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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.

VIG
Vereniging Innovatieve Geneesmiddelen

Industry association · Netherlands

5
files engaged
of 583 tracked
7
positions filed
in those 583 files
1
declared FTE
self-declared
1
EP accreditations
as declared to the register

Declared costs: €50K+ a year · in the register since 2023

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 (5)

Medicinal products for human use · A European Health Data Space · Revision of the EU legislation on medicines for children and rare diseases · 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

Vereniging Innovatieve Geneesmiddelen · filed 26 Apr 2021 · source

The Vereniging Innovatieve Geneesmiddelen (VIG) considers the evaluation of the pharmaceutical legislation an opportunity to draw lessons from the COVID-19 pandemic and prepare for the future. To remain attractive for innovation and R&D while effectively responding to future challenges and threats.

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.

Vereniging Innovatieve Geneesmiddelen · filed 7 Nov 2023 · source

On behalf of the Association Innovative Medicines (VIG), the Dutch industry association of 44 innovative medicines manufacturers, our response to the proposed revision of the EU pharmaceutical legislation. The members of the VIG are active in the biopharmaceutical ecosystem of the Netherlands, which extends from academic institutions and hospitals to medicine developers and service companies.

Filed in Dutch · English published by the European Commission

Vereniging Innovatieve Geneesmiddelen · filed 7 Nov 2023 · source

On behalf of the Association Innovative Medicines (VIG), the Dutch industry association of 44 innovative medicines manufacturers, our response to the proposed revision of the EU pharmaceutical legislation. The members of the VIG are active in the biopharmaceutical ecosystem of the Netherlands, which extends from academic institutions and hospitals to medicine developers and service companies.

Filed in Dutch · English published by the European Commission

A European Health Data Space

EFPIA · filed 3 Feb 2021 · source

EFPIA welcomes the proposal to create sectoral and horizontal legislative frameworks to unlock the value of data, support the use, re-use and exchange of health data at the EU level and ensure coherence between the operation of the different legislations contributing to the functioning of the Data Space.

Vereniging Innovatieve Geneesmiddelen · filed 4 Feb 2021 · source

The Vereniging Innovatieve Geneesmiddelen (VIG) is positive towards the proposal of the European Commission to establish a European Health Data Space (EHDS). This proposal enables the EU to better grasp the potential of health data for research and innovation on new preventive strategies, as well as on diagnosis and treatment of diseases to improve health outcomes.

EFPIA · filed 28 Jul 2022 · source

The legislative proposal on a European Health Data Space (EHDS) and respective horizontal proposals provide an unprecedented opportunity to shape the future health data and digital ecosystem. Digital transformation has the potential to increase the innovation and productivity of the EU economy and ensure that Europe remains an innovator and world leader in the development and manufacture of medicines, supporting…

Revision of the EU legislation on medicines for children and rare diseases

Vereniging Innovatieve Geneesmiddelen · filed 6 Jan 2021 · source

Pharmaceutical companies are committed to develop solutions for unmet needs and to ensure available treatments reach all patients in Europe. Patients with rare diseases and children have benefited greatly from the progress which has been realised with the OMP Regulations.

EFPIA · filed 6 Jan 2021 · source

EFPIA members are committed to ensuring that unmet needs are addressed and that available treatments reach all European patients. Children and rare disease (RD) patients have greatly benefited from the progress achieved through the Paediatric and Orphan Regulations. The Paediatric Regulation is meeting best-case expectations from its impact assessment (IA) conducted in 2004.

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.

Vereniging Innovatieve Geneesmiddelen · filed 29 Apr 2022 · source

Without the continuous and substantial investments in R &D, new technologies would not be developed. The (mRNA) vaccines and medicines used in the COVID pandemic would not have been there without the robust EU Intellectual Property (IE) system. IE, more specifically patents provide incentives for innovation through knowledge-sharing and in return temporary market protection to recoup (financial) investments.

Filed in Dutch · 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.

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.

Vereniging Innovatieve Geneesmiddelen · filed 4 Apr 2022 · source

The development and marketing of new medicines requires time and investment in research, the outcome of which is uncertain: many developments do not lead to a useful medicine. There is no doubt that a well-functioning IP system is indispensable for a good innovation and investment environment.

Filed in Dutch · 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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