t+m supports the Commissions objective of creating a harmonised framework for the registration and reporting of packaging producers across the EU. However, harmonisation should not simply mean introducing similar requirements in 27 different national systems. It should lead to a genuinely European approach that makes compliance simpler, more efficient and less burdensome for companies operating across borders.
GDT
Gesamtverband der deutschen Textil- und Modeindustrie e. V.
Industry association · Germany · EU Transparency Register 630565418685-37
16
positions filed
in the 665 files tracked
16
legislative files
of 665 tracked
15
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 1518 trade and business associations on this site, they rank #206 by legislative files engaged, a count of participation, not a measure of influence.
1
declared lobbying FTE
self-declared
€100K+
declared costs / yr (floor)
1
EP accreditations
as declared to the register
2015
in the register since
Declares membership of
- 1. Forschungskuratorium Textil e.V.
- 2. Bundesverband der Deutschen Industrie e.V.
- 3. Bundesvereinigung der Deutschen Arbeitgeberverbände e.V.
- 4. EURATEX European Apparel and Textile Confederation
- 5. Institut der deutschen Wirtschaft
- 6. DIN Deutsches Institut für Normung e.V.
- 7. IAF International Apparel Federation
- 8. Wittenberg-Zentrum für Globale Ethik e.V.
- 9. Forum für Zukunftsenergien e.V.
- 10. ifo Institut Leibniz-Institut für Wirtschaftsforschung an der Universität München e.V.
- 11. Deutscher Verband Nanotechnologie e. V.
- 12. Zentrale zur Bekämpfung unlauteren Wettbewerbs Frankfurt am Main e. V.
- and 10 more
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026).
- Register category
- Trade and business associations
- Registered as
- Confederation of the German Textile and Fashion Industry (textil+mode)
- Head office
- Berlin, Germany
- EU office
- Bruxelles
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
Gesamtverband der deutschen Textil- und Modeindustrie e. V. filed 16 positions between 17 Jan 2022 and 10 Sept 2026, across 16 of the 665 legislative files tracked here, attaching a full position paper 15 times.
2022 · 5 filed2023 · 1 filed2025 · 2 filed2026 · 8 filed
What they argued
Position Paper of the German Confederation of the Textile and Fashion Industry (textil+mode) on the European Commission Consultation on the Revised European Sustainability Reporting Standards (ESRS) Draft Delegated Regulation amending Commission Delegated Regulation (EU) 2023/2772 as regards the revision and simplification of the European Sustainability Reporting Standards (ESRS), Reference: Ares(2026)4623964…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
German textile & fashion industry companies, most of them SMEs, are committed to fair soc. & env. standards along supply chains, undertaking major efforts to expand knowledge & control. Their economic commitment & know-how transfer contribute much to sustainable growth & jobs in developing & emerging countries.
Germany’s medium-sized energy-intensive industry is facing a historically unprecedented crisis, leading not only to the outward movement of production, but also to plant closures and job losses. Energy-intensive small and medium-sized enterprises are committed to the European Union’s climate goals and want to follow this path by 2050.
Filed in German · English published by the European Commission
The CBAM (Carbon Border Adjustment Mechanism) is a completely new measure that has not yet been tested and is incomplete in its design. In its current form, it risks jeopardising the competitiveness of European industry and not providing effective protection against carbon leakage. A substantial improvement of the mechanism is urgently needed to achieve its objectives.
Filed in German · English published by the European Commission
The European Commission’s proposal for the revision of the Industrial Emissions Directive (IED) aims to contribute to achieving the objectives of the GREEN DEAL for a sustainable, climate-neutral EU-27 economy. The German textile industry, which is primarily a full-collar textile industry, is committed to sustainability and production-integrated environmental protection.
Filed in German · English published by the European Commission
The Confederation of the German Textile and Fashion Industry (t+m) welcomes the European Commissions commitment to reducing administrative burdens within environmental legislation. As a key industrial sector for Europes circular transition, the textile and fashion industry requires a coherent, practical, and economically viable regulatory framework to successfully deliver circularity in practice.
The proposed DPP registry introduces an additional centralized registration requirement alongside existing regulatory frameworks and registries, such as those within the context of Extended Producer Responsibility (EPR).
The textile industry is also at the forefront of the potential removal of plastic fibres in the oceans and of microplastics in the environment, in search of the sources of increasing plastic litter in the oceans and of microplastic particles in the environment. It puts many unsubstantiated claims into the space and ignores textiles as part of the solution using environmental and filtering techniques.
Filed in German · English published by the European Commission
Positionspapier zum Unionszollkodex EU-Transparenzregister: Nr. 630565418685-37 Revision des Unionszollkodex: Für einheitliche Verfahren, einheitliche IT und einen echten AEO Die deutsche Textil- und Modeindustrie ist eine stark globalisierte Branche. Unsere Unternehmen, die meisten von ihnen KMU, sind auf gut und verlässlich funktionierende und resiliente internationale Lieferketten angewiesen.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
In principle, the Federation of the German Textiles and Mode Industry welcomes the European Commission’s objective of revising Directive 2011/7/EU on combating late payment in commercial transactions. However, we would like to consider whether the individual amending measures (options) under consideration are suitable for this purpose.
Filed in German · English published by the European Commission
The EU’s main goal in the area of energy and climate policy is climate neutrality by 2050. The only instrument needed to achieve this objective is the EU Emissions Trading System (EU ETS), as it securely achieves a clearly defined climate target while being efficient.
Filed in German · English published by the European Commission
textil+mode (t+m), representing the German textile and fashion industry, welcomes the opportunity to contribute to the evaluation of the Biocidal Products Regulation (BPR). While supporting the BPRs objectives, we highlight key challenges for textile downstream users regarding predictability and transparency of regulatory processes, availability of approved active substances for critical applications (including…
The German association for the apparal and textile industry (t+m) welcomes the opportunity to provide feedback to the European Commission on the review of the Chemical Agents Directive (98/24/EC) (our opinion refers to diisocycate). As a downstream user industry, we have not closely followed the OEL process for diisocyanates so far, as the affectedness was not clear enough for our SME companies.
textil+mode supports the objective of protecting children from CMR 1A/1B substances in childcare products. Our comments therefore do not concern the objective of the proposal, but its practical implementation. As set out in the attached statement, the proposed restriction should be revised to ensure that it can be implemented by companies and enforced by authorities.
Textil+Mode (t+m), representing the German textile and fashion industry, welcomes the opportunity to comment on the proposed amendment to Regulation (EU) 2019/1021 on long-chain perfluorocarboxylic acids (C9C21 PFCAs), their salts and related compounds. We identify key issues regarding regulatory coherence, scope alignment with the Stockholm Convention and enforceability.
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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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Everything on this page comes from Gesamtverband der deutschen Textil- und Modeindustrie e. V.’s own submissions to the European Commission. We have added nothing and interpreted nothing. If something is wrong or out of date, email info@policyspeak.com and we will correct it. If you are an individual named in a record, our privacy policy sets out your rights to correction, objection and removal.
Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.