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.
Industry association · Portugal
NGO · Germany
Declared costs: not declared · in the register since 2008
Medicinal products for human use · Supplementary protection certificate for plant protection products. Recast
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.
APOGEN · filed 22 Apr 2021 · source
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…
Deutsche Sozialversicherung Europavertretung · filed 27 Apr 2021 · source
Health systems in the EU face the challenge of ensuring a high quality of affordable supply of medicines in the face of high prices. The German Social Insurance Agency therefore welcomes the EU’s intention to revise European pharmaceutical legislation.
Filed in German · English published by the European Commission
APOGEN · filed 2 Oct 2023 · source
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 · filed 2 Oct 2023 · source
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.
Deutsche Sozialversicherung Europavertretung · filed 2 Nov 2023 · source
The German Social Insurance Board (DSV) welcomes the Commission’s objectives of the reform proposals. They provide an opportunity to ensure equal access to medicines for patients in all Member States and to strengthen the security of supply of medicines as well as the adequacy of existing incentive schemes for drug development.
Filed in German · English published by the European Commission
Deutsche Sozialversicherung Europavertretung · filed 4 Apr 2022 · source
The European Commission is examining measures to optimise the existing system of Supplementary Protection Certificates (SPCs) in order to make it more transparent and efficient. SPCs are an intellectual property protection instrument that has the effect of extending the term of protection of a pharmaceutical patent by up to five years.
Filed in German · English published by the European Commission
APOGEN · filed 5 Apr 2022 · source
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…
Deutsche Sozialversicherung Europavertretung · filed 19 Sept 2023 · source
On April 27, 2023, the European Commission submitted proposals for the reform of intellectual property rights for medicinal products. Among other things, a unitary European supplementary protection certificate is to be established to complement the unitary European patent already introduced by Regulations (EU) No. 1257/2012 and (EU) No. 1260/2012 and due to start in 2023.
Deutsche Sozialversicherung Europavertretung · filed 19 Sept 2023 · source
On April 27, 2023, the European Commission submitted proposals for the reform of intellectual property rights for medicinal products. Among other things, a unitary European supplementary protection certificate is to be established to complement the unitary European patent already introduced by Regulations (EU) No. 1257/2012 and (EU) No. 1260/2012 and due to start in 2023.
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