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.
Company · Sweden
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.
The Swedish Association of the Pharmaceutical Industry · filed 29 Apr 2022 · source
The significant investment in research and development (R & D) by several actors and for many years in new technologies, vaccines, therapeutic and other products, now available to deal with COVID-19, would not have existed without the current and robust EU IP system.
Filed in Swedish · 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.
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 Swedish Association of the Pharmaceutical Industry · filed 5 Apr 2022 · source
The SPC is a very important intellectual property right for pharmaceutical companies, enabling innovation and the making available of new medicines. The positive effect of the SPC in this regard was confirmed by the Commission’s evaluation of the SPC legislation in 2020. In view of the above, Lif strongly believes that no changes should be made to the SPC itself or to related legislation (alt C2).
Filed in Swedish · 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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