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 · Switzerland
Declared costs: not declared · in the register since 2017
Industry association · Spain
Declared costs: €100K+ a year · in the register since 2015
Medicinal products for human use · Compulsory licensing of patents in crisis situations · 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.
Médecins Sans Frontières · filed 27 Apr 2021 · source
Médecins Sans Frontières (MSF) welcomes the European Commission’s ambition to ensure access to affordable medical tools. Beyond evaluating and revising the pharmaceuticals legislation, the Commission should take a comprehensive approach to revising the EU’s intellectual property (IP) and research and development (R&D) legislation and policies to meet this ambition.
Farmaindustria · filed 27 Apr 2021 · source
Farmaindustria considers it crucial to preserve the stability and predictability of the current European framework of incentives to attract investment and enable the pharmaceutical industry to continue to innovate in Europe, achieving better health outcomes.
Filed in Spanish · English published by the European Commission
Farmaindustria · filed 6 Nov 2023 · source
Farmaindustria (FI) supports the ultimate objective of the EC Proposal to improve the availability and access to medicines by promoting an innovative and competitive environment in the EU. We welcome the intention to prepare a regulatory framework for the future, maximising the use of fast-track procedures, optimising regulatory decision-making processes and reducing unnecessary red tape.
Filed in Spanish · English published by the European Commission
Médecins Sans Frontières · filed 29 Apr 2022 · source
Médecins Sans Frontières/Doctors Without Borders (MSF) welcomes the European Commission (EC)’s ambition to improve compulsory licensing (CL) in the EU. The Agreement on Trade Related Aspects of Intellectual Property Rights (TRIPS Agreement) and the Doha Declaration recognise that WTO members are free to determine the grounds on which to issue a CL.
Farmaindustria · filed 28 Jul 2023 · source
The EC proposal on the granting of compulsory licences (LO) is of great concern to FARMAINDUSTRIA by providing for the suspension of IP rights and preventing the choice of partners to voluntarily grant manufacturing licences for their products without any legal basis being observed to limit the use of this measure.
Filed in Spanish · English published by the European Commission
Farmaindustria · filed 26 Mar 2022 · source
Making new therapies available to patients is a long, complex and risky process that requires considerable investment, giving industrial protection — and the period for which it is effective — a key role in embarking on this process.
Filed in Spanish · English published by the European Commission
Médecins Sans Frontières · filed 5 Apr 2022 · source
Médecins Sans Frontières (MSF) recently published research in a peer-reviewed journal (attached) on supplementary protection certificates and their impact on access to medicines in Europe.1 The study examines sales revenue of and R&D investments in a number of lifesaving medicines (sofosbuvir, trastuzumab, and imatinib).
Farmaindustria · filed 18 Sept 2023 · source
Farmaindustria, as the representative of the innovative pharmaceutical industry established in Spain, welcomes the proposed revision of the SPC Regulation of, given its objective of creating a harmonised and centralised approach to the application, evaluation and granting of SPC for both classical European and unitary patents (UPs), providing a clearer and more efficient framework for industrial property in the EU…
Filed in Spanish · English published by the European Commission
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