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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.

NMA
Norwegian Medicines Agency

Public authority · Norway

3
files engaged
of 583 tracked
3
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 · Standards of quality and safety for substances of human origin intended for human application

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

Norwegian Medicines Agency · filed 27 Apr 2021 · source

The proposed impact assessment will form a good foundation for revision of the general pharmaceutical legislation. We would however emphasise the importance of devoting sufficient attention to the proper functioning of the legislation regarding off-patent medicinal products. There are substantial differences in access, affordability, sustainability and security of supply for off patented and patented medicines.

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…

Standards of quality and safety for substances of human origin intended for human application

Norwegian Medicines Agency · filed 14 Dec 2020 · source

Comments from the Norwegian Medicines Agency on the Inception Impact Assessment for the revision of the Union legislation on blood, tissues and cells The Norwegian Medicines Agency (NOMA) welcomes the possibility to comment on the Commission’s Inception Impact Assessment for the revision of the blood, cell and tissue (BTC) legislation. NOMA acknowledges the need for revision of the BTC legislation.

European Confederation of Pharmaceutical Entrepreneurs (EUCOPE) · filed 14 Dec 2020 · source

EUCOPE, the voice of small to mid-sized innovative companies active in the field of pharmaceuticals, bio- and medical technologies at the European level, shares the Commission’s views that the Blood Directive 2002/98/EC and the Tissues and Cells Directive 2004/23/EC (the BTC legislation) does not provide adequate measures for self-sufficient supplies of blood, tissues and cells and that divergent approaches at…

European Confederation of Pharmaceutical Entrepreneurs (EUCOPE) · filed 7 Sept 2022 · source

EUCOPE welcomes the proposal for a Regulation on standards of quality and safety for substances of human origin intended for human application. We welcome the transition of the BTC Directives into one Regulation which will increase regulatory predictability and harmonization. We welcome the continued regulatory delineation between BTCs and pharmaceutical products to increase regulatory predictability.

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