APOGEN welcomes the reform of the mandate of the European Centre for Disease Control (ECDC) especially in light of its response to the first wave of the COVID-19 pandemic in Europe when it struggled to collect data from member states and to provide forecasts of the progression of the virus.
AAO
APOGEN - Associação Portuguesa de Medicamentos Genéricos e Biossimilares
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.
3
positions filed
in the 583 files tracked
3
legislative files
of 583 tracked
0
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 - Associação Portuguesa de Medicamentos Genéricos e Biossimilares filed 3 positions on 2 Feb 2021, across 3 of the 583 legislative files tracked here.
What they argued
APOGEN, taking into account to the lessons learned from COVID-19 crisis, believes that the proposal on management and mitigation of medicines shortages should be improved for better outcomes of the collaboration between the manufacturers and National and European medicines agencies to improve the supply of medicines to patients and to ensure EU solidarity.
Taking the lessons learned from COVID-19, APOGEN has two main reflection points on the proposal: 1. We highlight the important challenges of using joint procurement (JP) for generic multisource medicines. The joint procurement of ICU medicines during the pandemic was not an efficient way to secure medicines supply.
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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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