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.
We would like to thank you for the opportunity to take a position in advance on the upcoming Regulation on Clean Company Vehicles. The association Baden-Württembergischer Omnibusunternehmen e.V. (WBO) represents, as an employers’ association, the interests of approximately 350 bus and coach undertakings in the federal state of Baden-Württemberg, under the umbrella of the Bdo Federation in Germany.
Filed in German · English published by the European Commission
Compared to other transport operators, shippers follow a different modus operandi within the supply chain which significantly depends on markets, products, production, and distribution networks. As a result, shippers have different expectations for road transport regarding volumes, distances, safety, and operational requirements.
Increasing the efficiency of the Internal Combustion Engine (ICE) has been the core driver of emissions reduction of passenger transport to date. In fact, average tailpipe CO2 emissions from petrol cars dropped by more than 30% between 2000 and 2016, largely due to increased performance of engines. At the same time, the fuel used in the car, also played an important part in making today’s cars cleaner.
We would ask you to consider these three points in the further procedure, in particular for coaches: Commercial vehicles are capital goods: Investment must be worthwhile to make it happen. On the one hand, the European Commission is seeking an end to internal combustion engines for heavy duty vehicles (still no date, 2037/2038?) and, on the other hand, bus manufacturers should invest in high-ambitious EURO VII…
Filed in German · English published by the European Commission
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