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EU consultation

Revision of the EU legislation on medicines for children and rare diseases

95 submissions from 95 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.

The Commission lists 416 submissions on this file. Shown here: the 95 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.

Who showed up

52 submissions from industry — companies and their trade associations — against 26 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 2 industry submissions for every one from civil society.

Industry 52Civil society 26Public authorities, academia, other 17

Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.

What the room declares

45 of 95
in the EU Register
161
full-time lobbying staff
€35.5M+
declared costs a year
153
EP accreditations declared

Self-declared to the EU Transparency Register (snapshot 2 Sept 2026). The cost figure sums band floors, so the true total is higher.

The file, right now

The consultation closed on 30 Jul 2021 — it ran from 7 May 2021.

Policy area
Health & food (DG SANTE)
Where it stands
Awaiting adoption
Adoption expected
31 Mar 2023

How it got here

  1. Impact assess incep6 Jan 2021
  2. Public consultation30 Jul 2021

Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned, Proposal for a regulation.

Showing 25 of 95 submissions.

I

IFSASALUD

· · filed 6 Jan 2021 · source

The right to access to medicines requires the implementation of complex mechanisms with the intervention of various actors, among which public institutions prevail as guarantors of collective health. The role of the administrations around access to medicines cannot be limited to a passive position and that far from being exhausted with the material delivery of the medicine to those who need it, it imports a series…

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HT

Horizon Therapeutics plc

· · filed 6 Jan 2021 · source

Horizon Therapeutics plc (Horizon) appreciates this opportunity to comment on the European Commission’s (EC) initiative to revise the Orphan and Paediatric Regulations. Horizon is a biopharmaceutical company focused on researching, developing and commercialising medicines that address critical needs for people impacted by rare and rheumatic diseases.

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US

U.S. Chamber of Commerce

· · filed 6 Jan 2021 · source

PDF

The U.S. Chamber of Commerce (“Chamber”) Global Innovation Policy Center (GIPC) appreciates the opportunity to respond to this European Commission (“Commission”) Inception Impact Assessment on intellectual property (IP) incentives, which complements the Chamber’s ongoing support for the Commission’s work to remove trade barriers and to protect IP in the European Union (EU) and internationally . The U.S.

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CA

CVBF as EPTRI Coordinator

· · filed 6 Jan 2021 · source

PDF

EPTRI, the European Paediatric Translational Research Infrastructure, is an initiative aimed to accelerate and expand the paediatric drug discovery and development processes by focusing on basic, preclinical, and translational research methods, services and technologies, curried on in collaboration between 112 research Institutions which have signed the EPTRI Memorandum of Understanding by October 2020.

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ER

European Respiratory Society

· · filed 6 Jan 2021 · source

The European respiratory Society (ERS) is an international organisation that brings together physicians, healthcare professionals, scientists and other experts working in respiratory medicine. It is one of the leading medical organisations in the respiratory field, with a growing membership representing over 160 countries worldwide.

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A

Amgen

· · filed 6 Jan 2021 · source

We welcome the opportunity to provide comments on the European Commission’s initial impact assessment on Regulations for medicines for children and rare diseases (RD). Amgen discovers, develops, manufactures, and delivers innovative human therapeutics. A biotechnology pioneer since 1980, Amgen was one of the first companies to realize the new science’s promise.

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IP

Ipsen Pharma

· · filed 6 Jan 2021 · source

As a global specialty-driven biopharmaceutical company committed to discovering new solutions for debilitating rare and ultra-rare diseases and improving quality of life for patients suffering from these diseases, Ipsen welcomes the opportunity to comment on the inception impact assessment.

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ER

EURORDIS Rare Diseases Europe

· · filed 6 Jan 2021 · source

PDF

EURORDIS Rare Diseases Europe welcomes the opportunity to provide feedback to the European Commission Inception Impact Assessment (IIA) on Paediatric Medicines and Orphan Medicinal Products. EURORDIS is of the opinion that moving forward, any future improvements to the Regulation on Orphan Medicinal Products and Paediatric Medicines are to reinforce the EU processes in a structured and seamless way for all rare…

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TE

TEDDY – European Network of Excellence for Paediatric Research

· · filed 6 Jan 2021 · source

PDF

After discussing the European Commission’s Inception Impact Assessment, we support the implementation of joint solutions to harmonise and optimise procedures, incentives and rewards addressed to paediatric and orphan medicinal products.

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FO

Forum of International Research and Development Pharmaceutical Companies, EIG

· · filed 6 Jan 2021 · source

In Forum, the Slovenian innovative pharmaceutical association, which represents 22 global research companies, we are aware, that to date, the Paediatric and Orphan Regulations have provided immense benefits for children and patients with rare diseases (RD) in Slovenia. We would welcome Commission’s effort to maintain the legislative framework which would ensure possibilities to treat DS also in the future.

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AE

AmCham EU

· · filed 6 Jan 2021 · source

PDF

Representing American companies operating in the EU, AmCham EU is well aware of the differences and respective strengths of innovation ecosystems on both sides of the Atlantic. The options laid out in the inception impact assessment (IIA) risk undermining an EU framework that has proven largely successful, rather than preserving the EU’s strengths and incorporating learnings from other regions.

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AO

Association of Innovative Pharmaceutical Manufacturers

· · filed 6 Jan 2021 · source

Insufficient development in areas of greatest unmet medical needs for patients: the development of medicines is not covering all major therapeutic areas. In the area of medicines for rare diseases, the evaluation found that 95% of rare diseases still have no treatment option. Unmet Medical Need (UMN) definition and criteria need to be well established and monitored.

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FH

F. Hoffmann-La Roche Ltd

· · filed 6 Jan 2021 · source

PDF

Roche is committed to support the improvement of the regulatory environment in Europe and welcomes the opportunity to contribute to the revision of the pediatric and rare diseases legislation. We believe that the revision should not only address current bottlenecks but more importantly, and in line with the Pharma strategy, should make the legislation future-proof and consider also future treatment options and…

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E

EuropaBio

· · filed 6 Jan 2021 · source

Developing medicines for children and rare diseases is a lengthy and complex undertaking. Much less is known about these illnesses when compared to more common conditions, meaning extensive research is required before scientists and researchers can seek to transform their ideas into potential treatments.

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H

HollandBIO

· · filed 6 Jan 2021 · source

PDF

HollandBIO, the Dutch biotech industry association, appreciates the opportunity to provide feedback on the inception impact assessment on the revision of the EU legislation on medicines for children and rare diseases. We endorse the four objectives for the revision of the two Regulations. We acknowledge there is room to improve and strengthen the effectiveness of the legislation.

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TP

Teva Pharmaceuticals

· · filed 6 Jan 2021 · source

PDF

Teva is a strategic partner of European healthcare systems. Teva is committed to researching and developing new therapeutic options for unmet medical needs and improving affordable and equitable access to quality medicines.

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TA

The Association of Innovative Pharmaceutical Industry

· · filed 6 Jan 2021 · source

The Association of Innovative Pharmaceutical Industry (AIFP) shares the EFPIA´s view expressed in its input into this Inception Impact Assessment. Further to this we would like to stress some of our main concerns and observations.

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A

Alexion

· · filed 6 Jan 2021 · source

Alexion is on a mission to transform the lives of people with rare disease and devastating conditions through the research and development of innovative medicines. Thanks to our commitment and sustained investments patients suffering from rare and ultra-rare conditions such as Paroxysmal Nocturnal Hemoglobinuria (PNH), atypical Hemolytic Uremic Syndrome (aHUS), generalized Myasthenia Gravis (gMG), Neuromyelitis…

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JJ

Johnson & Johnson

· · filed 6 Jan 2021 · source

The Orphan and Paediatric Regulations have spearheaded a wave of innovations in underserved areas. They have undeniably delivered on their objectives considering the marginal economic case for developing most of these medicines; but more must be done. We welcome the opportunity to discuss how to improve them so they better address unmet needs, unintended effects and are more future proof.

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DM

Dutch Ministry of Public Health, Welfare and Sport

· · filed 6 Jan 2021 · source

PDF

On behalf of the Ministry of Public Health, Welfare and Sport, please find attached a file containing the following: (1) Joint feedback from the Netherlands and Belgium on the inception impact assessment for the revision of the legislation for orphan and paediatric medicinal products; (2) Feedback from the Netherlands on the inception impact assessment for the revision of the legislation for orphan and paediatric…

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U

UCB

· · filed 6 Jan 2021 · source

UCB is dedicated to finding unique solutions for diseases with high degree of patient need. Regardless of the population size, it’s patients’ needs that direct our efforts. Our ambition for patients relies on our ability to innovate & bring differentiated solutions with unique outcomes that help specific patients achieve their goals.

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PR

Pharmaceutical Research and Manufacturers of America (PhRMA)

· · filed 6 Jan 2021 · source

PDF

PhRMA member companies share the goal of ensuring that patients with unmet medical needs in Europe have timely access to the latest cutting-edge treatments and cures. It’s been proven that innovative medicines help extend lives, lower hospital and overall health care costs and improve the financial sustainability of health systems.

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RF

REIF - French social security institutions

· · filed 6 Jan 2021 · source

The French representation of social security institutions in Brussels (REIF) welcomes the launch of the revision process of the regulations on medicines for children and rare diseases by the European Commission. REIF especially acknowledges the consideration given to a potential major overhaul of current mechanisms (Option 4 in particular).

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LE

Les Entreprises du Médicament - LEEM

· · filed 6 Jan 2021 · source

The LEEM and its 260 members are fully mobilised in the light of the objectives identified in the IIA. Any revision of incentives should be designed to maintain a Europe of innovation (one of the challenges of the Commission’s Pharmaceutical Strategy), but the proposed options do not allow this to be achieved.

Filed in French · English published by the European Commission

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PP

Plasma Protein Therapeutics Association (PPTA)

· · filed 6 Jan 2021 · source

The Plasma Protein Therapeutics Association (PPTA) promotes the availability of, and access to, safe and effective plasma-derived medicinal products (PDMPs) which treat a variety of rare, chronic, and potentially life-threatening conditions. 300,000 European patients rely on these essential medicines, without which they might not survive or would have a substantially diminished quality of life.

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Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.