The Swedish Society for Nature Conservations (SSNCs) comments on the EU general pharmaceuticals legislation: Regulation COM(2023) 193 (see separate feedback for Directive COM(2023) 192). Please find attached the pdf file containing a detailed response. GENERAL VIEWS: The SSNC supports the Commission's overall intentions regarding greater consideration for the environment in pharmaceuticals legislation.
SSN
Swedish Society for Nature Conservation (SSNC)
NGO · Sweden
3
positions filed
in the 583 files tracked
2
legislative files
of 583 tracked
3
with a full position paper
attached to a submission
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.
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Their record over time
Swedish Society for Nature Conservation (SSNC) filed 3 positions between 6 May 2022 and 29 Aug 2023, across 2 of the 583 legislative files tracked here, attaching a full position paper 3 times.
2022 · 1 filed2023 · 2 filed
What they argued
The Swedish Society for Nature Conservations (SSNCs) comments on the EU general pharmaceuticals legislation: Directive COM(2023) 192 (see separate feedback for Regulation COM(2023) 193). SUMMARY: 1) SSNC proposes that environmental risks should be included in the benefit-risk assessment of a pharmaceutical.
Today´s use of forest ecosystems does not meet the challenges facing society regarding biodiversity and forest ecosystem services, and not at least the need for climate adaptation of the forest and the forestry. Due to human pressures and unsustainable management the majority of the forests in Europe have medium to low ecosystem integrity.
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