impact assessment, however, neglects important aspects of sustainability and availability of alternative fuels for aviation.

Sustainable maritime fuels (FuelEU Maritime Initiative)

Deutsche Umwelthilfe e.V. · filed 23 Apr 2020 · source

Environmental Action Germany welcomes the opportunity to comment on this EC initiative. We wish to make the following comments: 1. Crop biofuels are more damaging to the climate than fossil fuels. Crop biofuels must be phased out entirely and must not be incentivised for use in shipping. 2. Advanced biofuels based on wastes and residues are not automatically sustainable.

Verband der Deutschen Biokraftstoffindustrie e.V. · filed 24 Apr 2020 · source

Addressing climate protection in the field of maritime shipping is an excellent initiative of the Euro-pean Commission. So far, this mode of transport has contributed virtually nothing to decarbonising Europe. This is mainly due to a lack of regulation. In order to reduce GHG emissions in maritime shipping effectively, a binding mandate is needed.

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