Skip to main content
PolicySpeak
← The ranking

Side by side

Compare organizations

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.

APO
APOGEN

Industry association · Portugal

2
files engaged
of 583 tracked
4
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
16
files engaged
of 583 tracked
24
positions filed
in those 583 files
4.4
declared FTE
self-declared
10
EP accreditations
as declared to the register

Declared costs: €800K+ a year · in the register since 2009

Files both filed on (2)

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.

What each said, in their own words

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.

Medicinal products for human use

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…

European Confederation of Pharmaceutical Entrepreneurs (EUCOPE) · filed 27 Apr 2021 · source

EUCOPE is the voice of small to midsize innovative companies active in the field of pharmaceuticals and medical technologies at the European level. The COVID-19 pandemic has again made the vital importance of the European pharmaceutical sector apparent, and while regulatory simplification is welcomed, broader business incentives should also be considered to address the EU’s competitiveness.

European Confederation of Pharmaceutical Entrepreneurs (EUCOPE) · filed 5 Sept 2023 · source

EUCOPE acknowledges the objectives of the Pharmaceutical Package, and welcomes maintaining a separate Directive and Regulation for decentralized and central approval processes. While we appreciate streamlining and digitisation of regulatory procedures, we are concerned that other proposed provisions will undermine R&D, innovation, EU competitiveness, and be particularly detrimental for patients and small and…

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.

Supplementary protection certificate for plant protection products. Recast

European Confederation of Pharmaceutical Entrepreneurs (EUCOPE) · filed 4 Apr 2022 · source

The European Confederation of Pharmaceutical Entrepreneurs (EUCOPE) is the European trade association for small to mid-sized innovative companies active in the field of pharmaceuticals and medical technologies at the European level.

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…

European Confederation of Pharmaceutical Entrepreneurs (EUCOPE) · filed 28 Jul 2023 · source

The European Confederation of Pharmaceutical Entrepreneurs (EUCOPE) is the European trade association for small to mid-sized innovative companies active in the field of pharmaceuticals and medical technologies at the European level.

Take this comparison with you

2 organizations on one sheet: every file each filed on, their register declarations, and a working link to each submission. Free: we ask for your name and email, and PolicySpeak may contact you about the product (privacy policy). The per-file record stays downloadable without signing up on each file’s page.