Regulation (EU) 2021/821 establishes an important framework for controlling dual-use exports, including certain non-listed cyber-surveillance items posing serious human-rights risks. Article 5 and Commission Recommendation (EU) 2024/2659 provide a legal and operational foundation. The evaluation should assess whether risk evidence is clear, consistent and reviewable across exporters and Member State authorities.
IR
Individual Researcher
Other · CHN
not in the EU Transparency RegisterThis organization files on consultations without a register number, so its record here is built from its filings alone. Register facts (staff, costs, accreditations) are not available for it.
3
positions filed
in the 687 files tracked
3
legislative files
of 687 tracked
2
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 687 consultation files tracked so far (60,344 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
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Their record over time
Individual Researcher filed 3 positions between 15 Oct 2026 and 21 Oct 2026, across 3 of the 687 legislative files tracked here, attaching a full position paper 2 times.
What they argued
Article 7 allows a qualified entity to transfer its accreditation when the original national competent authority ceases to use it for reasons unrelated to Article 6(3). This preserves recognition under Article 69(4) of Regulation (EU) 2018/1139. Yet continuity of accreditation does not ensure continuity of supervisory decisions.
A reduction in projected ammonia emissions between two national air pollution control programmes (NAPCPs) may reflect greater uptake of low-emission manure spreading, revised agricultural activity data, a different emission factor, or the reclassification of a measure from the with-additional-measures (WAM) scenario to the with-measures (WM) scenario.
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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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