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.
Industry association · United States
Industry association · Belgium
Declared costs: €6M+ a year · in the register since 2009
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.
EFPIA · filed 28 Apr 2022 · source
The substantial investment in R&D by multiple actors over many years into novel technologies, vaccine, therapeutic and other products now available to address Covid-19 would not have occurred without the robust IP system in the EU and elsewhere. IP protections, particularly patents, has provided the legal framework and incentive for the high risk, high-cost investment underpinning the response to the pandemic.
Pharmaceutical Research and Manufacturers of America · filed 29 Apr 2022 · source
PhRMA, and the innovative biopharmaceutical companies that it represents, has serious concerns with the call for legislative action regarding compulsory licensing in the EU and its Member States. While the call for evidence recognizes that compulsory licensing should be a tool of last resort, it suggests that there is a need for a central compulsory licensing mechanism in Europe for use in a potential crisis.
EFPIA · filed 28 Jul 2023 · source
In its Compulsory Licensing (CL) proposal, the European Commission (EC) posits a new EU-wide CL for crisis response. This harms IP rights and is a dramatic expansion of the ECs role into Member State (MS) remit, where viable CL provisions already exist. CLs are a last resort, all attempts at voluntary licensing having failed.
EFPIA · filed 30 Mar 2022 · source
Bringing new therapies to patients is a long, complex and risky process that requires long-term and continuous investments. Patents are critical to that purpose and to the EU’s innovation and industrial ambitions.
Pharmaceutical Research and Manufacturers of America · filed 5 Apr 2022 · source
The Pharmaceutical Research and Manufacturers of America, and the innovative biopharmaceuticals companies that they represent, commend the European Commission’s call for the development of a single procedure for the granting of supplementary protection certificates (SPCs) in Europe.
EFPIA · filed 15 Sept 2023 · source
EFPIA supports the stated aims for the SPC revisions. Central SPC issuance for classical European patents and Unitary Patents will improve IP framework efficiency, bringing innovative medicines to patients in a timely manner via reliable protection.
EFPIA · filed 15 Sept 2023 · source
EFPIA supports the stated aims for the SPC revisions. Central SPC issuance for classical European patents and Unitary Patents will improve IP framework efficiency, bringing innovative medicines to patients in a timely manner via reliable protection.
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