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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.

3
files engaged
of 583 tracked
5
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
EFP
EFPIA

Industry association · Belgium

35
files engaged
of 583 tracked
49
positions filed
in those 583 files
13.4
declared FTE
self-declared
13
EP accreditations
as declared to the register

Declared costs: €6M+ 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

EFPIA · filed 27 Apr 2021 · source

EFPIA supports an agile regulatory framework and a strong incentives’ system that embrace and encourage advances in science, technology & medicines. This evaluation is an opportunity to implement learnings from COVID-19 and ensure a competitive, world-class regulatory system in Europe supporting a globally competitive research-based industry at a critical time.

EFPIA · filed 3 Oct 2023 · source

EFPIA supports the objectives of enhancing the availability and accessibility of medicines, while fostering a competitive innovation environment in Europe. We welcome the proposal to future-proof the EU regulatory framework, maximising the use of expedited pathways, optimising regulatory decision-making processes, and reducing unnecessary administrative burdens.

EFPIA · filed 9 Oct 2023 · source

EFPIA supports the objectives of enhancing the availability and accessibility of medicines, while fostering a competitive innovation environment in Europe. We welcome the proposal to future-proof the EU regulatory framework, maximising the use of expedited pathways, optimising regulatory decision-making processes, and reducing unnecessary administrative burdens.

The Danish Association of the Pharmaceutical Industry · filed 7 Nov 2023 · source

On 26 April 2023, the European Commission published proposals for the reform of the EU pharmaceutical legislation revising existing legislation on medicines, with the aim of increasing the availability of medicines and vaccines, while at the same time strengthening scientific research and innovation in Europe for the benefit of patients.

Filed in Danish · English published by the European Commission

Compulsory licensing of patents in crisis situations

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.

The Danish Association of the Pharmaceutical Industry · filed 29 Apr 2022 · source

Strong IP protection has allowed the pharmaceutical industry to react quickly to COVID-19 and facilitates the cooperation and partnerships needed to defeat the virus and end the pandemic. Much of this work builds on products, knowledge and research capacities developed over many years to support a strong and stable IP system.

Filed in Danish · English published by the European Commission

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.

The Danish Association of the Pharmaceutical Industry · filed 31 Jul 2023 · source

This proposal is extremely worrying, especially as patents enabled the pharmaceutical industry to react quickly to COVID-19 and laid the foundations for the cooperation and partnerships needed to defeat the virus and end the pandemic. Much of this work was based on products, knowledge and research capacities developed over many years, supporting a strong and stable IP system.

Filed in Danish · English published by the European Commission

Supplementary protection certificate for plant protection products. Recast

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.

The Danish Association of the Pharmaceutical Industry · filed 4 Apr 2022 · source

Research and development of new innovative medicines is a very costly and lengthy process, thus also entailing significant commercial risks for businesses. Patents are therefore a prerequisite for a successful pharmaceutical industry that creates value and welfare for patients.

Filed in Danish · English published by the European Commission

The Danish Association of the Pharmaceutical Industry · filed 4 Apr 2022 · source

Research and development of new innovative medicines is a very costly and lengthy process, patents are therefore a prerequisite for a successful pharmaceutical industry that creates value and welfare for patients. SPCs, ensure sustainable financing of innovation by precisely compensating for the period of patent exclusivity lost during a lengthy and costly research and development process.

Filed in Danish · English published by the European Commission

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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