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.
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.
A successful, cost efficient translation of Europe´s political climate ambition into action depends on a holistic and consistent mix of policy instruments. The revision of the ETS Directive should be closely tied in with the revision of the ESR, the ETD and RED, the State Aid Guidelines (EEAG) or any possible CBAM proposal.
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.
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.
To stay ahead in the global race for the best climate and energy technology solutions, companies need a clear and reliable fit-for-55 implementation plan providing a clear commitment to Europe as an attractive business, investment and innovation location.
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
To stay ahead in the global race for the best climate and energy technology solutions, companies need a clear and reliable fit-for-55 implementation plan providing a clear commitment to Europe as an attractive business, investment and innovation location.
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