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.
Industry association · Germany
Declared costs: not declared · in the register since 2012
Industry association · Belgium
Declared costs: €10M+ a year · in the register since 2009
Monitoring, reporting and verification of greenhouse gas emissions from maritime transport · 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.
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.
Verband Deutscher Reeder · filed 26 Nov 2020 · source
The German Shipowners’ Association (VDR) welcomes the opportunity to provide input to the revision of the EU Emission Trading System Directive of the European Commission. You will find our feedback on the roadmap on the revision of the EU ETS Directive regarding shipping in the attached document.
Cefic · filed 26 Nov 2020 · source
The ETS should remain a core policy instrument to establish CO2 abatement at the lowest practicable cost to society. We do not favor inclusion of other sectors such as transport and buildings as an extension of the ETS current scheme, which already has to cope with different sectors with distinct elasticities, and risks on carbon leakage in one system.
Verband Deutscher Reeder · filed 8 Nov 2021 · source
If Europe wants to play a role in helping the shipping industry to make this propulsion revolution a reality, support needs to be given to shipping in overcoming the multiple hurdles to fully decarbonise. For a possible decision of Europe to integrate shipping in the EU Emission Trading System (ETS) this means that specific conditions need to be met when structuring the underlying regulation of the ETS.
Verband Deutscher Reeder · filed 8 Nov 2021 · source
The VDR welcomes the ambitious climate action presented by the European Commission in the Fit for 55 legislative package in July 2021 to make Europe the first climate-neutral continent in the world by 2050. in order for this Regulation on the use of renewable and low carbon fuels in maritime transport (hereinafter “FuelEU Maritime”) to be fully effective in terms of climate protection, the VDR considers that the…
Filed in German · English published by the European Commission
Cefic · filed 8 Nov 2021 · source
•The European Oleochemicals & Allied Products Group (APAG) welcomes the Commission’s proposal for the FuelEU Maritime Regulation. As we fully support the European Union’s intention to reduce emissions from shipping and would support a more ambitious approach on biofuels, modeled after the Renewable Energy Directive, including: 1.
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