Article / Provision: P.2 (4) & Others Unique Identifiers Proposed Amendment / Comment: The regulation should clearly state that any unique identifier design is permitted as long as it complies with international standards, such as ISO/IEC or GS1 Digital Link, and ensures interoperability.
RE
Ricoh Europe
Industry association · Netherlands
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.
2
positions filed
in the 655 files tracked
2
legislative files
of 655 tracked
1
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 655 consultation files tracked so far (56,999 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
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Their record over time
Ricoh Europe filed 2 positions between 27 May 2026 and 15 Sept 2026, across 2 of the 655 legislative files tracked here, attaching a full position paper 1 time.
What they argued
Dear European Commission, Please find attached Ricohs feedback on the proposed BEU09 entry, focusing on manufacturer-managed closed-loop programmes and the treatment of printer cartridges. Thank you for considering our feedback. Yours sincerely, Ricoh Europe
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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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