Industry association · Netherlands · EU Transparency Register 358492746482-66
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.
Among the 1518 trade and business associations on this site, they rank #673 by legislative files engaged, a count of participation, not a measure of influence.
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026).
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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RECS Energy Certificate Association filed 5 positions between 21 Mar 2022 and 3 Jun 2026, across 5 of the 665 legislative files tracked here, attaching a full position paper 3 times.
RECS welcomes the opportunity to provide feedback on the proposed amendments to Delegated Regulation (EU) 2023/2772 concerning the simplification of the European Sustainability Reporting Standards (ESRS). Please find our detailed comments below.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
We call on the Commission to: -Ensure coherence and alignment across EU legislation related to renewable energy markets, guarantees of origin and renewable PPAs, and carbon accounting rules; -Adopt Full Consumption Disclosure (FCD) as a central element of the post-2030 framework to ensure a level playing field and strengthen demand for renewable energy; -Support the modernisation and harmonisation of renewable…
Regarding (5): In Europe, claims about renewable energy (RE) use must be proven with Guarantees of Origin (GOs) (RED Art. 19). The use of Energy Attribute Certificates (EACs) from other countries that are equivalent to the European GOs should be allowed if relevant legislation mandates and actively ensures these as a unique instrument for tracking.
RECS appreciates the opportunity to provide feedback on the draft delegated regulation supplementing Directive (EU) 2023/1791 and amending Delegated Regulation (EU) 2024/1364 as regards the establishment of a common Union rating scheme for data centres. Key recommendations: -Data centres should be required to demonstrate 100% renewable electricity procurement, matched by calendar year (or month).
This is an expert opinion of the RECS Secretariat based on its experience of representing the users of GOs. It may not reflect the opinion of all members, but has been approved by the organisation's board. RECS appreciates the focus on empowering consumers through facilitating transparency regarding the origin of gases they consume.
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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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