The Commission's proposal for a Regulation establishing a framework for ensuring a secure and sustainable supply of critical raw materials (the CRMR) aims to ensure that the European Union has access to a secure and sustainable supply of Critical Raw Materials (CRMs) and Strategic Raw Materials (SRMs) for its digital and green transitions while ensuring a high level of environmental protection, circularity, and…
SOM
SOMO
NGO · Netherlands · EU Transparency Register 967160748894-22
5
positions filed
in the 665 files tracked
4
legislative files
of 665 tracked
4
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 (57,800 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 1107 non-governmental organisations on this site, they rank #314 by legislative files engaged, a count of participation, not a measure of influence.
0.8
declared lobbying FTE
self-declared
–
declared costs / yr (floor)
0
EP accreditations
as declared to the register
2023
in the register since
Declares membership of
- MVO-platform (CSR Platform NL)
Self-declared to the EU Transparency Register (snapshot 15 Oct 2026).
- Register category
- Non-governmental organisations
- Registered as
- Stichting Onderzoek Multinationale Ondernemingen (SOMO)
- Head office
- Amsterdam, Netherlands
Self-declared to the EU Transparency Register (snapshot 15 Oct 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
SOMO filed 5 positions between 6 Jun 2022 and 15 Sept 2025, across 4 of the 665 legislative files tracked here, attaching a full position paper 4 times.
2022 · 2 filed2023 · 2 filed2025 · 1 filed
What they argued
The proposal for a regulation amending Regulation (EU) 2021/1119 defines as its aim the contribution to the EUs path to climate neutrality. While we, the Centre for Research on Multinational Corporations (SOMO), welcome the Commissions effort to mitigate climate change, we are also very concerned with the proposed inclusion of carbon removals and offsets in the regulation.
SOMO appreciates the opportunity for providing feedback on the Commissions proposal for a new Union Customs Code. EU supply chains need to become much more transparent to effectively address the abuses they are fraught with. EU customs law reforms can substantially contribute to supply chain transparency.
Stichting Onderzoek Multinationale Ondernemingen Centre for Research on Multinational Corporations Reform of the Union customs legislation: SOMO submission for the call for evidence for an impact assessment The Centre for Research on Multinational Corporations (SOMO), is an action oriented non-profit research organisation based in Amsterdam, the Netherlands.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
As an expert research institution with more than 30 years of experience investigating the impacts of multinational companies, The Centre for Research on Multinational Corporations (SOMO) considers that there is, within the European Commission’s proposals, a fundamental misunderstanding about how ESG rating can contribute the objectives of the European Green Deal.
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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.
Showing 5 of 47.
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Everything on this page comes from SOMO’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.