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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.

MDS
Médecins Sans Frontières

NGO · Switzerland

3
files engaged
of 583 tracked
3
positions filed
in those 583 files
3
declared FTE
self-declared
2
EP accreditations
as declared to the register

Declared costs: not declared · in the register since 2017

ME
Medicines for Europe

Industry association · Belgium

15
files engaged
of 583 tracked
22
positions filed
in those 583 files
7.9
declared FTE
self-declared
10
EP accreditations
as declared to the register

Declared costs: €500K+ a year · in the register since 2009

Files both filed on (3)

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.

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

Medicines for Europe · filed 22 Apr 2021 · source

Medicines for Europe represents manufacturers of off-patent medicines supplying close to 70% of dispensed prescription medicines in Europe. 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 generic/biosimilar medicines.

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.

Medicines for Europe · filed 29 Sept 2023 · source

Medicines for Europe, representing manufacturers of generic, biosimilar and value added medicines across Europe, welcomes the proposals to review the EU general pharmaceutical legislation. As the off-patent sector accounting for 70% of medicines dispensed in Europe covering 80% of therapeutic areas, we fully share the goals of ensuring that all patients across the EU have timely and equitable access to safe…

Medicines for Europe · filed 29 Sept 2023 · source

Medicines for Europe, representing manufacturers of generic, biosimilar and value added medicines across Europe, welcomes the proposals to review the EU general pharmaceutical legislation. As the off-patent sector accounting for 70% of medicines dispensed in Europe across 80% of therapeutic areas, we fully share the goals of ensuring that all patients in the EU have timely and equitable access to safe, effective and…

Compulsory licensing of patents in crisis situations

Medicines for Europe · filed 27 Apr 2022 · source

Medicines for Europe welcomes the chance to provide feedback on the proposal to review the compulsory licensing system in Europe. Medicines for Europe is strongly convinced that voluntary licensing agreements are the right way forward to tackle health crises.

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.

Medicines for Europe · filed 28 Jul 2023 · source

Medicines for Europe welcomes the opportunity to provide valuable feedback on the EC proposal to review the compulsory licensing system in Europe. At Medicines for Europe, we firmly maintain that voluntary licensing agreements present the most effective approach to tackle health crises.

Supplementary protection certificate for plant protection products. Recast

Medicines for Europe · filed 4 Apr 2022 · source

Medicines for Europe 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…

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).

Medicines for Europe · filed 18 Sept 2023 · source

Medicines for Europe is glad to be able to provide its feedback and emphasizes the need for safeguards to ensure high quality SPCs, prevent litigation strategies and ensure access to affordable medicines. First, SPC holders should be able to obtain a SPC protection so to enjoy an overall maximum of 14 years of exclusivity from the marketing authorisation.

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