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.
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)
TÜV-Verband represents the political and technical interests of the TÜV organizations, which together employ around 30,000 highly qualified professionals in the automotive sector and are active in approximately 70 countries worldwide. As independent, neutral, and sovereignly recognized technical services, the TÜV organizations and their experts have been instrumental in advancing vehicle and road safety since 1910.
VdTÜV (Association of Technical Inspection Agencies) advocates technical safety and trust in products, plants and services by independent testing in the European Union. Its international members are the TÜV organizations as well as industrial companies which are affiliated with the objectives and tasks of the association.
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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