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.
Company · Spain
Company · Germany
Declared costs: €100K+ a year · in the register since 2018
Medicinal products for human use · Evaluation of the Regulation on serious cross-border threats to health
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.
PHOENIX group · filed 3 Nov 2023 · source
To whom this may concern, Please find attached PHOENIX group contribution to the European Commissions public consultation on the Revision of the EU general pharmaceuticals legislation. PHOENIX group applauds the European Commission for reviewing and updating the outdated European pharmaceutical legislation for the benefit of European patients.
COFARES · filed 8 Nov 2023 · source
Positioning OF COFARES, S.L ANTE THE PROPOSALS FOR DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the Union code relating to medicinal products for human use and repealing Directive 2001/83/EC and Directive 2009/35/EC For the attention of the person concerned: Cofares, Sociedad Cooperativa Farmaceutica Española D.S.
Filed in Spanish · English published by the European Commission
PHOENIX group · filed 22 Jan 2024 · source
To whom this may concern, PHOENIX group welcomes the initiative of the European Commission to evaluate the early implementation period of the Serious Cross-Border Threats to Heath Regulation. In our capacity as the largest European integrated healthcare provider with 224 sites in the business areas of pharmaceutical wholesale and pre-wholesale across 29 European countries and with more than 3,200 pharmacies in 17…
COFARES · filed 12 Feb 2024 · source
In relation to the European Commission’s decision to assess the period of early application of the Regulation on serious cross-border threats to health, in accordance with its Article 33, COFARES, Spanish Pharmaceutical Cooperative (hereinafter ‘Cofares’), welcomes this initiative and has prepared this document with the aim of providing input and comments.
Filed in Spanish · English published by the European Commission
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