Side by side
Consultation participation and their own register declarations, side by side. Counts, not judgments — participation is not influence.
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.
NGO · Ireland
Industry association · Belgium
Declared costs: €6M+ a year · in the register since 2009
Medicinal products for human use · Compulsory licensing of patents in crisis situations
Register facts self-declared (snapshot 2 Sept 2026); cost bands are floors. Shared files are shared attention, not evidence of coordination.
Their opening passages on the files they share, verbatim and in filing order. We do not summarize, compare, or characterize positions — read them at source.
Access to Medicines Ireland · filed 26 Apr 2021 · source
Access to Medicines Ireland (AMI) welcomes the opportunity to contribute to the revision of the general pharmaceutical legislation. We have comments, and recommendations in the following areas: Unmet Need 1. Towards a definition of ‘unmet need’, we recommend developing a fair, equitable and transparent decision-making process for what is an ‘unmet need’. 2.
EFPIA · filed 27 Apr 2021 · source
EFPIA supports an agile regulatory framework and a strong incentives’ system that embrace and encourage advances in science, technology & medicines. This evaluation is an opportunity to implement learnings from COVID-19 and ensure a competitive, world-class regulatory system in Europe supporting a globally competitive research-based industry at a critical time.
EFPIA · filed 3 Oct 2023 · source
EFPIA supports the objectives of enhancing the availability and accessibility of medicines, while fostering a competitive innovation environment in Europe. We welcome the proposal to future-proof the EU regulatory framework, maximising the use of expedited pathways, optimising regulatory decision-making processes, and reducing unnecessary administrative burdens.
EFPIA · filed 9 Oct 2023 · source
EFPIA supports the objectives of enhancing the availability and accessibility of medicines, while fostering a competitive innovation environment in Europe. We welcome the proposal to future-proof the EU regulatory framework, maximising the use of expedited pathways, optimising regulatory decision-making processes, and reducing unnecessary administrative burdens.
EFPIA · filed 28 Apr 2022 · source
The substantial investment in R&D by multiple actors over many years into novel technologies, vaccine, therapeutic and other products now available to address Covid-19 would not have occurred without the robust IP system in the EU and elsewhere. IP protections, particularly patents, has provided the legal framework and incentive for the high risk, high-cost investment underpinning the response to the pandemic.
Access to Medicines Ireland · filed 29 Apr 2022 · source
Compulsory Licensing in the EU: Call for Evidence Submission by Access to Medicines Ireland (AMI) 29 April 2022 [max 4000 characters] AMI is a voluntary membership group of Cómhlamh, and we welcome the opportunity to provide feedback on the EU’s proposal to review the compulsory licensing in Europe.
EFPIA · filed 28 Jul 2023 · source
In its Compulsory Licensing (CL) proposal, the European Commission (EC) posits a new EU-wide CL for crisis response. This harms IP rights and is a dramatic expansion of the ECs role into Member State (MS) remit, where viable CL provisions already exist. CLs are a last resort, all attempts at voluntary licensing having failed.
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