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
NGO · Belgium
Declared costs: not declared · in the register since 2010
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.
Transport & Environment · filed 26 Nov 2020 · source
T&E welcomes the Commission’s initiative to align the ETS directive with the EU’s 2030 target of at least -55% emissions reduction and to ensure that all sectors contribute, in line with the EU’s international commitment to economy-wide action under the Paris Agreement. However, T&E regrets that the Commission is considering to switch gear on tackling emissions in the road sector.
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.
Transport & Environment · filed 8 Nov 2021 · source
This response is about the inclusion of 1)shipping and 2)road transport into the ETS: 1.SHIPPING Shipping accounts for around 3.5% of the EU’s total GHG emissions, but has so far avoided regulation on its climate impact. Integrating shipping into the ETS is a positive step in the right direction and will put shipping on the path towards climate neutrality in line with the Paris Agreement.
Transport & Environment · filed 23 Apr 2020 · source
We welcome the EC initiative to develop an effective EU regulation to drive the uptake of sustainable alternative fuels in EU shipping. We agree with the EC assessment that creating a predictable demand in the shipping industry is essential for the investment and mass scale deployment of sustainable alternative fuels.
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
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.
Transport & Environment · filed 13 Jul 2017 · source
EU shipping MRV has 3 main objectives: 1. Provide accurate and transparent bottom-up ship emissions data 2. Address market barriers for uptake of efficient ships 3. Incentivise operational efficiency ships by providing clear metrics for real transport work By moving first, the adoption of the EU MRV incentivised the IMO to start work on a global Data Collection System (DCS) and as such, this clear leadership by the…
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