APOGEN, Portuguese Generic and Biosimilar Medicines Association represents the companies of generic and biosimilar medicines in Portugal, welcomes the proposals to review the EU general pharmaceutical legislation.
APO
APOGEN
Industry association · Portugal · EU Transparency Register 628796439608-51not in register snapshot
This register number is the organization’s own declaration on its submission. It is not in the 2 Sept 2026 snapshot of the EU Transparency Register, so we neither link to it nor use it to identify this organization.
4
positions filed
in the 583 files tracked
2
legislative files
of 583 tracked
4
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 583 consultation files tracked so far (42,224 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
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Their record over time
APOGEN filed 4 positions between 22 Apr 2021 and 2 Oct 2023, across 2 of the 583 legislative files tracked here, attaching a full position paper 4 times.
2021 · 1 filed2022 · 1 filed2023 · 2 filed
What they argued
APOGEN, Portuguese Generic and Biosimilar Medicines Association represents the companies of generic and biosimilar medicines in Portugal, welcomes the proposals to review the EU general pharmaceutical legislation.
APOGEN represents manufacturers of off-patent medicines supplying 63% in retail market and 76% in hospitals of dispensed prescription medicines in Portugal. The pharmaceutical legislation should foster access to follow-on off-patent medicines on day-1 after IP expiry by extending the scope and harmonising the Bolar exemption to cover API supply and all administrative steps needed to effectively launch…
APOGEN welcomes the chance to provide feedback on the proposal to reduce fragmentation in the SPC system. The Call for Evidence (CfE) makes almost no reference to a need to tackle fragmentation in enforcement/litigation phase of SPC lifecycles, arguably the highest priority for ensuring timely patient access to generic/biosimilar medicines, legal certainty & address national budget issues, ignoring the core problem…
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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 21.
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