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
Company · France
Declared costs: €2M+ 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.
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.
EDF · filed 8 Nov 2021 · source
In short below and for details please find enclosed EDF(Electricité de France)'s contribution EDF welcomes the ambitious revision of the EU-ETS to align it with the new 2030 target. A meaningful carbon price will drive cost-effective energy transition by promoting investments in renewable and low-carbon technologies.
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
EDF · filed 8 Nov 2021 · source
EDF welcomes the European Commission’s FuelEU Maritime initiative aiming to reduce GHG emissions in the maritime sector. Today maritime transport is a growing source of GHG emissions and the EU needs to tackle this issue to be fully in line with the Green Deal and the carbon neutrality target by 2050.
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