European Association for the Study of the Liver
EASL
EASL is a medical association dedicated to pursuing excellence in liver research, clinical practice of liver disorders, and in providing education to all those interested in hepatology.
ID: 597006135119-96
Lobbying Activity
Response to Evaluation of the rates and structures of excise duty on alcohol and alcoholic beverages
4 Jul 2022
The European Association for the Study of the Liver (EASL) aims to be the Home of Hepatology so that all who are involved in treating liver disease can realise their full potential to cure and prevent it. EASL welcomes the European Commission's evaluation of excise duty rates and tax structures on alcoholic beverages.
According to the Global Burden of Disease, 1,256,900 deaths occurred worldwide due to liver disease in 2016, of which 334,900 (27%) were attributable to alcohol. Additionally, 245,000 liver cancer deaths were associated with alcohol intake (30% of all liver cancers deaths). In Europe, from the 35 countries included in the HEPAHEALTH report, there were 38,378 deaths in the last year available (2012-2015) that were coded as alcohol-related liver disease. The liver disease accounts for significant health and economic losses, as two-thirds of potential years of life lost are working years. Furthermore, of these 35 European countries, 32 have experienced increasing prevalence in levels of cirrhosis since 1990. Liver mortality is largely determined by population alcohol consumption, with a direct correlation seen between overall alcohol consumption and liver mortality in 21 of 28 European Union (EU) member states.
Affordability of alcohol is one of the key factors that impact alcohol consumption. Any type of measures implemented to control or affect the prices and affordability of alcohol can reduce alcohol consumption and therefore harm. In the context of a competitive market, alcohol consumption is negatively correlated with price, meaning that as price increases, consumers will reduce their consumption. Evidence suggests the control of alcohol marketing must be the responsibility of governments, independent of the alcohol industry, monitored by governments and civil society interested in Public Health.
EASL wants to emphasize that the main priority of the ongoing evaluation should be to implement a tax structure that promotes and protects public health and not the interest of the alcohol industries thus, facilitating Member States' abilities to implement the most efficient tax structure to reduce alcohol consumption and alcohol-related harm.
As outlined in the EASL - Lancet Liver Commission, European governments must introduce uniform and effective policies to reduce the harmful use of alcohol; specifically, EASL recommends that a minimum price of €1/cL of pure alcohol (MPC) is introduced across all countries of the EU and associated countries and that the MPC is accompanied by appropriate increases in alcohol taxation to ensure that any MPC windfall to retailers is returned to government finances.
Further, we would like to stress the following points:
• Consider a minimum price per alcohol gram, such that the minimum price of sale of an alcohol product (C) is calculated by multiplying the minimum price for alcohol per gram (A) with the amount in grams of the alcohol product (B): A x B=C. As an example, in Scotland this price was set on 50 pence, but it can be different in each country.
• Excise taxes and minimum unit price should be regularly reviewed and revised upwards appropriately according to inflation and the observed effects on the rate of alcohol consumption and alcohol-related harms
Read full responseResponse to Cancer Screening Recommendation
22 Feb 2022
The European Association for the Study of the Liver (EASL) recommends extending the Recommendation to liver cancer for high-risk groups living with chronic liver diseases; these patients are identifiable, have a high risk of liver cancer, and can be offered curative treatment if their liver cancer is diagnosed early. Furthermore, liver cancer detection tools are easily available and affordable - Find the full EASL response enclosed.
Liver cancer is a broad public health concern: Liver cancer and chronic liver disease go hand in hand, and 90% of patients with liver cancer have underlying chronic liver disease. Mortality from liver cancer has increased in most European countries since 1980 due to our failure to stop the tide of chronic liver disease resulting mainly from viral hepatitis, non-alcoholic fatty liver disease (NAFLD/NASH), and harmful alcohol consumption. Liver cancer is now the sixth-most common cancer and the third-most frequent cause of cancer-related death globally, and it has become a major health burden in the European Union. In 2019, 87,000 Europeans were diagnosed with liver cancer, and 78,000 died from liver cancer. That number—78,000 dead Europeans—is 70% higher than what it was in 1990. To make matters worse, liver cancer is more common in deprived areas and therefore contributes to inequity in health. A do-nothing scenario will result in an increased burden of liver cancer in Europe over the next decade. By contrast, South-East Asia has demonstrated that screening and other preventive measures effectively reduce the burden of liver cancer. In other countries, such as the United States, liver cancer screening in patients with chronic hepatitis B has also been shown to reduce mortality.
Survival is improved by early diagnosis: Liver cancer has the poorest survival of all cancers monitored by the Joint Research Centre. Detection of liver cancer at an early stage could reduce mortality to a maximum of 5 years of life lost relative to the general population, but unfortunately, more than 60% of patients with liver cancer in Europe are diagnosed at the more advanced, intermediate, or advanced stages. This is in contrast to Japan, where more than 60% of these patients are now diagnosed at the early stage, and 5-year survival has improved from 5.1% in 1978–1982 to 42.7% in 2003–2005. These improvements are attributed to the establishment of the screening system, advances in diagnostic imaging, and therapeutic technologies. This makes a strong case for liver cancer screening in Europe. We look with envy to the South-East Asian high-income countries whose massive liver cancer screening programmes have resulted in better survival. Europe must take this as an example and promote screening for liver cancer.
High-risk populations for liver cancer are well known: Liver cancer develops in people with chronic liver disease, often in those with advanced-stage characterized by the presence of cirrhosis. Chronic liver disease is almost universally caused by viral hepatitis, non-alcoholic fatty liver disease, and/or harmful alcohol consumption. Patients with one or more of these risk factors are the high-risk populations for liver cancer. Many of them are already followed in an outpatient or primary care setting for their cirrhosis, and it is straightforward and feasible to implement a recommendation of liver cancer screening in these patients. The patients who are not followed must be identified and offered screening and linkage to healthcare. Screening for liver cancer is done with an ultrasound examination of the liver with or without a blood test for alpha-fetoprotein (AFP) every 6 months. General practitioners, hepato-gastroenterologists, and patients must be informed about this key screening practice.
The find full EASL response is enclosed.
Read full responseResponse to Revision of Food Information to Consumers for what concerns labelling rules on alcoholic beverages
22 Jul 2021
The European Association for the Study of the Liver (EASL) welcomes the revision of rules on information provided to consumers for alcoholic beverages and the efforts of the European Commission towards more standardized labelling requirements of alcoholic beverages in the European Union. EU citizens merit to have informed choices, thus EASL supports the efforts towards decrease alcohol-related harm by improved labelling rules on alcoholic beverages and looks forward to future consultation activities.
Alcohol consumption and liver diseases, including liver cancer:
According to the Global Burden of Disease, 1,256,900 deaths occurred worldwide due to liver disease in 2016, of which 334,900 (27%) were attributable to alcohol. Additionally, 245,000 liver cancer deaths were associated with alcohol intake (30% of all liver cancers deaths). In Europe, from the 35 countries included in the HEPAHEALTH report, there were 38,378 deaths in the last year available (2012-2015) that were coded as alcohol-related liver disease. The liver disease accounts for significant health and economic losses, as two-thirds of potential years of life lost are working years, which contrasts with other chronic diseases where onset and death generally occur at a later age. Furthermore, of these 35 European countries, 32 have experienced increasing prevalence in the levels of cirrhosis since 1990.
People with cirrhosis are at higher risk to develop liver cancer, up to 1/3 will develop Hepatocellular carcinoma (HCC- the most common liver cancer) during their lifetime and 90% of HCC cases in Western countries have a cirrhotic background. Liver cancer is a global health burden with an estimated 905 677 new cases in 2020, it is the sixth most common cancer and the third leading cause of cancer death. The cancer risk associated with alcohol is poorly understood by the public. It is important to increase alcohol harm awareness and people must reduce alcohol consumption. We must reach the same awareness for alcohol-related cancers risk as is reached for tobacco use today.
EASL supports option 2 in the Inception Impact Assessment:
Effective policy on alcohol to reduce alcohol consumption may reduce liver mortality quickly, as well as alcohol-attributable cancers, as patients with alcohol-related liver disease (ARLD) usually die from acute-on-chronic liver failure driven by recent excessive alcohol consumption. It is a consumer right to receive information about adverse health effects from foodstuffs, yet alcohol is exempt from this regulation, despite being a level one carcinogen.
To foster more informed consumer behaviours in respect to alcohol consumption, the European Association for the Study of the Liver (EASL) supports the European Commission’s intention to review its Regulation 1169/2011, as to include additional labelling information regarding different health warnings such as health information aiming to inform the public of the risks of alcohol consumption, including cancer and risks consumption during pregnancy, drinking, and driving, information regarding the caloric value expressed in Kilojoules and Kilocalories. This should include ensuring that alcohol packaging displays a complete list of ingredients for all alcoholic beverages including those whose alcohol by volume is above 1.2% which are now exempted.
Therefore, the European Association for the Study of the Liver (EASL) supports Option 2: “Revise the rules for all alcoholic beverages: revoke the exemption and require all indications on-label".
Read full response8 Mar 2021
EASL position on alcohol products:
Alcohol is the most dangerous commodity marketed in Europe, second only to tobacco, whose marketing is more heavily regulated.
A systematic review of longitudinal studies found an association between youth exposure to alcohol marketing and drinking behaviour. The European Commission concluded that marketing leads children to drink at an earlier age and drink more. In general, alcohol marketing causes more harm to vulnerable populations, including children, adolescents, and those with alcohol dependence.
EASL recommend that countries should move towards a comprehensive ban on alcohol advertising, promotion and sponsorship. Self-regulation by the alcohol industry is not effective, and regulations should be statutory as there is strong evidence that the alcohol industry has been successful in preventing implementation of effective policies, and in circulating misleading information to the public. Evidence suggests the control of alcohol marketing must be the responsibility of governments, independent of the alcohol industry, monitored by governments and civil society interested in Public Health.
Recommendations:
EASL suggests a National Alcohol Program to be implemented in each EU country that should include:
• Increase the price of alcohol through increases in excise taxes and other pricing policies.
• Consider a minimum price per alcohol gram, such that the minimum price of sale of an alcohol product (C) is calculated by multiplying the minimum price for alcohol per gram (A) with the amount in grams of the alcohol product (B): A x B=C. As an example, in Scotland this price was set on 50 pence, but it can be different in each country.
• Excise taxes and minimum unit price should be regularly reviewed and revised upwards appropriately according to inflation and the observed effects on the rate of alcohol consumption
and alcohol-related harms.
Labelling of alcohol products and notices in licensed premises:
Implement mandatory labelling of the alcohol products, including:
• Health information aiming to inform the public of the risks of alcohol consumption, including cancer and risks consumption during pregnancy.
• Information regarding the caloric value expressed in Kilojoules and Kilocalories
Regulation of advertising and sponsorship of alcohol products:
• Effective legislation to protect children and young people from the deleterious effects of alcohol marketing, including:
• Regulating sponsorship activities that promote alcoholic beverages
• Restricting or banning promotions in connection with activities targeting young people
• Regulating new forms of alcohol marketing techniques, for instance social media
• The above should be monitored by public health bodies who will uphold consistent enforcement and accountability. Self-regulation by the alcohol industry is not an appropriate tool to address alcohol marketing.
EASL Conclusions and recommendations on food products:
• Promoting water consumption instead of SSBs by making drinking water easily accessible to children and adults in public facilities including parks, playgrounds, schools, and worksites.
• Promoting population-based policies to restrict advertising and marketing of SSBs and industrially processed foods high in saturated fat, sugar and salt to children.
• Implementing fiscal measures for SSBs, as well as implementing fruit and vegetables subsidies.
• Using legislation to ensure that the food industry improves the composition (reformulation) of processed foods (e.g. reducing trans and saturated fat, sugar and salt content).
• Mandating nutritional labeling, in particular “traffic light labeling”, as well as labeling of calories on menus of fast food restaurant.
• Emphasizing the benefits of diets such as the Mediterranean
Read full response