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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.

ZDK
Zentralverband Deutsches Kraftfahrzeuggewerbe

Industry association · Germany

2
files engaged
of 583 tracked
2
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
ACE
ACEA

Industry association · Belgium

46
files engaged
of 583 tracked
55
positions filed
in those 583 files
19.5
declared FTE
self-declared
11
EP accreditations
as declared to the register

Declared costs: €5.5M+ a year · in the register since 2008

Files both filed on (2)

Vehicle registration documents and vehicle registration data (Roadworthiness package) · Type-approval of motor vehicles and engines with respect to their emissions and battery durability (Euro 7)

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.

Vehicle registration documents and vehicle registration data (Roadworthiness package)

Zentralverband Deutsches Kraftfahrzeuggewerbe · filed 1 Nov 2021 · source

Deutsches Kraftfahrzeuggewerbe Zentralverband Position on the revision of the Roadworthiness Package Roadworthiness environment • The Roadworthiness Package must fit the related needs of the individual Member States to keep up functioning testing frameworks and to improve less effective testing frameworks.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ACEA · filed 25 Jul 2025 · source

The European Automobile Manufacturers' Association (ACEA) represents Europes 16 major Car, Van, Truck and Bus manufacturers. Technical defects on vehicles are related to less than 1% of fatalities, as a study from fka (RWTH Technical University Aachen) shows: https://www.acea.auto/news/less-than-1-of-accidents-caused-by-technical-defects-confirms-new-study/ Each potential measure should be evaluated with a…

Type-approval of motor vehicles and engines with respect to their emissions and battery durability (Euro 7)

ACEA · filed 26 May 2020 · source

The European Automobile Manufacturers' Association (ACEA) represents the 16 major Europe-based car, van, truck and bus makers. The activities of ACEA members sustain 13.8 million jobs for Europeans in the auto industry (directly and indirectly), accounting for 6.1% of all EU jobs.

Zentralverband Deutsches Kraftfahrzeuggewerbe · filed 9 Feb 2023 · source

The Central Association of German Motor Vehicle Industry (ZDK) in Bonn and Berlin represents the professional interests of 36.570 car houses and workshops with around 435.000 employees. With an annual turnover of EUR 179.8 billion, the motor vehicle industry is an important economic factor in Germany. The 36.570 establishments are organised in 236 guilds and 14 regional associations and 34 factories associations.

Filed in German · English published by the European Commission

ACEA · filed 9 Feb 2023 · source

The European manufacturers of cars, vans and heavy-duty vehicles (trucks, buses and coaches), represented by ACEA, are fully committed to providing the right vehicles to swiftly move Europes mobility and transport sector to climate neutrality and to minimise the impact of our sector on air pollution. ACEAs members support the aim to improve air quality in Europe.

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