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De Regenboog Groep

FRG

Correlation-European Harm Reduction Network (C-EHRN) was established in 2004 in Amsterdam as a European civil society network and centre of expertise in the field of drug use, harm reduction and social inclusion for marginalised populations affected by drug use and related harms.

Lobbying Activity

Response to EU Drugs Strategy and European Action Plan Against Drug Trafficking

24 Sept 2025

This statement is submitted on behalf of Correlation European Harm Reduction Network and is supported by the European Drug Policy Alliance, representing more than 40 European drug policy and harm reduction organisations. We welcome the opportunity to contribute to the forthcoming EU Drugs Strategy. While the Commission refers to a balanced approach, we are concerned that the Strategy disproportionately emphasises supply reduction, without concrete commitments, actions, or indicators in the areas of health and human rights. Such an imbalance undermines the EUs longstanding commitment to evidence-based, rights-focused drug policy that provides guidance to Member States. The title of the call for evidence already signals a shift away from balance, framing drug policy primarily through a security lens. referring only to drug trafficking and suggesting, for the first time, the removal of dedicated sections on demand and harm reduction. This represents a significant departure from the principles guiding EU drug policy since 2013. The new Strategy should build on both the achievements and shortcomings of the current framework. While harm reduction and public health are affirmed in principle, implementation remains inconsistent. Supply-side interventions are systematically prioritised and well-resourced, whereas health and harm reduction measures remain fragmented and underfunded. Essential services including needle and syringe programmes, opioid agonist treatment, naloxone provision, drug consumption rooms, safer inhalation equipment, drug checking, and community-based HIV and hepatitis C testing and treatment remain insufficient across Europe. This gap is not due to lack of evidence, but reflects a lack of political prioritisation, commitment and long-term funding. Harm reduction works! It saves lives, prevents communicable diseases and other health problems, reduces overdose deaths, and promotes social inclusion. It is cost-effective and endorsed by all relevant international health and human rights bodies. In contrast, prohibitionist and security-based approaches continue to attract significant investment, despite research including by the European Commission demonstrating that supply-disruption strategies fail to reduce availability, merely displace trafficking routes, and exacerbate violence and crime. As a result, Europe is experiencing increasing drug availability, rising prevalence of use, higher levels of drug-related violence, organised crime, and preventable mortality. The Strategy must therefore place health and human rights at its core. Drug use should be addressed as a health and social issue rather than a matter of criminal justice. Punitive measures perpetuate stigma, deter individuals from accessing services, and deepen marginalisation. A health and rights-based approach should prioritise decriminalisation, explore models of responsible regulation, ensure equitable access to harm reduction and healthcare, and remove barriers to dignity, rights, and inclusion. Adequate and sustainable funding must be a central priority. Community-based organisations delivering essential services are constrained by unstable funding and short-term support. The EU should establish long-term financing mechanisms for harm reduction, reinforce support for civil society, and ensure transparent, equitable allocation of resources among Member States. The meaningful participation of affected communities and civil society must be guaranteed, enhancing responsiveness, inclusiveness, and sustainability of interventions. Finally, accountability is essential. A credible balanced strategy requires measurable health and human rights indicators, alongside supply reduction. These should include reductions in overdose deaths, HIV and HCV incidence, levels of stigma, and improved access to harm reduction and health services. Such indicators must be integrated into EU and national monitoring frameworks and made publicly available.
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Response to EU Civil Society Strategy

3 Sept 2025

Statement on the EU Civil Society Strategy Correlation European Harm Reduction Network (C-EHRN) is a European civil society-based network working in the field of drug policy, health, and social inclusion. We envision an inclusive and just Europe where people who use drugs, alongside other marginalised and underserved communities, have equitable and universal access to health and social carefree from discrimination and stigma. Across Europe, civil society organisations working on health, human rights, and social justice face mounting pressures. Harm reduction services remain chronically underfunded, while marginalised communitiesincluding people who use drugs, migrants, LGBTQI individuals, sex workers, and people experiencing homelessnesscontinue to suffer from systemic exclusion. The shrinking of civic space, coupled with the rise of authoritarian and populist politics, exacerbates these inequalities and undermines democratic values. In the field of drug policy reform and harm reduction, civic space is under particularly acute attack. Punitive laws entrenched in criminalisation not only target people who use drugs but also obstruct the essential work of civil society and peer-led groups providing life-saving services. These organisations increasingly face legal uncertainty, harassment, smear campaigns, and direct threats to their ability to operate. This erosion of civic space is amplified by the spread of foreign agent laws in Bosnia and Herzegovina, Georgia, Hungary, Moldova, Montenegro, Serbia, and Ukraine. Such measures stigmatise NGOs, impose disproportionate administrative burdens, and undermine public trust. Elsewhere, authoritarian and far-right governments restrict advocacy, increase surveillance, obstruct registration, and criminalise the dissemination of harm reduction information under the false pretext of preventing drug propaganda. Hungarys recent constitutional amendment banning the promotion of drugs epitomises this dangerous trajectory, leading to the closure of harm reduction services and attacks on reform-oriented NGOs, which have been branded as foreign agents or accomplices of drug traffickers. At both EU and national levels, drug policy continues to be framed as a security issue, sidelining health and human rights. At the same time, funding for harm reduction and reform-focused organisations has been cut, while enforcement budgets expand. With donor support dwindling and national funding shrinking, the survival of many community-led and peer-run harm reduction programmes is at critical risk. Against this backdrop, the EUs Civil Society Strategy must take decisive action to protect and strengthen civic space, and to ensure the sustainable resourcing of civil society organisations. We therefore call on the EU to: Acknowledge the essential role of civil society in upholding the rule of law and protecting marginalised communities. Strengthen the mandate and active engagement of civil society across Europe and across all areas of EU policymaking. Make civic space protection a cornerstone of the EU framework, and hold Member States accountable for safeguarding the rights of civil society organisations. Support civil society engagement across all EU policies, ensuring participation through transparent mechanisms and access to funding opportunities in every policy domain. Guarantee the continuation of Operating Grant funding as an essential instrument to protect civic space and sustain civil societys engagement. These grants have been vital for enabling organisations to promote health, build capacity, monitor policy, and advocate for vulnerable and underserved communities. Civil society is not an obstacle to governanceit is an indispensable partner. For drug policies, and indeed for all EU policies, to be just, humane, and effective, the EU must commit to protecting civic space and providing the resources that civil society and affected communities need to survive and thrive.
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Response to EU Strategy on medical countermeasures

18 Apr 2025

Stichting De Regenboog Groep and Correlation European Harm Reduction Network (C-EHRN) welcome the European Commissions initiative to develop a comprehensive EU Strategy to Support Medical Countermeasures (MCMs) and appreciate the opportunity to contribute to this important consultation. Drawing from our longstanding work with communities disproportionately affected by stigma, discrimination, and structural health inequitiesparticularly people who use drugswe strongly urge the Commission to embed the principles of equity, inclusivity, and accessibility at the heart of the forthcoming strategy. Public health emergencies inevitably deepen existing inequalities and often hit hardest those already underserved by mainstream healthcare systems. For the MCM Strategy to be effective, it must explicitly address these disparities and ensure that no one is left behind. We call for the integration of the following principles and priorities: Equity as a foundational principle in the development, allocation, and deployment of medical countermeasures; Inclusive preparedness planning that accounts for people in vulnerable and marginalised situations, including those facing legal, social, and systemic exclusion; Meaningful involvement of civil society and affected communities in all stages of planning, implementation, and monitoring; Do no harm: MCMs must be designed and delivered in ways that prevent further harm or exclusion of people in vulnerable contexts; Recognition of the social determinants of health as a key factor influencing resilience and access to MCMs; Removal of structural and practical barriers to accessing MCMs for groups such as people who use drugs, undocumented migrants, people experiencing homelessness, and others with limited access to mainstream healthcare; Support for community-based and community-led services, which serve as trusted, frontline actors during public health crises; Fair, transparent, and needs-based distribution mechanisms for vaccines, diagnostics, therapeutics, and protective equipment; Integration of lessons learned from the COVID-19 pandemic, particularly the critical role civil society played in reaching communities often left out of institutional responses. Medical countermeasures can only be effective if they are equitably accessible and tailored to reach those most at risk. A truly resilient and impactful EU Strategy must be intersectional, community-driven, and grounded in human rights. We remain committed to supporting the Commission in shaping a strategy that safeguards the health of all people in Europe, with special attention to those most often excluded from conventional public health planning and response. Stichting De Regenboog Groep & Correlation European Harm Reduction Network (C-EHRN) April 2025
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Response to Evaluation of the Council Framework Decision on criminal acts and applicable penalties for drug trafficking

4 Feb 2025

Correlation-European Harm Reduction Network (C-EHRN) submission for the evaluation of Council Framework Decision 2004/757/JHA The European Harm Reduction Network (C-EHRN) welcomes the opportunity to comment on the Council Framework Decision 2004/757/JHA, contributing with the following comments and recommendations: As the landscape of drug use in Europe evolves, a variety of complex dynamics arise, including greater diversity, potency, and purity of substances. Synthetic drugs, including potent opioids and newer psychoactive substances and their associated risks, create new health and policy challenges, and require adaptation of existing responses and services. The illegal drug market is thriving and has become more complex. At the same time the human rights situation in relation to drug control is deteriorating. The Council Framework Decision aims (amongst others) to reduce the availability of illicit drugs. Although this seems a noble endeavor, evidence shows that the unbalanced focus on law enforcement and crime prevention is ineffective and counterproductive. Recommendations 1. Need for an evidence and health-based drug policy approach and a balanced EU Drug Policy Instead of focusing on the unrealistic goal of reducing the drug supply and the scale of the drug market, the Framework Decision should acknowledge and address the complexity of drug use and the associated health risks and reduce criminalisation, stigma and violence against affected communities, contributing to marginalization and socio-economic and health inequalities. Additionally, the evolving drug landscape's complexity requires innovative, pragmatic policy solutions. Such a policy approach cannot shy away from exploring responsible regulation as a key measure to contrast organised crime and ultimately support the health and human rights of communities. 2. Ensure the exclusion of personal consumption from imposition of criminal sanctions The Council Framework Decision proposes to focus on the most serious types of drug offences, excluding personal consumption. This is fundamental, considering the severe health and human rights harms associated with the criminalisation of people who use drugs, as highlighted by OHCHR, the UN Special Rapporteur on the right to health, UNAIDS and other UN experts. This principle should extend not only to drug use, but also possession, cultivation and purchase for personal use, as well as social sharing. 3. Ensure the principle on proportionality The Framework Decision calls on Member States to impose effective, proportionate and dissuasive penalties, including custodial sentences, depending on the quality and type of drugs trafficked and the involvement of criminal organisations. Research shows that people targeted by drug law enforcement are generally involved at the lowest levels of the trafficking chain, are among the most marginalised, and face multiple and intersecting layers of vulnerability. While their arrest and incarceration has no effect on the scale of the market, it has long-lasting impacts on their lives, their families and communities. According to the principle of proportionality, situations of vulnerability and marginalisation should be taken into account in the imposition of any sanction, and prison should be used as a means of very last resort. In line with the UN System Common Positions on drugs and on incarceration, the Framework Decision should recognise this and explicitly promote alternatives to punishment. 4. Address the human rights implications of the use of new technologies in drug control States increasingly rely on surveillance technologies to enforce drug control measures, placing predictive policing and forecasting at the centre of law enforcement. This has led to the emergence of privacy-invasive tools and practices such as pre-crime profiling, so-called gangs databases, registries of people who use drugs, individual bio-testing as a condition to access services,
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Response to Ex-post evaluation of the Justice programme (2014-2020) and interim evaluation of the Justice programme (2021-2027)

7 Sept 2023

The Justice Programme 2014-2020 offered funding opportunities for small civil society led projects in the field of drug demand reduction and harm reduction, which resulted in.a number of relevant drug- related projects in the field. This includes for example the Peer2Peer Project, the Eurosider Project, the Betrad Project, the NPS Project, the CSFD project I and Ii, the So-prep Project, the Drug-prep Project and the Feniqs Project. All these project were closely linked to the priorities in the EU Drug Strategy (2104-2020) and the follow-up Strategy from (2021-2027) and contributed as such to the implementation of a balanced drug policy approach, based on evidence and good practices. The Justice Programme 2021-2027 eliminated all funding opportunities for civil society organisations in the field of drug demand and harm reduction. Instead, all funding opportunities for drug related projects are limited to initiatives linked to security and the prevention of drug-related crime. Although the Drug Strategy (2021-2027) clearly calls for a baalnced approach, this is not refelcted in the programme. We therfore call for a serious review of the current Justice programme and a more balanced approach in favor of civil society led drug demand abnd harm reduction projects. We also want stress the need to involve civil society and the CIvil Society Forum on Drugs in particular in yhe evaluation of the Programme and the development of a new programme.
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Response to Revision of the mandate of the European Monitoring Centre for Drugs and Drug Addiction

11 Apr 2022

Correlation-European Harm Reduction Network (C-EHRN) welcomes a renewed mandate for the EMCDDA. The EMCDDA plays a crucial role in collecting and analysing reliable data and in building and promoting evidence-based interventions in the field of drug demand reduction. C-EHRN welcomes that the EMCDDA will be able - to further enhance its important role in collecting and sharing drug-related data and information and monitor the drug phenomenon, encompassing public health, safety and security dimensions. - to improve the information exchange and the early warning system for new psychoactive substances - to contribute to competence development in EU Member States In addition to this, C-EHRN would like to address some points of concern: Important role of civil society The role of civil society is currently insufficiently addressed in the proposal. Civil Society Organisations (CSO) working in the field of health play a crucial role at many levels, and their activities are necessary at different levels. They are a vital partner to both European and national institutions in shaping public health strategies and drug policies, and they are in most countries a fundamental vehicle for their implementation. CSOs are also essential in bridging the gap between policymaking and the communities they represent, and they approach this in a professional, efficient, and democratic manner. This became even more apparent during the current COVID-19 pandemic, when CSOs were able to rapidly adapt to the situation, dedicating expertise and capacity to help policymakers in developing and communicating their pandemic response strategies to the public, while feeding back essential information for better decisions based on people’s diverse needs and concerns. CSOs play an important role in the – not only in the implementation of services, but also in the collection of data and information. In many countries, Reitox Focal Points already depend on relevant data from CSOs. CSOs do and can contribute significantly to the early warning system, the threat assessment and the development of preparedness interventions. As such, we would welcome if CSOs, professionals and networks of people who use drugs are acknowledged as critical sources of information and knowledge, and as intermediary to ensure that information is disseminated and shared with drug services and people who use drugs. Involving civil society in a meaningful way will increase the impact of EMCDDA activities and contribute to the promotion of evidence based interventions and good practices. Monitoring and evaluation of national drug policies CSOs should also be involved in the monitoring and the evaluation of drug policies, which will be one of the tasks of the national focal points, as suggested in article 33(d). The evaluation of drug policies should be organised in a structured and inclusive manner, ensuring the meaningful involvement of those, directly affected by the policies. Increased focus on the promotion of evidence-based interventions Although C-EHRN welcomes the specific focus on prevention in the field of competence development, more emphasis on other areas of drug demand reduction, in particular harm reduction is needed. The promotion of evidence-based interventions through the EMCDDA would help to catalyse the wider implementation at EU MS level and support effective support and health care services for People Who Use Drugs.
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