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.
Trustworthy information about the status and utilisation of forests, such as the recent MAES report by JRC , are key for responsible decision making. Without the existence of good quality, consistent and available data, policy and financial decision makers cannot make informed decisions. However, the current datasets are far from being consistent.
The EUs forests are increasingly under pressure even though the area covered by forests is increasing. The current definition of forest can be misleading, as it can include land that is used, or has recently been used for agriculture, as well as monoculture non-native plantations and even tree-less areas (i.e., clearcuts where forest regeneration is planned).
The EUTR was a good step into the right direction, but there are at least three elements, which require further improvement (a) the annex of the legislation must be all inclusive to cover all forest related products. This is going to be even more relevant if the EU pushes the implementation of the BioEconomy strategy further.
BirdLife Europe echoes calls for the EUTR fitness check to assess the legislation in light of its environmental goals and legal basis (Art. 192 TFEU), and in terms of its contribution to the EU’s forest protection objectives.
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