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.
NGO · Netherlands
Declared costs: not declared · in the register since 2015
NGO · Germany
Declared costs: not declared · in the register since 2012
Sustainable aviation fuels (ReFuelEU Aviation Initiative) · 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.
Vereniging Milieudefensie · filed 20 Apr 2020 · source
Milieudefensie - Friends of the Earth Netherlands welcomes the opportunity to give feedback on the inception impact assessment of the ReFuelEU Aviation initiative. Milieudefensie supports the objective to reduce the environmental footprint of the aviation sector. To bring the sector in line with the Paris Agreement, we believe mandatory greenhouse gas emission reduction targets are indispensable.
Deutsche Umwelthilfe e.V. · filed 21 Apr 2020 · source
Environmental Action Germany (Deutsche Umwelthilfe e.V.) welcomes the opportunity to comment on the ReFuelEU initiative. Greenhouse gas emissions from aviation must be reduced urgently. The ReFuelEU inception impact assessment, however, neglects important aspects of sustainability and availability of alternative fuels for aviation.
Vereniging Milieudefensie · filed 23 Apr 2020 · source
Milieudefensie - Friends of the Earth Netherlands supports the objective to reduce the emissions from the maritime sector by accelerating the uptake of sustainable alternative fuels and power. We agree with the European Commission that creating a predictable demand in this sector is essential for the investment and mass scale deployment of sustainable alternative fuels and power.
Deutsche Umwelthilfe e.V. · filed 23 Apr 2020 · source
Environmental Action Germany welcomes the opportunity to comment on this EC initiative. We wish to make the following comments: 1. Crop biofuels are more damaging to the climate than fossil fuels. Crop biofuels must be phased out entirely and must not be incentivised for use in shipping. 2. Advanced biofuels based on wastes and residues are not automatically sustainable.
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