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: €900K+ a year · in the register since 2011
Monitoring, reporting and verification of greenhouse gas emissions from maritime transport · Sustainable maritime fuels (FuelEU Maritime Initiative) · Carbon dioxide emissions from maritime transport: global data collection system for ship fuel oil consumption data
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.
European Shipowners | ECSA · filed 8 Nov 2021 · source
Even though ECSA's first preference always is an international regulation for shipping at IMO level, the sector should contribute its fair share to address the climate crisis at EU level as well. European shipowners firmly support a dedicated fund to be set up under the EU ETS to stabilise the carbon price.
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
European Shipowners | ECSA · filed 8 Nov 2021 · source
ECSA supports the objective of the FuelEU Maritime proposal to foster the uptake of cleaner fuels in shipping. However, the proposal may become a missed opportunity. Using documents provided by non-EU fuel suppliers to calculate carbon savings contributing to the EU’s climate targets may create substantial enforcement loopholes.
Verband Deutscher Reeder · filed 12 Jul 2017 · source
The shipping industry is encouraged by the positive statements from the European Commission which acknowledge the significant progress made by IMO Member States towards addressing GHG emissions from international shipping. With the full support of the industry, IMO Member States have agreed inter alia to develop a comprehensive strategy for the further reduction of GHG emissions from shipping.
European Shipowners | ECSA · filed 29 Mar 2019 · source
The European Community Shipowners’ Associations (ECSA) and the International Chamber of Shipping (ICS) welcome the revision of Regulation (EU) 2015/757, thereafter the MRV Regulation, attempting to align the EU MRV with the global IMO Data Collection System (IMO DCS). ECSA nonetheless regrets that the European Commission did not opt for a full alignment with the IMO DCS.
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