OpenLobby.EU
Explore

European Alcohol Policy Alliance

Eurocare

The European Alcohol Policy Alliance is an NGO working to reduce alcohol-related harm in Europe.

Lobbying Activity

Meeting with David Boublil (Head of Unit Taxation and Customs Union)

30 Sept 2025 · HFSS taxation, Tobacco taxation

Eurocare calls for alcohol taxes in EU cardiovascular health plan

16 Sept 2025
Topic — The Commission is seeking views on a plan to reduce cardiovascular diseases.
Message — Eurocare demands the Commission prioritize population-level measures like alcohol taxation and mandatory on-label nutritional information. They also call for an end to EU subsidies for alcohol production and promotion.1234
Why — Strict regulations would decrease overall alcohol consumption and improve health in vulnerable communities.56
Impact — Alcohol producers and wine growers would face higher costs and reduced financial support.78
Read full response

Health alliance demands stable funding in new EU strategy

5 Sept 2025
Topic — This consultation seeks input on creating a framework to support EU civil society.
Message — The alliance calls for multi-annual operating grants and a binding agreement on civil dialogue. They demand enforced consultation standards and protection from industry-led harassment and legal threats.12
Why — Stable funding would secure their independence and long-term ability to influence policy.3
Impact — Industry lobbyists would lose their dominant influence over high-level EU policy meetings.4
Read full response

Meeting with Olivér Várhelyi (Commissioner) and

2 Sept 2025 · Preparation for the upcoming EU Cardiovasular Action Plan

Meeting with Antonella Rossetti (Cabinet of Commissioner Christophe Hansen)

25 Jun 2025 · Exchange of Views on Alcohol Labelling

Meeting with Alexandra Nikolakopoulou (Head of Unit Health and Food Safety)

17 Jun 2025 · Meeting on the Revision of the FIC Regulation

Meeting with Vytenis Povilas Andriukaitis (Member of the European Parliament)

23 Apr 2025 · EU Health Policy

Meeting with Tomislav Sokol (Member of the European Parliament)

20 Feb 2025 · Consumer protection

Meeting with Tilly Metz (Member of the European Parliament)

25 Sept 2024 · public health policy

Meeting with Sarah Wiener (Member of the European Parliament)

2 Feb 2023 · Labelling on alcohol

Meeting with Stella Kyriakides (Commissioner)

25 Jul 2022 · Video conference with representatives of the European Alcohol Policy Alliance

Response to Revision of Food Information to Consumers for what concerns labelling rules on alcoholic beverages

20 Jul 2021

EUROCARE (The European Alcohol Policy Alliance) is an alliance of 52 non-governmental and public health organisations in 21 European countries with member organisations across Europe advocating for the prevention and reduction of alcohol related harm in Europe. Eurocare welcomes the opportunity to provide input and feedback on the Inception Impact Assessments of the Proposal for a revision of Regulation (EU) No 1169/2011 on the provision of food information to consumers, for what concerns labelling rules on alcoholic beverages and we look forward to future consultation activities. Eurocare mostly agrees with the European Commission’s understanding of the problem and welcomes the conclusion of the Commission’s 2017 Report regarding the mandatory labelling of the list of ingredients and the nutrition declaration of alcoholic beverages asserting that there can be no objective grounds justifying the absence of information to consumers on ingredients and nutrition information on alcoholic beverages. However, Eurocare wishes to express its disappointment at the scope of the inception impact report for the revision of Regulation of Regulation (EU) No 1169/2011 on the provision of food information to consumers (FIC Regulation). Indeed, Eurocare considers that inclusion of a lex specialis approach would have been far more appropriate. Alcoholic beverages are not consumed in the same way, nor do they have the same effects, as food products; although alcoholic beverages contain calories and therefore have a nutritional aspect that should be clearly indicated on the label, they are fundamentally different from foodstuffs in that they have psychoactive and dependence-producing properties; Alcoholic beverages are drinkable liquids containing ethanol (ethyl alcohol; C2H5OH) , a substance rapidly absorbed from the gastrointestinal tract and distributed throughout the body with psychoactive effects. Alcohol consumption is also a causal factor in more than 200 disease and injury conditions. Moreover, there is a causal relationship between harmful use of alcohol and a range of mental and behavioural disorders, other noncommunicable conditions as well as injuries. The latest causal relationships have been established between harmful drinking and incidence of infectious diseases such as tuberculosis as well as the course of HIV/AIDS. Beyond health consequences, the harmful use of alcohol brings significant social and economic losses to individuals and society at large . In other words, from a health and social perspective, alcoholic beverages are not an ordinary foodstuff nor an ordinary commodity. Therefore – as suggested by de Coninck and Gilmore in their recent contribution in the Lancet – the objectives of consumer protection as well as health and well-being of citizens would be better achieved through legislation specifically adapted to the characteristics of these products, rather than legislation applying to food products in general. Inspiration could be drawn from the success of the Tobacco Products Directive (2014/40/EU) in this regard.
Read full response

Response to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services

29 Mar 2021

The European Alcohol Policy Alliance (Eurocare) welcomes the opportunity to comment on the Digital Services Act – deepening the internal market and clarifying responsibilities for digital services. Eurocare is an alliance of non-governmental health organisations with 52 member organisations across 22 European countries advocating the prevention and reduction of alcohol related harm in Europe. Given Eurocare’s profile, comments are given to areas in which it possesses expertise and interest. As a general comment Eurocare would like to support the European Commission’s initiative for a horizontal instrument to prevent legal and practical fragmentations in the single market and the need for better alignment and simplification of the legal provisions governing the digital landscape. Eurocare believes that it is the European Commission’s obligation to lay down clearer, more stringent, harmonised rules for digital actors’ responsibilities to increase citizen’s safety online and protect their rights. Eurocare would like the DSA to focus on safety of vulnerable users, children and young people. Special attention needs to be given to areas such as online advertising as they are a core feature (and heart of the business model) for most online platforms and currently enjoy competitive advantage compared to traditional media. The European Alcohol Policy Alliance (Eurocare) has in previously DSA-consultation expressed the need to include harm into the legislation – not only illegal content. Given the burden alcohol places on people’s health and its role as a risk factor for cancer, EU should ensure policy coherence between provisions for online advertising of alcohol (through AVMSD, DSA and other legal instruments) and its health policy goals. With this in mind, we have the following feedback to the proposed initiative: Article 17: internal complaint-handling system We believe harmful content, and not only illegal content, should be included in a responsible internal complaint-handling system of the platforms. An example is advertisement of alcohol that are not following the AVMSD, such as advertisement of alcohol linked to social success. This content is in most Member States not illegal, but given the negative health consequences of the product, it should be included in complaint systems. In addition, in some Member States the content is not allowed, and this cross-border issue should also be reflected in the complaint-handling system. Article 19: trusted flaggers As explained above, harmful content should be part of the issue of trusted flaggers, and not only illegal content. There may be content that is not illegal, but still have negative consequences and should therefore be included in the issue of trusted flaggers. Article 31: data access and scrutiny (for ‘very large online platforms’ only) We would like to propose that very large online platforms also should give access to data about advertisement of potentially harmful content for consumers – such as alcohol, food in high fat, sugar, and salt. Again, the data released for scrutiny should not be limited to illegal content, but also other data related to other potential harms. Article 37: crisis protocol We would like to express our support to the inclusion of public health in the proposal, where the Board may recommend the Commission to initiate crisis protocols. Article 48 – structure of the Board: We would like to propose the inclusion of a civil society representative for consumer issues, including public health, as part of the Board. This would strengthen citizen’s voice in the work of the Board, and lead to better transparency and legitimacy. Eurocare would strongly advocate that given the burden alcohol places on people’s health and its role as a risk factor for cancer, EU should ensure policy coherence between provisions for online advertising of alcohol (through AVMSD, DSA and other legal instruments) and its health policy goals.
Read full response

Response to Information and promotion measures for agricultural and food products in the internal market and in non-EU countries

8 Mar 2021

The European Alcohol Policy Alliance (Eurocare) supports the comprehensive approach within the F2F strategy and to introduce changes within the food system enabling EU citizens to lead healthy lifestyle regardless of social background. Given Eurocare’s profile, comments will be given to areas in which it possesses expertise, mainly prevention and reduction of alcohol related harm. Europe’s Beating Cancer Plan stated it will support Member States and stakeholders for the implementation of best practice interventions and capacity building activities to reduce harmful alcohol consumption in line with the targets of the UN SDGs. To achieve this, it needs to reduce the exposure of young people to marketing of alcoholic beverages. The Commission should therefore stop stimulating consumption of alcohol via the EU promotion programme for agricultural products. Wine promotion subsidies are aimed primarily at increasing European wines’ competitiveness in non-EU countries through activities such as information campaigns, market studies and participation at wine fairs abroad. The CAP features two parallel schemes for wine promotion. One is regulated over Reg (EU) 1308/2013 and amounts to nearly €250 million in 2018. Another one is regulated over Reg (EU) 1144/2014 and has financed more than €22 million in wine related promotion since its inception in 2014. There is a clear trend of increasing budgets for both these schemes. These promotional measures, draining millions of euros from the EU budget, jeopardize public health, create market distortions, and occasionally camouflage serious misuse of funds by the beneficiaries. Furthermore, the European Court of Auditors have questioned the role of EU grants to promote wine, citing lack of demonstrable results over the scheme’s lifetime. European agricultural policies are important tools to support farmers’ livelihood and sustainable rural development. However, EU policies must be coherent and cannot be evaluated according to economic metrics alone: Public health perspectives should always be weighed into evaluations, especially when the beneficiaries of a policy are producers of alcoholic beverages. Worryingly, the wine industry’s promotional activities heavily rely on marketing in social media that does not differentiate between youth and adult users. And so, kids and youth below legal drinking age are exposed to messages that encourage them to drink European wine. The earlier youth start drinking, the worse are the long-term health consequences. The subsidies favour Europe’s big wine producing countries: almost 90 percent of the funds are awarded to Spain, France and Italy, a situation that reinforces these countries’ grip of consumer markets. The EU should phase out this expensive market intervention, which could save at least as €1000 million per financial period (the amount that is paid in promotion subsidies to producers over a five-year period). Instead, the grubbing-up scheme should be reintroduced, which pays the wine farmers in cash money in exchange for permanently uprooting their vines. Unlike wine promotion subsidies, it has proven to be an effective measure in stemming the overproduction of wine. EUROCARE POSITION – LIMIT WINE PROMOTION SUBSIDIES • While we are supportive of promotional measures for agricultural products that are components of a healthy diet, wine – as a product with scientifically proven health risks – should not be considered a priority product. • In the evaluation of project proposals, public health perspectives must be taken into consideration next to the other evaluation criteria. • No promotional measures should be funded that exposes youth to alcohol marketing, particularly with the use of social media. Therefore, no social media promotional activities should receive funding. • The EU should enforce tighter scrutiny of the disbursed funds to combat fraudulent use of subsidies.
Read full response

Response to Facilitation of the installation of alcohol interlocks in motor vehicles

3 Mar 2021

The European Alcohol Policy Alliance (Eurocare) welcomes the opportunity to comment on how alcohol interlocks can improve traffic safety by preventing drivers from driving with alcohol concentrations above certain limits. Unfortunately, these devices are not mandatory in the EU but can be retrofitted to vehicles after they are first sold. It should be made easy to do this, vehicle manufacturers should be required to provide either a standardised connector or a clear document giving the necessary guidance on how to install them. Traffic accidents related to alcohol consumption are a major cause for concern in the EU. In 2018 25.150 people were killed on the roads in EU and 25% of all road deaths are alcohol related. At least 5.000 deaths would have been prevented if all drivers had been sober. The fatality risk increases exponentially with the blood alcohol content (BAC) level of the driver. The risk for drivers with low BAC levels (0.1 to 0.5g/L) is 1 to 3 times the risk of sober drivers. For drivers with a BAC level of 0.5 to 0.8 g/L it is already up to 20 times higher, increasing to 5-30 times for drivers with BAC levels of 0.8 to 1.2g/l. For high BAC offenders the risk is 20-200 times higher that of sober drivers. Eurocare supports European Transport Safety Council call for the European Union should introduce a zero-tolerance drink-driving limit as part of a package of measures to help prevent up to 5,000 alcohol-linked road deaths every year. The EU has recently set a target to reduce deaths and serious injuries on the road by half by 2030. A quarter of the 25,000 EU road deaths each year are likely to be linked to alcohol, according to European Commission estimates. Therefore, more progress on tackling drink driving is essential to reaching the overall target. Currently only seven out of 28 EU countries have a standard Blood Alcohol Concentration (BAC) limit of 0.2 g/l or below. 0.1 and 0.2 are effectively equivalent to zero tolerance, while still allowing for consumption of certain medicines, or drinks marketed as alcohol free. 19 have a limit of 0.5, while Lithuania has 0.4. Many countries also set lower limits for professional and/or novice drivers. (2) EUROCARE POSITION – Zero tolerance to alcohol-linked traffic accidents in the EU. • Alcohol interlocks can improve traffic safety by preventing drivers from driving with alcohol concentrations above certain limits. They should be mandatory in all cars. • As a minimum vehicle manufacturer should be required to provide it so it is easy to be retrofitted to vehicles after they are first sold. • Mandate the use of alcohol interlocks for professional drivers. • A zero-tolerance level (i.e. a maximum BAC of 0,2g/l) for all road users. • Intensity enforcement. Couple enforcement with publicity activities. • Improve data collection of alcohol-related road deaths. Mandate systematic testing of all road users involved in a collision with injury. • Run regular campaigns.
Read full response

Response to Revision of EU marketing standards for agricultural products

15 Feb 2021

The European Alcohol Policy Alliance (Eurocare) welcomes the opportunity to comment on the Agricultural products – revision of EU marketing standards. Eurocare supports the comprehensive approach within the F2F strategy and the EU’s determination to introduce changes within the food system enabling EU citizens to lead healthy lifestyle regardless of social background by promoting sustainable food consumption, facilitating the shift towards healthy, sustainable diets. Eurocare cares about the CAP because it lays out support programs for the promotion and marketing of wine. Wine promotion subsidies are aimed primarily at increasing European wines’ competitiveness in non-EU countries through activities such as information campaigns, market studies and participation at wine fairs abroad. These promotional measures, draining millions of euros from the EU budget, jeopardize public health, create market distortions, and occasionally camouflage serious misuse of funds by the beneficiaries. Furthermore, the European Court of Auditors have questioned the role of EU grants to promote wine, citing lack of demonstrable results over the scheme’s lifetime. European agricultural policies are important tools to support farmers’ livelihood and sustainable rural development. However, EU policies must be coherent and cannot be evaluated according to economic metrics alone: Public health perspectives should always be weighed into evaluations, especially when the beneficiaries of a policy are producers of alcoholic beverages. Worryingly, the wine industry’s promotional activities heavily rely on marketing in social media that does not differentiate between youth and adult users. And so, kids and youth below legal drinking age are exposed to messages that encourage them to drink European wine. The earlier youth start drinking, the worse are the long-term health consequences. The subsidies favour Europe’s big wine producing countries: almost 90 percent of the funds are awarded to Spain, France and Italy, a situation that reinforces these countries’ grip of consumer markets. The EU should phase out this expensive market intervention, which could save at least as €1000 million per financial period (the amount that is paid in promotion subsidies to producers over a five-year period). Instead, the grubbing-up scheme should be reintroduced, which pays the wine farmers in cash money in exchange for permanently uprooting their vines. Unlike wine promotion subsidies, it has proven to be an effective measure in stemming the overproduction of wine. EUROCARE POSITION – LIMIT WINE PROMOTION SUBSIDIES • While we are supportive of promotional measures for agricultural products that are components of a healthy diet, wine – as a product with scientifically proven health risks – should not be considered a priority product. • In the evaluation of project proposals, public health perspectives must be taken into consideration next to the other evaluation criteria. • No promotional measures should be funded that exposes youth to alcohol marketing, particularly with the use of social media. Therefore, no social media promotional activities should receive funding. • The EU should enforce tighter scrutiny of the disbursed funds to combat fraudulent use of subsidies. Eurocare will closely follow and contribute to further reforms and improvements to EU marketing standards.
Read full response

Response to Setting of nutrient profiles

1 Feb 2021

Eurocare welcomes the opportunity to comment on the Food labelling – revision of rules on information provided to consumers. Given Eurocare’s profile, comments will be given to areas in which it possesses expertise, mainly prevention and reduction of alcohol related harm. In March 2017, Eurocare welcomed the European Commission’s report on alcohol labelling required by Regulation (EU) No 1169/2011 on the provision of food information to consumers. Eurocare fully agrees and supports the report’s statement that objective grounds have NOT been identified which would justify the absence of information on ingredients and nutritional information on alcoholic beverages or a differentiated treatment for some alcoholic beverages, such as “alcopops”. There are obvious health reasons why labels should include ingredients, nutritional and health information. Being high in sugar, alcohol contains a considerable number of calories, with an energy content of 7.1 kilocalories per gram – only fat has a higher energy value per gram (9kcal/g). Additionally, many types of alcoholic beverages have extra added sugar which contributes to the total calorie content. Drinking alcohol is associated with a risk of developing more than 200 different types of diseases . Every day in EU+ countries, around 800 people die from alcohol attributable causes (291.000 per year). The main cause of death due to alcohol in 2016 was cancer (29% of alcohol-attributable deaths) . Product labels can serve several purposes, providing information about the product to the consumer, enticing the consumer to buy the product and alerting consumers to the dangers and health risks from the product. Due to insufficient labelling, when a consumer drinks an alcoholic beverage, it is almost certain that they are not aware of what they are drinking. One of the objectives of public bodies should be to effectively protect people from the risks and threats that they cannot tackle as individuals. EU Regulation 1169/2011 on the provision of food information to consumers unfortunately, exempted alcoholic beverages (containing more than 1,2% by volume) from the obligation to provide information to consumers - listing its ingredients and providing nutritional information nor the harm the product can cause the consumer. Listing the ingredients contained in a particular beverage alerts the consumer to the presence of any potentially harmful or problematic substances. Equally important, providing the nutritional information such as calorie content allows the consumer to monitor their diets better and makes it easier to keep a healthy lifestyle. Consumers should also be informed about the risks associated with alcohol consumption: damages to health (liver cirrhosis, cancers) risk of dependence, dangers associated with drinking alcohol during pregnancy, when driving, operating machinery and when taking certain medication. Providing full information about the product enables consumers to make informed choices and ensures that consumers know what is in the product they are spending their money on. The asymmetric relationship between the producers and purchasers of alcohol calls for enhanced consumer protection. Eurocare is convinced that bringing alcohol packaging in line with non-alcoholic beverages would enhance consumer choice. European Union Institutions are perfectly positioned to coordinate common efforts to inform consumers of the composition of alcoholic beverages. Eurocare is strongly convinced that the consumer has a right to make informed choices about the products they purchase, and it is the obligation of public institutions to enable them to exercise this right.
Read full response

Response to Cross-border acquisitions of excise goods by private individuals

21 Dec 2020

Eurocare welcomes the initiative regarding cross-border acquisitions of excise goods by private individuals. It is positive that the initiative is connected to the Europe's Beating Cancer Plan. Alcohol and tobacco taxation are some of the most effective policy instruments for reducing alcohol/tobacco consumption and thereby the prevalence of alcohol/tobacco related cancers. Raising the real price of alcohol through taxes and pricing policies is identified by the World Health Organisation as one of the most effective and cost-effective ways to reduce rates of alcohol harm. There is strong and consistent evidence that increasing the price of alcohol reduces immediate and chronic harm related to drinking among people of all ages. All consumers, including heavy and problematic drinkers, respond to changes in alcohol prices. As a general comment Eurocare would like to highlight that Article 32(1) of the Directive provides that excise goods, acquired by a private individual for his own use, and transported from one Member State to another by him in person, shall be liable to excise duty only in the Member State in which the excise goods are acquired and not in the Member State where the goods are consumed. This is an exception from the general rule that excises duties are levied in the place of consumption. The main policy options identified in the Inception Impact Assessment provide a good foundation for the process going forward. The change of guide levels to concrete and easily enforceable limits (quantitative limits) should be included within the scope of the policy option “revised and adjust the guide levels”. Many countries have also expressed a desire for similar rules as to purchase of fuels to apply to alcohol and tobacco. It is important that different combinations of the identified policy options are considered. The problems with the current rules are multi-layered and challenges differ slightly between countries. The best final policy option is most likely a combination of different policy changes. Enforcement should be considered when looking into the proportionality of policy options. Easily enforceable rules contribute to adherence, reduce legal fragmentation, and reduce administrative burdens. Eurocare calls for: • Member States should have the flexibility to limit individual cross-border purchases so as not to diminish the impact of their current tax policies. • Excises duties should be levied in the place of consumption
Read full response

Response to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services

30 Jun 2020

Given Eurocare’s profile, comments are given to areas in which it possesses expertise and interest. As a general comment Eurocare would like to support the European Commission’s remarks regarding an increasingly fragmented legal landscape and the need for better alignment and simplification of the legal provisions governing the digital landscape. Eurocare believes that it is the European Commission’s obligation to lay down clearer, more stringent, harmonised rules for digital actors’ responsibilities in order to increase citizen’s safety online and protect their rights. Eurocare would like the DSA to focus on safety of vulnerable users, children and young people. Special attention needs to be given to areas such as online advertising as they are a core feature (and heart of the business model) for most online platforms and currently enjoy competitive advantage compared to traditional media. Eurocare would suggest policy option 2 as most appropriate for DSA (a more comprehensive legal intervention) Eurocare would strongly advocate that given the burden alcohol places on people’s health and its role as a risk factor for cancer, EU should ensure policy coherence between provisions for online advertising of alcohol (through AVMSD, DSA and other legal instruments) and its health policy goals. In Eurocare’s view the DSA should: 1. Include the notion of harmful content (not only illegal) as one of its core principles; this should include content harmful to physical health (i.e. unhealthy food, alcohol, tobacco, drugs, gambling) as well as mental health 2. Alignment of provisions regarding alcohol advertising in the digital landscape with Article 22 of AVMSD (for Television advertising and teleshopping). Revised AVMSD promotes codes of self-regulation in area of online advertising however majority of current codes are vague, and alignment would provide better legal certainty. Furthermore, currently the traditional media i.e. national tv stations are placed at a competitive disadvantage compared with the US tech giants i.e. Facebook, YouTube in terms of alcohol advertising. A solution would be to ensure that players in the digital area must follow the same rules. 3. Address the suitability of the current EU legislative framework to deal with such developments as: a) 'integrative advertising' methods which rely on the mixing of commercial and non-commercial content b) advergames c) digital influencers and vlogging advertising (including product placement, sponsorships, editorials and other forms of vlogging advertising) 4. Improved enforcement mechanisms for cross-border disputes. Member States should be able to adopt laws protecting consumer interests. 5. Fragmentation in classification of digital players (intermediaries) and their responsibilities, for instance ‘gate keeper’ platforms with paramount importance to competition should be held to standards reflecting their market power. The current exemption in Art 14 of E-Commerce directive is not fit for purpose to determine platform liability. A platform which obtains income from alcohol advertising should have a duty of care for violations and not benefit from liability exemptions. This would create a double protection mechanism where advertiser and the medium on which it advertises would ensure alcohol advertising is not targeting children and vulnerable groups (i.e. previous heavy drinkers). 6. Explore the possibilities to limit cross platform profile sharing (creation of ‘super profiles’) especially in areas of sensitive data such as health (i.e. health apps data being combined with social media profiles for commercialisation purposes)
Read full response

Response to Farm to Fork Strategy

13 Mar 2020

European Alcohol Policy Alliance (Eurocare) welcomes the comprehensive approach within the F2F strategy. We particularly support EU’s determination to introduce changes within the food system enabling EU citizens to lead healthy lifestyle regardless of social background by Promoting sustainable food consumption, facilitating the shift towards healthy, sustainable diets. Eurocare is an alliance of non-governmental and public health organisations across Europe advocating for the prevention and reduction of alcohol-related harm. Member organisations are involved in advocacy and research, the provision of information and training on alcohol issues, and services for people whose lives are affected by alcohol problems. Eurocare’s mission is to promote policies that prevent and reduce alcohol-related harm. Our message regarding alcohol consumption is that “less is better”. Eurocare cares about the Common Agricultural Policy (CAP) because it lays out support programs for the agricultural sector. One of these measures is the promotion and marketing of wine. Wine promotion subsidies are aimed primarily at increasing European wines’ competitiveness in non-EU countries through activities such as information campaigns, market studies and participation at wine fairs abroad. The CAP features two parallel schemes for wine promotion. One is regulated over Reg (EU) 1308/2013 and amounts to nearly €250 million in 2018. Another one is regulated over Reg (EU) 1144/2014 and has financed more than €22 million in wine related promotion since its inception in 2014. There is a clear trend of increasing budgets for both these schemes. These promotional measures, draining millions of euros from the EU budget, jeopardize public health, create market distortions and occasionally camouflage serious misuse of funds by the beneficiaries. Furthermore, the European Court of Auditors have questioned the role of EU grants to promote wine, citing lack of demonstrable results over the scheme’s lifetime. European agricultural policies are important tools to support farmers’ livelihood and sustainable rural development. However, EU policies must be coherent and cannot be evaluated according to economic metrics alone: Public health perspectives should always be weighed into evaluations, especially when the beneficiaries of a policy are producers of alcoholic beverages. Worryingly, the wine industry’s promotional activities heavily rely on marketing in social media that does not differentiate between youth and adult users. And so, kids and youth below legal drinking age are exposed to messages that encourage them to drink European wine. The earlier youth start drinking, the worse are the long-term health consequences. The subsidies favour Europe’s big wine producing countries: almost 90 percent of the funds are awarded to Spain, France and Italy, a situation that reinforces these countries’ grip of consumer markets. The EU should phase out this expensive market intervention, which could save at least as €1000 million per financial period (the amount that is paid in promotion subsidies to producers over a five-year period).3 Instead, the grubbing-up scheme should be reintroduced, which pays the wine farmers in cash money in exchange for permanently uprooting their vines. Unlike wine promotion subsidies, it has proven to be an effective measure in stemming the overproduction of wine. EUROCARE POSITION – LIMIT WINE PROMOTION SUBSIDIES • While we are supportive of promotional measures for agricultural products that are components of a healthy diet, wine – as a product with scientifically proven health risks – should not be considered a priority product. • In the evaluation process, public health perspectives must be taken into consideration next to the other evaluation criteria. • No promotional measures should be funded that exposes youth to alcohol marketing, particularly with the use of social media.
Read full response

Response to Europe’s Beating Cancer Plan

28 Feb 2020

Given Eurocare’s profile, comments are given to areas in which it possesses expertise, mainly the prevention pillar. Furthermore, comments are given in relation to EU’s level of action. European Commission is best positioned to suggest the adequate level of implementation taking into account subsidiarity and proportionality. As a general comment Eurocare would like to support the European Commission’s remarks regarding too little resources being allocated for prevention efforts (an average of 3% of health budgets). As stated in the document, avoiding known risks and adopting healthy lifestyles can greatly lower people’s risk of getting cancer. Eurocare agrees that prevention is the easiest and most effective way of reducing cancer in the EU. Eurocare would strongly advocate that given the burden alcohol places on people’s health and its role as a risk factor for cancer, EU should be ambitious in its actions and introduce alcohol specific legislation. While over the years EU has achieved significant progress on tobacco, it has not placed similar emphasis on alcohol. Eurocare welcomes the suggestion of the objective ‘prevent the preventable’ and specific mention of alcohol consumption in that setting. Digital tools are a welcomed development of the recent years but Eurocare would like to point out that prevention efforts can be complemented by digital tools and not primarily dependent on them. Access to digital tools relies heavily on the individual actively engaging with them, making a choice to be informed. This can result in increased knowledge disparities among EU’s citizens in terms of knowledge regarding alcohol and cancer. Eurocare would suggest allocation of resources into awareness raising efforts to increase citizen’s knowledge about alcohol as a risk factor for cancer. Healthy lifestyle changes can only come to fruition if public is aware of the risks and has environment encouraging a lifestyle change. Eurocare is pleased to see the role of taxation highlighted as potential instrument to reduce alcohol related harm. The document suggests a set of legislative and soft measures, however with regards to alcohol, Eurocare would strongly suggest considering legislative measures and widening the scope of potential actions beyond taxation, under the umbrella of a comprehensive alcohol directive. Eurocare strongly recommends for the Europe’s Beating Caner (EBC) plan to include specific measures related to prevention of alcohol-related cancers such as: - Allocation of funding for campaigns to increase awareness about the connection between alcohol and cancer. - Gathering information regarding citizens knowledge about alcohol and cancer (the latest Eurobarometer asking that question is a decade old). - Gathering information regarding prevalence of alcohol-related cancers in the EU-27, and good practice examples from Member States on methods to increase awareness and reduce prevalence (this could be part of a State of Health of the EU review series). EU should seek legislative means to enhance the current alcohol policy landscape, this could be achieved through harmonisation of currently diverging policies among Member States in areas such as: - Commercial communications, especially regarding the digital environment - Labelling of health-related messages on containers of alcoholic beverages Eurocare would suggest that EBC plan in area of prevention should built on the work and evidence generated by WHO ‘best buys’. Taking into account EU’s competences the EBC plan could contribute to achievement of the ‘best buys’ by Member States by: - Putting forward a proposal addressing EU excise duty arrangements for travellers’ purchases of alcohol - Putting forward a proposal allowing Member States to levy excise duties based on alcohol content on all categories of alcoholic beverages - Ensuring Member States retain the power to enforce national marketing restrictions (also online) on products with links to cancer
Read full response

Meeting with Anne Bucher (Director-General Health and Food Safety)

21 Oct 2019 · prevention of alcohol related harm ; Labelling of alcoholic beverages ; Monitoring of alcohol consumption in the EU ; Digital marketing of alcoholic beverages

Meeting with Vytenis Andriukaitis (Commissioner) and

22 May 2019 · Labelling of alcoholic beverages

Response to Evaluation of Regulation on reporting, analysis and follow-up of occurrences in Civil Aviation

15 May 2019

The European Alcohol Policy Alliance (Eurocare), an alliance with 55 member organisations across 23 European countries advocating the prevention and reduction of alcohol related harm. Excessive alcohol intake by air passengers has economic, medical and welfare ramifications, and is identified as a top three risk to aviation safety. Drunkenness on airplanes disrupts, causes flights to be diverted, distracts the cabin crew from their normal safety duties and is a hazard in emergency evacuations. The prevalence of disruptive behaviour at airports and on airplanes due to alcohol consumption is increasing. In 2017, there was one unruly passenger incident for every 1,053 flights – higher than the 2016 incident rate of one incident every 1,424 flights. Alcohol intoxication being one of the top three risks (27%), there were 2,454 incidents of intoxicated behaviour, of which 561 involved passengers consuming alcohol they had brought on-board. The figures show a 325% rise in unruly passenger behaviour reports between 2013 and 2017. Alcohol was identified as the main cause of disruptive behaviour, with a general spike during the summer months and on routes to destinations popular with holiday makers. It was reported that in a two-year period (until March 2016) an average of four people a week were arrested on suspicion of being drunk on a plane or at an airport. One aviation security expert estimated alcohol-triggered misconduct affects around 50 flights a day worldwide. In the United Kingdom (UK), police made 387 arrests at airports and on planes in 2016, up from 255 in the previous year. The unruly passengers often have had their first drinks before arriving at the airport, continue drinking at the airport and in-flight, either by buying alcohol on board or by drawing on personal supplies. The cabin crew may experience difficulties in tracking the alcohol consumption of these individuals because drinking has started pre-flight, making it hard to foresee the tipping point of an individual passenger at which their behaviour becomes a safety threat. EU regulation on serving alcohol is lax and only contains a recommendation that airlines “shall take all reasonable measures to ensure that no person enters or is in an aircraft when under the influence of alcohol or drugs to the extent that the safety of the aircraft or its occupants is likely to be endangered”. Thus, for time being it is at each airline’s discretion to formulate and enforce its own serving policies within this broad formulation. Furthermore, passengers involved in serious disruptive events during a flight may face no charges on the ground. This is due to the multi-jurisdictional nature of air travel: Under existing international laws, while the authorities in the country of registry have jurisdiction over an incident that takes place during a flight, the authorities in the country where the plane lands are often powerless to act. The Montreal Protocol 2014 grants legal jurisdiction over these incidents to the country where the airplane lands. However, 22 countries must adopt the protocol before it comes into force; so far only twelve have done so. Better prevention could be achieved by combined efforts in a commonly agreed direction of aviation industry, bars and restaurants at airport, duty free retail and local police. Limiting the availability of alcohol is considered by the World Health Organization as one of the ‘best buys’ to address the excessive alcohol consumption and the harm that is caused by it. In the setting of air travels, it could translate into small changes as banning promotions of alcohol at the airports and on the flights, limiting the hours during which alcohol is served at airport restaurants and bars, limiting the amount of alcohol allowed to buy at the airport. Due to the international natures of the problem, we would greatly appreciate European Commission’s consultation to consider actions to solve this problem.
Read full response

Meeting with Arunas Vinciunas (Cabinet of Commissioner Vytenis Andriukaitis), Inga Preikšienė (Cabinet of Commissioner Vytenis Andriukaitis)

6 Feb 2019 · Priorities regarding alcohol related harm at EU level

Response to Evaluation of the EU agricultural promotion policy

6 Aug 2018

European Alcohol Policy Alliance (Eurocare) would like to highlight that the reformed EU’s agricultural promotion policy should ensure policy coherence with health policies, especially with regards to alcohol consumption – namely ending with promotion of alcohol under current Art 5.3 in Reg (EU) 1144/2014 • Promotional funds are a form of alcohol marketing and should not be financed by the EU. • Responsible drinking messages are ineffective and part of companies CSRs. • Alcohol can be linked to health and social problems which create a hindrance to development The overall aim of the information and promotion initiatives should be to encourage consumption of healthy products and creation of healthy lifestyles. EU agricultural promotion policy should not include a possibility to finance promotion campaigns for alcohol, especially ‘responsible consumption’ funding should be stopped. Wine and other alcoholic beverages are the third leading global risk for the burden of disease . Globally, harmful use of alcohol causes approximately 3.3 million deaths every year (or 5.9% of all deaths), and 5.1% of the global burden of disease is attributable to alcohol consumption. According to the World Health Organization (WHO), a causal relationship exists between alcohol consumption and more than 200 health conditions, including new data on causal relationships between the harmful use of alcohol and the incidence and clinical outcomes of infectious diseases such as tuberculosis, HIV/AIDS and pneumonia. Considering that beyond health consequences, the harmful use of alcohol inflicts significant social and economic losses on individuals and society at large, the harmful use of alcohol continues to be a factor that has to be addressed to ensure sustained social and economic development. While promotion funds in Reg (EU) 1144/2014 are used for marketing of alcoholic beverages, the World Health Organization is calling for marketing restrictions for alcoholic beverages to tackle the burden of non-communicable diseases . Moreover, it is well documented that ‘responsible drinking’ (consumption) messaging is used as part of the alcohol companies Corporate Social Responsibility (CSR) activities, used to shift the policy debate attention from those who manufacture and promote the products to those who consume them . It is a strategically ambiguous, industry-affiliated term allowing multiple interpretations. Industry sources rarely reference government drinking guidelines in the context of responsible drinking, instead stressing individual responsibility and risk management to protect industry interests at the expense of public health . There is no justification for the European funds to be promoting class one carcinogenic product - alcohol. The continuous support for promotion schemes for alcoholic beverages is hindering European Union’s efforts to meet the UN’s Sustainable Development Goals (SDGs) and policy coherence with other EU objectives (e.g. 2006 European Union strategy to support Member States in reducing alcohol related harm and Art 208 TFEU).
Read full response

Response to Multiannual Financial Framework - CAP Strategic Plans

2 Aug 2018

European Alcohol Policy Alliance (Eurocare) welcomes that the Proposal recognises the link between consumption and public health. However, Eurocare would like to highlight that the Proposal should better reinforce the links to health policy especially with regards to alcohol consumption – namely end with promotion of wine. The continuous support for promotion schemes in the wine sector are hindering European Union’s efforts to meet the Sustainable Development Goals (SDGs) and policy coherence with other EU objectives (e.g. 2006 European Union strategy to support Member States in reducing alcohol related harm and Art 208 TFEU) Alcohol can be linked to health and social problems which create a hindrance to development. For the EU to be promoting wine marketing campaigns in third countries outside the EU (including many of the developing countries) is unethical and can be in direct opposition to its commitments to SDGs and Art 208 TFEU. This unprecedented EU-funded propping up of advertisement for a single product which is classified as class one carcinogen creates a gross dissonance with the CAP notion of providing a stable supply of “safe food”. As recognised by the European Commission itself, alcohol related harm is a major public health concern in the EU accountable for over 7% of all ill health and early deaths . ‘Responsible drinking’ messaging (e.g. ‘Drink [product] Responsibly’) which is suggested under Art 51 (g) and Art 52 (g), are a well-documented part of companies’ corporate social responsibility (CSR) activities. It is a strategically ambiguous, industry-affiliated term allowing multiple interpretations. It stresses individual responsibility and risk management to protect industry interests at the expense of public health by shifting the attention from those who manufacture and promote the products to those who consume them . Some studies point out that young people shown ‘responsible drinking’ messages viewed them as glamorising alcohol consumption among young adults, and as being similar to marketing . There is no justification for a special treatment of the wine industry. The EU should seize the opportunity and end with the ‘special case’/ ‘specificity’ of the wine sector. In the current political climate, the EU should set an example of anti-protectionism and not provide further protection for one interest group (wine producers). In promotional funds alone, this could provide savings of around 262 499 000 EUR a year. To conclude, health is a public interest worthy of consideration in development and implementation of all EU’s policies. To work towards achieving that objective, the current proposal should delete the possibility of marketing wine through CAP. Articles: 51 (g), 52 (g) and (h) should be deleted.
Read full response

Meeting with Vytenis Andriukaitis (Commissioner) and

9 Feb 2018 · Action on alcohol and health

Response to Evaluation of the CAP measures applicable to the wine sector

6 Dec 2017

European Alcohol Policy Alliance (Eurocare) welcomes the forthcoming evaluation of CAP measure applicable to the wine sector and would like to draw the European Commission’s attention to some elements in its Fitness Check Roadmap. As a general comment Eurocare would like to highlight that public health perspective is entirely missing from the proposed objectives and scope of the evaluation. Eurocare understands that the primary target group and stakeholders for DG AGRI are the wine producers. However, taking into account the European Union’s commitment to the Sustainable Development Goals (SDGs) we consider lack of public health perspective detrimental to the policy coherence of the European Union’s actions. SDG 3.5 requires the EU to strengthen prevention and treatment of substance abuse, including narcotic drug abuse and harmful use of alcohol. Wine, similarly to beer or spirits is an alcoholic beverage, therefore any CAP measures applicable to the wine sector need to consider their impact on public health. Firstly, Eurocare urges DG AGRI to include impact on public health as one of the evaluation focus areas next to already listed: agricultural income, market balance including marketability and marketing standards, quality as well as competitiveness etc. Public health should be one of the objectives vis-à-vis which CAP policy instruments applicable to wine sector will be measured. Secondly, with regards to efficiency, the evaluation should include detailed assessment of the usage of promotional funds. The promotion funds are used for advertising of wine, while the World Health Organisation is calling on advertising restrictions for alcoholic beverages to reduce alcohol-related harm. Continuing with the wine promotion scheme could run in opposition to the EU efforts to fulfil SDGs. Furthermore, 2014 European Court of Auditors questioned the role of EU grants for promotion of wines. Therefore, it appears natural for the evaluation of the CAP measures applicable to the wine sector to address this area of concern. In terms of the consultation strategy, the roadmap mentions that internet-based consultation will be in relation to the ‘practical experience with the implementation’ this indirectly limits to scope for participation. Some interest groups might not have practical experience but would like to contribute to the consultation. We would encourage the DG AGRI to provide internet-based consultation for all interested stakeholders not merely those with practical experience. As mentioned above the focus of the consultation should be not merely on farm income, competitiveness, market balance and product quality but also its impact on society, particularly public health (page 2 last sentence). Finally, any effort made in the evaluation of the CAP measures under point 5 of the context (Smooth functioning of the internal market, through labelling rules that take into account legitimate interest of consumers and producers) should ensure that it does not jeopardise the work undertake in DG SANTE, in the framework of EU (Reg) 1169/2011. We trust that the forthcoming evaluation for CAP measures applicable to the wine sector will take into account policy coherence and greater framework of agri sector need to reform. There is no justification for a special treatment for wine industry. The EU should seize the opportunity and end with the ‘special case’ ‘specificity’ of the wine sector. In the current political climate, the EU should set an example of anti-protectionism and not provide further protection for one interest group (wine producers). In promotional funds alone, this could provide savings of around 262 499 000 EUR a year. For more information please contact: Mariann Skar Secretary General Eurocare Rue Archimede 17 1000 Brussels, Belgium Tel +32 (0)2 732 67 82 GSM +32 (0)47 4830041 E-mail: Mariann.Skar@eurocare.org
Read full response

Meeting with Vytenis Andriukaitis (Commissioner) and

7 Jun 2017 · Action to address alcohol abuse and harm that it causes

Response to General arrangements for excise duty – harmonisation and simplification

10 Apr 2017

European Alcohol Policy Alliance (Eurocare) welcomes the revision of the Directive 2008/118/EC and would like to draw the European Commission’s attention to some elements in its Inception Impact Assessment. Apart from the issues identified in the Evaluation report (Evaluation of current arrangements of the holding and moving of excise good under excise suspension) we would like to urge European Commission in the REFIT to address the issue of private acquisition of alcoholic beverages (Art 32). The general objectives list safeguarding revenue of Member States. Collection of excise duties is a major source of revenue for the Member States. Nevertheless almost 99% of all intra-EU movements of excise duties goods take place under suspension of excise duty, amounting to associated excise duty of EUR 90 billion. If some of that suspension was lifted it can be argued that this would allow Member States to collect higher excise duties. From the public health perspective price and availability of alcohol are key policy areas recommended by World Health Organisation to reduce alcohol related harm. Currently, European region is the heaviest drinking region in the world. Hence, we would like to encourage the European Commission to revise the quotas, also to ensure policy coherence of the European Institutions. Taking public health perspective into account could allow for the revised Directive to even better met the general objective of safeguarding the budgetary interests of the Member States by increasing income from excise duties on alcoholic beverages. Furthermore, we find it surprising that the European Commission did not identify any likely social impacts in the Inception Impact Assessment (point C, page 3). The World Health Organization points to affordability and availability of alcohol as one of the main factors influencing alcohol consumption. The REFIT aims to harmonise and simply provisions for the export, import and transit of excise duties. It can be assumed that these changes will consequently have an impact on the availability and price of alcohol. This in return is highly likely to have an impact on health and other social aspects. As a case in point, in 2004 Finland reduced its excise duties by a third on average, in an effort to prevent people travelling to Estonia to purchase alcohol. This led to an increase in alcohol consumption and a substantial increase in deaths from alcohol attributable diseases. Deaths from liver disease rose by 46%, rates of hospitalization, alcohol poisoning and alcohol dependence were also higher as a result of the change. To ensure the proper functioning of the internal market and also to allow Members States to use fiscal policy tools for public health outcomes, the personal quotas should be addressed in the REFIT. Furthermore, there is a strong potential for cross-border movement through private acquisitions to contribute to tax evasion and this point should be consulted upon. Finally, we strongly agree with the objective to strengthen the fight against fraud and tax evasion, and would suggest that REFIT places more emphasis on the issue of denatured alcohol and coherence with Directive 92/83/ECC, Art 27 (1)(a). The REFIT should result in clarification of terms and harmonisation of the categorisation of the denatured alcohol, in alliance with 92/83/ECC.
Read full response

Meeting with Vytenis Andriukaitis (Commissioner) and

2 Mar 2017 · Towards a renewed EU Alcohol and Health Forum

Meeting with Vytenis Andriukaitis (Commissioner) and

6 Dec 2016 · Action to prevent alcohol abuse and address alcohol-related harm, the Alcohol Forum

Meeting with Xavier Prats Monné (Director-General Health and Food Safety)

18 Nov 2015 · alcohol related harm issues

Meeting with Vytenis Andriukaitis (Commissioner) and

2 Jul 2015 · alcohol policy

Meeting with Robert Madelin (Director-General Communications Networks, Content and Technology)

16 Apr 2015 · Mariann Skar, Lauri Beekmann, Claude Riviere and Aleksandra Kaczmarek from Eurocare