ECRE does not support the measures proposed, which will have an adverse effect on the right to asylum without adequately responding to the situation at the EU’s borders with Belarus. The main fundamental rights affected by the proposal are the right to human dignity (Article 1 EU Charter of Fundamental Rights (CFREU)), the right to asylum (Article 18 CFREU), the prohibition of torture and inhuman or degrading…
ECRE
NGO · Belgium
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.
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Their record over time
ECRE filed 2 positions between 11 Mar 2021 and 1 Feb 2022, across 2 of the 583 legislative files tracked here, attaching a full position paper 2 times.
What they argued
Like Dublin IV before it, the overall approach of the Regulation on asylum and migration management (RAMM) to responsibility allocation is to maintain the status quo but add “corrective” solidarity mechanisms intended to compensate for the outcomes of the standard rules and make them fairer. A deeper overhaul of the criteria on sharing of responsibility is vital to address the system’s dysfunctionalities.
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers — not evidence of coordination, and we do not suggest any.
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