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.
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.
A FIT PHARMACEUTICAL LEGISLATION TO BENEFIT E.U. CITIZENS AND HEALTH SYSTEMS AESGP supports a pragmatic and risk-based regulatory framework that fosters a stronger role for self-care and prevention. The current structure is overall fit for purpose although some issues may arise from divergent interpretation, disharmonised application and addition of gold plating or administrative elements.
AESGP expresses support for the Commission Proposal to revise the EU general pharmaceutical legislation. We believe this long-awaited revision will consolidate and streamline legislation which underwent multiple updates over the past 20 years. While AESGP members acknowledge the legislation's goals, we raise concerns on unintended consequences for non-prescription medicines (NPMs).
The LIF welcomes the Commission’s initiative for a modernised regulatory framework for medicines that can be more easily adapted to technological and medical developments. The LIF considers that the Commission’s objective of creating more equal access to new medicines between EU Member States is important. On the other hand, the proposal contains several elements to which Lif has strong objections.
Filed in Swedish · English published by the European Commission
Replies to the EU Commission deadline 7 November 2023 Lif welcomes the Commission’s initiative for a modernised regulatory framework for medicines that can be more easily adapted to technological and medical developments. The LIF considers that the Commission’s objective of creating more equal access to new medicines between EU Member States is important.
Filed in Swedish · English published by the European Commission
Lif Sweden is the trade association for the research-based pharmaceutical industry in Sweden. Lif welcomes the opportunity to comment on the EU Commissions EMA fees proposal. The up-coming revision of the EU regulatory system is an opportunity to make the system faster, more efficient and flexible and thereby strengthen EU global competitiveness.
Please see below the AESGP comments on the European Commission proposal on updating the rules on fees payable to the European Medicines Agency. The detailed comments are provided in the attached document. The EMA is currently funded at 86% by fees, 13% by EU contribution and 1% by other sources.
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