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.
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.
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 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 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.
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
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.
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
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.
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
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.
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
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 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 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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