GIFAS (the French aerospace sector) contribution: In line with Afep-MEDEF and EU association ASD responses. Main points : Fair presentation: several changes to the text bringing improvements (new §21 AR4 & 6) but this is a new concept whose implications for auditing are not clear and could contradict the simplifications objective. So we are opposed to the introduction of this concept.
GFA
GIFAS (French Aerospace Industries)
Industry association · France
2
positions filed
in the 657 files tracked
2
legislative files
of 657 tracked
2
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 657 consultation files tracked so far (57,479 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
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Their record over time
GIFAS (French Aerospace Industries) filed 2 positions between 3 Jun 2026 and 27 Jul 2026, across 2 of the 657 legislative files tracked here, attaching a full position paper 2 times.
What they argued
Critical raw materials (CRM) are of strategic importance for the Aeronautical, Space and Defence sectors, given their essential role in ensuring the security of supply, competitiveness, technological leadership and resilience of industrial value chains. In this context, GIFAS is closely following the European Commissions initiative to establish an EU Critical Raw Materials Centre.
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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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