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.
Industry association · Germany
Industry association · Belgium
Declared costs: €800K+ a year · in the register since 2011
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.
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.
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)
CLEPA · filed 28 Jul 2025 · source
Feedback to COM(2025)180 concerning amendments to Directive 2014/45/EU on periodic roadworthiness tests. CLEPA recommends opting for a Regulation instead of a Directive to secure a harmonised legal framework across the EU is effectively and consistently applied, to reduce operating costs for all operators and users, as well as preserve consistency of test parameters and equipment to those used in type-approval.
CLEPA · filed 13 May 2020 · source
CLEPA represents over 3.000 companies supplying state-of-the-art components and innovative technology for safe, smart and sustainable mobility, investing over 25 billion euros yearly in research and development. Automotive suppliers in Europe employ overall nearly five million people across the continent.
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
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