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
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.
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 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 Pharmaceutical Research and Manufacturers of America (PhRMA) · filed 8 Nov 2023 · source
The Pharmaceutical Research and Manufacturers of America and its member companies join the European Federation of Pharmaceutical Industries and Associations in raising significant concerns with a number of the proposed revisions to Directive 2001/83/EC and Regulation EC 726/2004.
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.
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 Pharmaceutical Research and Manufacturers of America (PhRMA) · filed 31 Jul 2023 · source
PhRMA has serious concerns with the ECs proposed regulation to establish a pan-EU compulsory licensing (CL) mechanism for crisis management. Although most respondents during the consultation process supported a coordinating role only for the EU institutions related to CLs, the proposed regulation goes significantly further.
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.
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.
The Pharmaceutical Research and Manufacturers of America (PhRMA) · filed 20 Sept 2023 · source
PhRMA joins EFPIA in raising significant concerns with the European Commissions (ECs) proposal to establish a new mechanism for parties to oppose the grant of SPCs. While PhRMA supports the general intent of the proposed recast of the SPC Regulation to establish a centralized process for seeking SPCs in the EU without altering the substance of that protection, the proposed procedure includes redundant and…
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