Knowledge Ecology International Europe's (KEI Europe) comments on the Commission's proposal for a regulation on compulsory licensing addresses the following issues. The regulation should not be limited to an emergency. The exceptions for regulatory data protections and market exclusivity are important. The exceptions can be implemented under Article 44.2 of TRIPS, more efficiently than under Articles 31 or 31bis.
Knowledge Ecology International Europe
NGO · Switzerland · EU Transparency Register 274093330410-67
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.
Who they are
Among the 964 non-governmental organisations on this site, they rank #597 by legislative files engaged — a count of participation, not a measure of influence.
Declares membership of
- Trans Atlantic Consumer Dialogue - http://tacd.org/
Self-declared to the EU Transparency Register (snapshot 2 Sept 2026).
- Register category
- Non-governmental organisations
- Head office
- Le Grand-Saconnex, Switzerland
Self-declared to the EU Transparency Register (snapshot 2 Sept 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
Knowledge Ecology International Europe filed 2 positions between 29 Apr 2022 and 31 Jul 2023, across 1 of the 583 legislative files tracked here.
What they argued
1. In the European Union (EU)’s revised framework for compulsory licensing of patents, the EU anticipates establishing an EU-level compulsory licence for use in a crisis, acknowledging that a patchwork of fragmented, national compulsory licensing laws are not fit for purpose in dealing with the pandemic response or other crises. The following are KEI Europe’s recommendations regarding this issue. 2.
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Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.