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.
ETS reform as part of a package to collectively increase climate ambition Deutsche Umwelthilfe (DUH) notes that even with a 2030-climate target of 55%, Europe remains off track to reach the Paris Agreement 1.5°C objective. Emission cuts of at least 65% are required for the EU to fully honor its international commitments.
VIK e.V. supports the European Commission’s plans for an improved emissions trading mechanism. However, it must be ensured that the planned reform of emissions trading does not lead to an increased risk of carbon leakage. A price corridor can accelerate the convergence of the two systems and thus provide planning certainty.
Filed in German · English published by the European Commission
Immediate social concerns and unclear climate benefits Environmental Action Germany (DUH) welcomes pricing in climate damage costs in the transport and building sectors, where emissions reductions are slow at best. We are concerned, however, that the introduction of a new emissions trading system is not the right instrument.
VIK welcomes the opportunity to participate in the consultation on the roadmap and inception impact assessment hydrogen and gas markets decarbonization package. VIK supports the goal of the Green Deal to change energy markets in a non-disruptive and cost-efficient manner. However, the industries concerned are exposed to international competition.
Deutsche Umwelthilfe / Environmental Action Germany welcomes the opportunity to comment on the initiative at this stage. This legislation is essential in leveling the playing field between natural gas, hydrogen, other gases and renewable electricity. Natural gas currently enjoys significant regulatory advantages. While green hydrogen, renewable electricity etc.
JOINT VIK/VCI OPINION Legislative proposals on hydrogen and gas market decarbonisation Key messages •VIK and VCI welcome the steps taken by the legislative initiative for the integration of low greenhouse gas pipeline gases into the internal market.
Filed in German · English published by the European Commission
Deutsche Umwelthilfe / Environmental Action Germany (DUH) welcomes the opportunity to consult on the gas market directive and regulation. In general, we are not pleased with the roles that low-carbon gases and green hydrogen are given with this reform. The broad allocation of hydrogen across many sectors is critical.
JOINT VIK/VCI OPINION Legislative proposals on hydrogen and gas market decarbonisation Key messages •VIK and VCI welcome the steps taken by the legislative initiative for the integration of low greenhouse gas pipeline gases into the internal market.
Filed in German · English published by the European Commission
Deutsche Umwelthilfe / Environmental Action Germany welcomes the opportunity to consult on the gas market directive and regulation. In general, we are not pleased with the roles that low-carbon gases and green hydrogen are given with this reform. The broad allocation of hydrogen across many sectors is critical.
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