The Commission published its proposals on orphan works some time ago, and the International Federation of Reproduction Rights Organisations has now put in its observations which can be found here. No surprise that they advocate a solution based on licensing, and argue that conditions for use of orphan works need to be decided on by authors and publishers. They also invoke the principle of subsidiarity to support a call for Member States to be permitted to legislate for different solutions at the national level.
The Commission's page on the proposal is here.
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