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European Public Health Alliance

EPHA

The European Public Health Alliance is a leading non-profit advocating for equitable health solutions and improved public health across Europe.

Lobbying Activity

European Public Health Alliance urges EU to restore NGO funding

4 Sept 2025
Topic — A new framework to strengthen engagement and protect civil society across Europe.
Message — The alliance calls for multi-annual operating grants and recognition of advocacy as eligible for support. They also seek a binding agreement to ensure meaningful participation in decision-making.12
Why — Restored funding would ensure long-term sustainability and independence for health advocacy groups.3
Impact — Commercial interests would lose their dominant influence over high-level European policy meetings.4
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Meeting with Tilly Metz (Member of the European Parliament) and Health Care Without Harm Europe

1 Sept 2025 · AMR Interest Group

Health alliance urges EU to redirect subsidies from harmful products to cardiovascular prevention

18 Aug 2025
Topic — New EU plan to reduce cardiovascular disease through prevention, screening, and treatment.
Message — The organization requests accelerated implementation of Europe's Beating Cancer Plan measures relevant to cardiovascular health, including legislative action on tobacco control and marketing of unhealthy products. They call for phasing out EU subsidies for harmful products like alcohol, tobacco, ultra-processed foods, and fossil fuels, redirecting resources to health-promoting measures. They urge establishment of an EU Expert Group on Climate and Health to integrate cardiovascular prevention into environmental and urban policy.123
Why — This would align EU spending with public health goals and eliminate contradictions in current policy.45
Impact — Tobacco, alcohol, ultra-processed food, and fossil fuel industries lose EU subsidies and tax breaks.67
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Response to Anti-racism Strategy

8 Jul 2025

The European Public Health Alliance (EPHA), through its DisQo anti-discrimination & health equity network, welcomes the opportunity to contribute to the development of the next EU Anti-racism strategy. As civil society organisations and stakeholders working closely with marginalised and/or racialised communities, particularly people of African descent (PAD), we affirm that racism - systemic, institutional, and interpersonal - continues to undermine the right to health across Europe, evidenced by epidemiological data (e.g. disparities in prostate/breast cancer outcomes). Based on co-creation with the DisQo network, six priorities where the European Commission could take increased action and/or a leadership role are summarised below. 1. Recognise racism and discrimination as fundamental determinants of health Explicitly name racism and racial discrimination as root causes of health inequities in EU policies, legislation, and training curricula. Strengthen the Racial Equality Directive (2000/43/EC) to protect the right to health and penalise racism in healthcare, to better protect health rights and support legal enforcement mechanisms. Prioritise research funding on racisms health impacts (e.g., mental/physical effects of prolonged discrimination). Highlight disparities in late diagnosis and disease incidence (e.g., higher prostate cancer rates in Black men) as evidence of systemic inequities. 2. Meaningful involvement of affected communities and experts Involving civil society in every phase of policy design, implementation, and monitoring. Empowering affected communities and ensuring they have the skills, funding, and agency to engage in policymaking Enabling meaningful (social) participation across EU institutions and healthcare systems, not only in frontline roles but also in leadership and governance. Mandating participatory frameworks for all health programs, ensuring marginalised groups lead design/evaluation. 3. Respectful and inclusive language Developing an EU glossary of key terms (e.g., racism, health equity) via participatory consultation. Harmonising fragmented definitions across DGs and agencies to ensure consistency and safe dialogue. Addressing stigma in health communications and train providers on culturally sensitive terminology. 4. Disaggregated equality data Leading the harmonisation of intersectional equality data collection (ethnicity, migration status, health outcomes). Funding community-led data initiatives (e.g., Afrozensus) and ethical digital tools (e.g., Dutch G4 analysis tool). Guiding member states on human rights-aligned data practices, including health-specific indicators. 5. Breaking down silos and taking action Mainstreaming anti-racism across sectors via the Task Force on Equality, with an intersectional focus. Promoting national best practices (e.g., National Anti-Racism Coordinators) and standardise anti-discrimination laws. Advocating for coordinated national anti-discrimination laws to enable standardised equality data collection. 6. Addressing racism in healthcare and science Shifting from race-based to race-conscious medicine (e.g., eliminate biased clinical standards). Diversifying health research (e.g., inclusive clinical trials) and workforce representation (especially in leadership). Mandating cultural competency training and improve access (e.g., language services, trauma-informed care). Requiring equity plans in health funding (e.g., ethics approvals contingent on inclusive recruitment). To ensure impact, the next EU Anti-Racism Strategy should embed health equity as a core part of efforts to combat racism and promote inclusion. This includes recognising racism as a health determinant, addressing disparities through coordinated, inclusive policies, and ensuring meaningful representation and accountability. Developed with affected communities, these priorities should guide a rights-based, cross-sectoral strategy that delivers tangible progress.
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Meeting with Sandra Gallina (Director-General Health and Food Safety) and

10 Jun 2025 · Cooperation in the context of the EU4Health Programme

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

26 May 2025 · Exchange of views

Meeting with Christophe Hansen (Commissioner) and

30 Apr 2025 · Sustainable Protein Diversification for the Vision

Meeting with Alisa Tiganj (Cabinet of Commissioner Christophe Hansen) and Bureau Européen des Unions de Consommateurs and

25 Feb 2025 · Vision for Agriculture & Food Exchange of views on the Vision on agriculture and food, in particular aspects related to the “food” aspects.

Meeting with Maria Walsh (Member of the European Parliament)

6 Feb 2025 · Women's Health Strategy

Meeting with Peter Liese (Member of the European Parliament) and Eurogroup for Animals and

29 Jan 2025 · Austausch

Meeting with Ricard Ramon I Sumoy (Acting Head of Unit Agriculture and Rural Development) and Bureau Européen des Unions de Consommateurs and

28 Jan 2025 · Exchange of views on issue considered relevant by the organisations on the Vision of agriculture and food, under preparation; in particular the food aspects.

Meeting with Stine Bosse (Member of the European Parliament, Committee chair)

20 Sept 2024 · European

Response to Assessing the implementation of the Member States' national Roma strategic frameworks

2 Feb 2024

The European Public Health Alliance (EPHA) coordinates the Roma Health Network, which brings together organisations and researchers that work with Roma communities on the social determinants of health. Using the hands-on experience and expertise of its members, the Network has reviewed and monitored the EU Roma Strategic Framework with a focus on Roma health. In the Networks view, cooperation with the Roma Coordination Team has improved in 2023, but direct engagement with civil society has decreased with clear effects on the national level, where progress is still stagnating and where the paper reality in the strategies does not translate to progress on the ground. Though the increasing discussion on the effects of structural racism and antigypsyism is welcome, it has not yet translated to an improvement in Roma health. A cross-sectoral and structured approach to antigypsyism is still generally lacking in the National Roma Strategic Frameworks (NRSF). In relation, the increased focus on the housing situation in Roma communities is welcomed, but focus should not be taken away from health and the other social determinants of health in the NRSFs. FRA data shows that the average life expectancy is still 10 years lower for Roma compared to non-Roma, while experiences of discrimination in healthcare have increased from 8% to 14% on average. This shows that the 2030 goal of cutting the life expectancy gap is increasingly moving out of reach. Based on the experience of the Network members overarching issue were identified. EU Member States should; 1. increase their focus on health in the NRSF, not instead of other sectoral focuses, but in addition to them; 2. reduce Roma health inequities by recognising and addressing antigypsyism in a more cross-cutting and cross-sectoral way in the strategies; 3. make it easier to attain medical cards/registration numbers without requiring identification documentation to improve access to essential services; 4. significantly increase engagement with Roma (health) civil society in the development of the NRSF and with the National Roma Contact Points, empowered through more easily accessible funding; 5. foster exchange between Roma and pro-Roma (health) civil society to ensure capacity building conscious to the needs of individual Roma communities. Accession country members are particularly concerned about the lack of transparency in the development of the NRSF, unclear definition of activities, the lack of clear indicators, use of incorrect terminology and an unclarity about who is responsible for their Roma inclusion strategy in general. More specifically to health, a lack of capacity has led to a lack of coverage of key topics necessary to ensure Roma health equity. The NRSF should include measures focusing on; mental health and mental health literacy programs; cultural awareness or cultural competence training and awareness-raising activities on Roma culture and history to prevent prejudice in healthcare (as well as employment, housing and education); digital health literacy programs; empowering healthcare activities for Roma women (focusing on early/forced marriage, early pregnancy and reproductive health); health promotion activities; reducing dangerous working conditions. EPHA and the Roma Health Network would like to once again call attention to the recommendations of its paper titled Roma Health and Housing: Filling in the Gaps A Policy Paper by the Roma Health Network, included in the attachment to this response, whose recommendations remain relevant; 1. commit to using health and housing indicators for monitoring; 2. setting up of health advocacy schemes; 3. taking a psychosocial approach to mental health; 4. expand housing strategies with a health impact assessment; 5. focus more on Roma environmental justice.
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Health Groups Urge Strict Air Quality Standards for Boiler Rules

15 Dec 2023
Topic — EU review of energy efficiency and ecodesign requirements for solid fuel boilers.
Message — Health organizations request direct involvement in product policy decisions, alignment of health and climate policies, and phasing out coal-based appliances. They emphasize testing methods must reflect real-life use and social equity dimensions need consideration.1234
Why — This would reduce health harms from air pollution caused by biomass burning.56
Impact — Low-income households using solid fuel lose access to economical heating options.78
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Health groups urge stronger protections in solid fuel heater regulations

14 Dec 2023
Topic — EU review of ecodesign requirements for solid fuel local space heaters and emissions.
Message — The organizations request direct health community involvement in product policy decisions, alignment of health and climate goals, and phase-out of coal-based appliances. They emphasize stricter air quality standards and real-life testing methods that reflect actual usage conditions.1234
Why — This would strengthen their advocacy for Health in All Policies and reduce air pollution health impacts.56
Impact — Low-income households face continued health risks from inadequate heating options and poor indoor air quality.78
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Meeting with Tilly Metz (Member of the European Parliament) and European Patients' Forum (EPF) and

10 Oct 2023 · Pharma Package

Meeting with Catherine Amalric (Member of the European Parliament, Shadow rapporteur) and European Federation of Pharmaceutical Industries and Associations and France Assos Santé

18 Sept 2023 · Reform of the EU pharmaceutical legislation

Meeting with Erik Poulsen (Member of the European Parliament, Rapporteur) and European Thrombosis and Haemostasis Alliance

31 Aug 2023 · NCD

Meeting with Milan Brglez (Member of the European Parliament, Shadow rapporteur)

13 Jun 2023 · Staff level meeting on the measures in support of children and their families

Response to Implementation of the EU anti-racism action plan

1 Jun 2023

The European Public Health Alliance (EPHA) submits this response on behalf of the DisQo anti-discrimination & health equity network, currently listing +60 members/supports. The network recognises racism and discrimination as Fundamental Determinants of Health. Despite the increasing evidence showing that structural, institutional, and interpersonal racism and discrimination aggravate physical and mental health inequities, the issue has gained too little attention in the public health domain including in EU health policy. DisQo actively supports and promotes the EU anti-racism action plan and other EU anti-discrimination strategies for a Union of Equality and praises the momentum created over the past three years. This momentum, however, is not equally spread across the EU and across sectors, which is illustrated by the delayed submission of many national action plans against racism (NAPARs), paired with a lack of civil society consultation. Although the action plan includes measures across a range of policy areas, it has not yet resulted in tangible actions or commitments in the EU HEALTH policy domain for which it states specific policies and initiatives. For example, the EU4Health programme does not mention race, racism or discrimination once, while its 2023 work programme mentions discrimination twice in the context of cancer screening, in a non-prominent place. Consequently, no funding has been allocated to address the issue. Also, the EU Health Policy Platform has not introduced a specific focus on reducing inequalities based on racial or ethnic origin and has not (to our knowledge) pass[ed] on proposals from civil society to the EU and national level health policy makers. DG SANTE did, however, support the proposal for the DisQo network, and at the time of writing this Call for evidence, the network is waiting for a formal response to its Joint Statement, offered to DG SANTE on 23 May 2023. The anti-racism policy mainstreaming across Commission DGs and Agencies is so far insufficiently coming off the ground and/or insufficiently visible. DisQo proposes more transparency and stronger civil society engagement, including for the Task Force on Equality, whose actions would benefit from being more transparent. Addressing racism and discrimination as a fundamental determinant of health and well-being requires a holistic approach. Based on reflections and exchanges within the DisQo network (Nov 2022 - Apr 2023) a Joint Statement was developed, describing 5 key priority areas to address racism and discrimination for increasing equity in health. Each priority states DisQos commitments and identifies areas where the European Commission could take increased action and/or a leadership role. These priorities are briefly mentioned below and attached as a pdf this Call for evidence. 1. Recognition: Racism and discrimination are fundamental determinants of health and should be recognised as such, across the Commission, in the NAPARs, and in calls for EU funding. 2. Social Participation: Participation of stakeholders is a crucial driver of health equity and should be at the core of decision-making processes, following the Better Regulation guidelines. 3. Language: Harmonisation is needed for definitions for racism, discrimination and health equity as they are currently fragmented. These are crucial to facilitate safe spaces for inclusive and respectful dialogue. 4. (Health) Equality Data: If you cant measure it, you cant fix it. More, and better use of existing, (health) equality data, disaggregated by indicators on multiple grounds of discrimination, is needed, as well as and harmonised EU data collection. 5. Breaking silos: Racism and discrimination are deeply rooted and require action and the breaking down of silos across sectors and at all levels: strengthened policy mainstreaming, increased transparency (including for the Task force on equality), and social participation.
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Health Alliance Calls for EU Gas Stove Ban

30 May 2023
Topic — Review of EU ecodesign and energy labelling requirements for cooking appliances.
Message — The organization requests strict nitrogen dioxide emission limits and a phase-out of gas cooking appliances. They argue gas stoves cause over 700,000 paediatric asthma cases in the EU and expose households to pollution exceeding WHO guidelines multiple times weekly.123
Why — This would advance their public health mission by reducing indoor air pollution affecting vulnerable populations.45
Impact — Gas appliance manufacturers lose market access as fossil-fuel powered cooking products are phased out.67
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Meeting with Ilan De Basso (Member of the European Parliament) and Save the Children Europe and

30 May 2023 · Möte

Health Alliance Urges Ambitious EU 2040 Climate Target

19 May 2023
Topic — Setting EU greenhouse gas emission reduction target for 2040 toward climate neutrality.
Message — The organization requests immediate, rapid, deep emission reductions beyond current Green Deal commitments. They call for strong accountability frameworks, social participation, and political commitment. Climate goals should prioritize marginalized populations and integrate Sustainable Development Goals principles.1234
Why — This would advance their mission to protect public health through climate action and health co-benefits.56
Impact — Disadvantaged groups suffer disproportionately from climate change effects, deepening health inequalities among those contributing least.78
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Meeting with Sara Cerdas (Member of the European Parliament) and ReAct - Action on Antibiotic Resistance

14 Apr 2023 · Resistência a antimicrobianos

Meeting with Margaritis Schinas (Vice-President) and

6 Mar 2023 · Pharma Strategy

Meeting with Stella Kyriakides (Commissioner) and

6 Mar 2023 · Meeting to discuss the reform of EU pharmaceutical legislation

EPHA urges EU to adopt comprehensive mental health strategy

14 Feb 2023
Topic — The European Commission is seeking input on a new initiative for mental health.
Message — EPHA urges a European Mental Health Strategy with a clear timeline, budget, and monitoring framework. It seeks a psychosocial approach addressing social determinants like poverty and discrimination in all policies. The initiative must also include commercial controls on alcohol pricing and marketing.123
Why — This proposal would expand the influence of health NGOs across multiple non-health policy domains.4
Impact — The alcohol industry faces stricter commercial controls on their pricing and marketing practices.5
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Meeting with Javi López (Member of the European Parliament, Rapporteur) and European Environmental Bureau and

23 Jan 2023 · Revision of the Ambient Air Quality Directives

Meeting with Sara Cerdas (Member of the European Parliament) and GLOBAL HEALTH ADVOCATES and

20 Jan 2023 · COVI Committee hearings and report

EPHA demands strict antimicrobial standards for animal product imports

1 Jan 2023
Topic — A consultation on banning specific antimicrobials in animals and products imported to Europe.
Message — EPHA insists that imported food products mirror the antimicrobial standards used by EU farmers. They demand a verification system with sanctions for countries failing traceability audits.12
Why — Stricter rules protect public health by reducing global resistance and lowering healthcare costs.3
Impact — Non-EU producers lose market access if they cannot verify their antimicrobial standards.4
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Meeting with Annukka Ojala (Cabinet of Commissioner Stella Kyriakides) and Eurocities and

16 Dec 2022 · VTC Meeting: Sustainable Food Systems/Procurement

Meeting with Tilly Metz (Member of the European Parliament) and Bureau Européen des Unions de Consommateurs

14 Nov 2022 · Health

Meeting with Renaud Savignat (Cabinet of Commissioner Jutta Urpilainen) and OXFAM INTERNATIONAL EU ADVOCACY OFFICE and

9 Nov 2022 · Global Health Strategy

Meeting with Sara Cerdas (Member of the European Parliament)

2 Nov 2022 · Incentivos para a indústria em AMR na legislação farmacêutica

Meeting with Petros Kokkalis (Member of the European Parliament, Shadow rapporteur)

13 Oct 2022 · Ambient Air Quality Directives

Meeting with Sara Cerdas (Member of the European Parliament)

12 Oct 2022 · Rotulagem de bebidas alcóolicas

Meeting with Stella Kyriakides (Commissioner) and

21 Sept 2022 · Rare diseases

European Public Health Alliance demands comprehensive outdoor smoking bans

20 Jul 2022
Topic — Revision of EU recommendation on smoke-free environments to cover emerging products and outdoor spaces.
Message — The organization requests harmonization of smoke-free laws in outdoor spaces including beaches, parks, and sports venues, extension to emerging products like e-cigarettes, and elimination of smoking areas. They demand explicit reference to WHO FCTC Article 5.3 to prevent tobacco industry interference.1234
Why — This would strengthen their advocacy position and align EU policy with WHO Framework Convention they champion.56
Impact — Tobacco industry loses influence as Article 5.3 reference would exclude them from policymaking processes.789
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Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans) and Bureau Européen des Unions de Consommateurs and Eurogroup for Animals

12 Jul 2022 · Food security

Response to Evaluation of the rates and structures of excise duty on alcohol and alcoholic beverages

4 Jul 2022

The European Public Health Alliance (EPHA) is a leading European civil society alliance in Brussels, made up of 80 public health NGOs, patient groups, health professionals and disease groups, working to improve health and strengthen the voice of public health in Europe. EPHA welcomes the European Commission's evaluation of excise duty rates and tax structures on alcoholic beverages. It is timely and health of the European citizens should be part of the review of the upcoming exercise, as per the mandate of the EU. From EPHA’s perspective, it is essential to comprehensively fight alcohol-related harms to achieve the United Nations Sustainable Development Goals (SDGs)target to reduce by at least 10% the harmful use of alcohol by 2025. Referring to the Mission letter from Ursula von der Leyen to Commissioner for Health and Safety, December 2019, each Commissioner will ensure the delivery of the UN SDGs within their policy area as this responsibility is carried by the Commission as guardian for all EU. Affordability 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 . The overall price elasticity of alcohol demand has an average value of approximately −0.5, which means that a 1% increase in alcohol prices will yield a 0.5% reduction in its consumption. All countries in the EU levy taxes on alcohol in one form or another, although there are many that de facto do not have a tax on wine. A growing body of research demonstrates that alcohol affordability has generally been increasing in the EU because population income has increased while the relative prices of alcoholic beverages have remained generally stable or fallen. These low prices are supported not only by the relatively low alcohol excise rates, but also by the long-lasting financial support of the EU to wine producers EPHA in alignment with its members emphasises that the main priority of the ongoing evaluation should be to implement a tax structure that promotes and protects public health and facilitates Member States’ abilities to implement the most efficient tax structure to reduce alcohol consumption and alcohol-related harm. EPHA would like to call upon the Commission to the following: • Ensure that all alcohol products are taxed based on alcoholic strength and therefore depart from the current tax structure on wine and fermented beverages that is based on volume of finished product. • Raise the EU minimum tax levels on all alcoholic beverages but especially for beverages where the current minimum levels are 0 (for example wine and fermented beverages). • Index the minimum tax levels to match price developments and ensure that the minimum tax levels stay relevant over time. To conclude, as guided by WHO evidence, alcohol pricing policies and alcohol taxation are among the most effective and cost–effective measures to reduce alcohol consumption and harms, but they are also the most underutilised. Alcohol taxation is applied in most EU countries to set pricing policy, yet these taxes are often not implemented in a way that can improve the public health impact. EPHA supports the responses of its members, the European Alcohol Policy Alliance (Eurocare), European Heart Network and IOGT-NTO. EPHA calls upon the Commission to act upon its duty and review the evidence presented by EPHA and its members.
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Meeting with Marc Botenga (Member of the European Parliament)

30 Jun 2022 · Access to Health Technologies

Meeting with Marc Botenga (Member of the European Parliament)

22 Jun 2022 · Access to Health Technologies

European Public Health Alliance urges EU action on antimicrobial resistance crisis

24 Mar 2022
Topic — EU proposal to strengthen Member States' actions against antimicrobial resistance through concrete objectives.
Message — The organization requests increased public funding for antibiotic development with conditions ensuring affordability and access. They advocate for delinking R&D costs from sales revenues and avoiding monopoly extensions. They also call for more support to help Member States develop and implement National Action Plans.123456
Why — This would ensure new antibiotics remain affordable and accessible rather than restricted by monopolies.78
Impact — Pharmaceutical companies lose monopoly extensions that allow them to charge higher prices for medicines.9
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Meeting with Sarah Wiener (Member of the European Parliament) and Association Internationale de la Mutualité

3 Feb 2022 · Marketing of nutrionally poor food to children

Meeting with Stella Kyriakides (Commissioner) and WWF European Policy Programme and

31 Jan 2022 · VTC Meeting on the framework legislation on sustainable food systems

Meeting with Annukka Ojala (Cabinet of Commissioner Stella Kyriakides), Karolina Herbout-Borczak (Cabinet of Commissioner Stella Kyriakides), Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides)

2 Dec 2021 · VTC Meeting: Sustainable food system framework initiative

Meeting with Giorgos Rossides (Cabinet of Commissioner Stella Kyriakides) and European Patients' Forum (EPF) and

25 Nov 2021 · Follow up to Cssr Kyriakides’ meeting with CSOs on 25/10/2021 on civil society funding through EU4Health

Response to Revision of Alternative Fuels Infrastructure Directive

18 Nov 2021

EPHA welcomes the European Commission’s proposal to improve the EU’s refuelling and recharging infrastructure for zero emission new vehicles. Better refuelling and recharging infrastructure are crucial to get to 100% zero emissions mobility. This proposal should ensure that European Union can meet its own Green Deal goals and improve air quality. Especially considering the consequences of the COVID-19 pandemic, the European Union needs a public health driven, green recovery to help fight the climate crisis. To this end, the European Green Deal should be strengthened to lead the European transition to sustainable mobility, including zero-emission vehicles. The proposal of regulation on improving the EU’s refuelling/recharging infrastructure will be vital in this strategy, to make sure that vehicles on European roads no longer endanger any lives due to their emissions. EPHA believes that this new regulation shall contribute to a modal shift in cities from car-based to walking, cycling, and public transport, wherever possible. These are the healthiest, the less polluting and most efficient transport options. Non-internal combustion engines should be preferred over conventional fossil fuel-powered vehicles because they are non-exhaust emission sources. For health, climate protection and environmental reasons, the vehicle emissions of air pollutants should be drastically reduced. Many pollutants emitted from automotive engines are dangerous to human health.
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Response to Proposal for a Regulation on establishing a Climate Action Social Facility

18 Nov 2021

EPHA welcomes the opportunity to provide feedback on the proposed Social Climate Fund. The Social Climate Fund is a crucial aspect of the European Green Deal. It contributes to simultaneously decarbonize and reduce air pollution by addressing the social impacts of the future inclusion of greenhouse gas (GHG) emissions from buildings and road transport in the European Union Emissions Trading System (EU ETS). Both carbon pricing and regulatory action must be complemented by subsidy programs in order to secure a socially just transition. Energy poverty of particular concern in the context of the EU ETS extension. It already represents a wide-spread problem in the EU, 34 million Europeans having reported an inability to keep their homes adequately warm in 2018. Energy poor households often use inefficient or more polluting forms of energy, which can contribute to poor mental and physical health. These vulnerable households must be protected and supported through temporary direct income support and through investments. Especially considering the consequences of the COVID-19 pandemic, the European Union needs a public health driven, green and social recovery to help fight the climate and social crisis. To this end, the European Green Deal should be strengthened to lead the European transition to sustainable mobility and building sectors, including zero-emission heating. We must make sure that vehicles on our roads and heating in our homes no longer endanger any lives due to their emissions, and the updating and extension of the EU ETS can be part of a positive way forward. The transport and buildings sectors are two massive contributors to both air pollution and greenhouse gas emissions in the EU. This poses a challenge but also an opportunity for the EU to address a common cause of much human and climate harm. This proposal should thus ensure that European Union can meet its own Green Deal goals and improve air quality. Additionally, stricter emissions standards for all petrol and diesel cars and vans, and all heating systems are crucial to get to 100% zero emissions mobility and buildings. EPHA believes that this new Social Climate Fund should contribute to a modal shift in cities from car-based to walking, cycling, and public transport, wherever possible, and from fossil fuel-based heating systems to zero-emission ones, such as efficient heat pumps, or solar thermal. These are the healthiest, the least polluting and most efficient transport and heating options. Non-internal combustion engines should be preferred over conventional fossil fuel-powered vehicles because they are non-exhaust emission sources.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

EPHA welcomes the opportunity to provide feedback on the proposed revision of the EU renewable energy rules (Directive 2018/2001/EU). The use of renewable energy must be supported and significantly scaled up at an accelerated pace if the EU is to achieve its climate and health ambitions. The transport and buildings sectors are two massive contributors to both air pollution and greenhouse gas emissions in the EU. This poses a challenge but also an opportunity for the EU to address a common cause of much human and climate harm. This proposal should thus ensure that European Union can meet its own European Green Deal goals and improve air quality. Additionally, it should be integrated with other instruments establishing strict emission standards for heating systems. EPHA proposes that policies and legislative action must be coherent and work towards solutions that provide climate and health co-benefits. The legislative package revealed this summer identifies and presents many opportunities for a socially just transition towards cleaner and healthier ways of living. Yet it remains crucial that each proposal displays integrative thinking and considers the full potential of climate and health co-benefits, while ensuring that actions taken in one field do not endanger progress in the other. Classifying biomass as renewable is a case in point. This choice has been disputed by many environmental organisations, noting that newly planted trees may need decades to reabsorb the carbon released by burning the old ones. Additionally, from a health perspective, biomass burning has long been known to result in adverse impacts, as it is a major source of particulate matter (PM), which has been associated with cancer, lower- and chronic respiratory diseases and cardiovascular diseases. Studies in Denmark and Sweden have found that rural areas with limited traffic but high density of wood burning experience levels of air pollution that are comparable to those resulting from traffic in major cities. Therefore, stricter conditions and sustainability criteria should be used to considerably limit the use of biomass. Moreover, this issue also has an important social equity dimension, as biomass is oftentimes seen as a cheaper form of fuel when gathered locally. Therefore, vulnerable households may be more prone to using it for heating and thus be exposed to associated air pollutants. This comes in a European context where energy poverty is of particular concern: it represents a wide-spread problem in the EU, 34 million Europeans having reported an inability to keep their homes adequately warm in 2018. Energy poor households often use inefficient or more polluting forms of energy, which can contribute to poor mental and physical health. These vulnerable households must be protected and supported through targeted policies. Especially considering the consequences of the COVID-19 pandemic, the European Union needs a public health driven, green and social recovery to help fight the climate and social crisis. In parallel, all direct and indirect subsidies for fossil fuels must end. Following the Green Deal and the Zero Pollution ambition, EU and national instruments should be revised to ensure that no funding goes to climate and health harmful activities. We must make sure that the heating in our homes no longer endanger any lives due to emissions, and the updating of the EU renewable energy rules can be part of a positive way forward. Additionally, EPHA urges the European Union to phase out new fossil fuel heaters within this decade, in order to reach climate neutrality by 2050.
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Response to Updating the EU Emissions Trading System

8 Nov 2021

The European Public Health Alliance (EPHA) welcomes the opportunity to provide feedback on the proposed extension of the EU Emissions Trading System (EU ETS) scheme to the transport and building (heating) sectors. The transport and buildings sectors are two massive contributors to both air pollution and greenhouse gas emissions in the EU. This poses a challenge but also an opportunity for the EU to address a common cause of much human and climate harm. This proposal should thus ensure that European Union can meet its own Green Deal goals and improve air quality. Additionally, stricter emissions standards for all petrol and diesel cars and vans, and all heating systems are crucial to get to 100% zero emissions mobility and buildings. Both carbon pricing and regulatory action must be complemented by subsidy programs in order to secure a socially just transition. Energy poverty of particular concern in the context of the EU ETS extension. It already represents a wide-spread problem in the EU, 34 million Europeans having reported an inability to keep their homes adequately warm in 2018. Energy poor households often use inefficient or more polluting forms of energy, which can contribute to poor mental and physical health. These vulnerable households must be protected and supported through targeted policies. Especially considering the consequences of the COVID-19 pandemic, the European Union needs a public health driven, green and social recovery to help fight the climate and social crisis. To this end, the European Green Deal should be strengthened to lead the European transition to sustainable mobility and building sectors, including zero-emission heating. We must make sure that vehicles on our roads and heating in our homes no longer endanger any lives due to their emissions, and the updating and extension of the EU ETS can be part of a positive way forward. EPHA believes that this new EU ETS regulation should contribute to a modal shift in cities from car-based to walking, cycling, and public transport, wherever possible, and from fossil fuel-based heating systems to zero-emission ones, such as efficient heat pumps, or solar thermal. These are the healthiest, the least polluting and most efficient transport and heating options. Non-internal combustion engines should be preferred over conventional fossil fuel-powered vehicles because they are non-exhaust emission sources. For health, climate protection and environmental reasons, the vehicle and heating emissions should be drastically reduced, and air quality significantly improved throughout Europe.
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Response to Revision of the CO2 emission standards for cars and vans

8 Nov 2021

The European Public Health Alliance (EPHA) welcomes the European Commission’s proposal to sell exclusively zero-emission new vehicles in the EU from 2035. Stricter emissions standards for all petrol and diesel cars and vans are crucial to get to 100% zero emissions mobility. This proposal should ensure that European Union can meet its own Green Deal goals and improve air quality. Especially considering the consequences of the COVID-19 pandemic, the European Union needs a public health driven, green recovery to help fight the climate crisis. To this end, the European Green Deal should be strengthened to lead the European transition to sustainable mobility, including zero-emission vehicles. The new revision of vehicle performance standards will be vital in this strategy, to make sure that vehicles on European roads no longer endanger any lives due to their emissions. EPHA believes that this new regulation shall contribute to a modal shift in cities from car-based to walking, cycling, and public transport, wherever possible. These are the healthiest, the less polluting and most efficient transport options. Non-internal combustion engines should be preferred over conventional fossil fuel-powered vehicles because they are non-exhaust emission sources. For health, climate protection and environmental reasons, the vehicle emissions of air pollutants should be drastically reduced. Many pollutants emitted from automotive engines are dangerous to human health. Yet, they are poorly regulated or not regulated at all under the current European emission standards nor the EU Air Quality Standards: all must be regulated. EPHA welcomes the upcoming revision of the Ambient Air Quality Directives and urges the full alignment of EU’s air quality standards with the 2021 WHO Global Air Quality Guidelines by 2030. Consequently, the Euro emissions standards and their enforcement should also be strengthened. EPHA urges the European Union to end the sale of new diesel and petrol cars as soon as possible, while progressively phasing out existing polluting vehicles from urban areas. It is important to strengthen the emissions regulation, especially the removal of the conformity factor for all pollutants, to ensure that vehicles meet the emission limits on the road, for all pollutants, under all possible driving conditions. Effective implementation is as important as the limits themselves. EPHA policy recommendations EPHA stresses the importance of more stringent CO2 emissions for cars and vans, as strict as possible, as soon as possible, and more crucially, alternatives to combustion engines. This principle should be mainstreamed and implemented in the technical regulation. The new standards must be aligned with the “zero pollution” ambition of the European Green Deal and with the goal of net zero greenhouse emissions by 2050. Limits must apply under all conditions all the time, including during DPF regeneration and throughout the vehicles’ lifetime. Particle pollution from brakes and tyres should be regulated as part of Euro 7/VII. Revised car and van CO2 emissions targets should include an interim milestone that keeps the automotive industry on a clean track to 2030. The new standards must also introduce a roadmap to achieving 100% zero emission vehicles as soon as possible, by 2028.
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Response to Sustainable food system – setting up an EU framework

26 Oct 2021

The shift to healthy, sustainable food systems is a public health urgency. The European Public Health Alliance (EPHA) considers that only a new framework law offers the opportunity to address in a comprehensive, effective and equitable way the challenges and opportunities linked to reforming the European food system. To achieve its transformative potential, this legislative framework should be designed to generate direct impacts in terms of the responsibilities it establishes on food system actors, both private and public, and in terms of leveraging further sectoral regulations and policies, both at EU and national levels. The creation of enabling food environments for the uptake of sustainable healthy diets should be at the heart of the framework law. This will empower citizens and consumers to contribute to sustainable food systems. Ensuring socio-economic access to healthy and sustainable diets is also a key precondition for a sustainable, just transition. A well-designed and implemented legislative framework for sustainable food systems will be the crowning achievement of the EU Farm to Fork Strategy. In the attached response EPHA sets out proposals for building blocks for the legislative framework and how the framework can advance the creation of enabling food environments.
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Meeting with Stella Kyriakides (Commissioner) and European Patients' Forum (EPF) and

25 Oct 2021 · VTC Meeting: EU4Health Work Programme 2022 and operating grants.

Meeting with Alvaro De Elera (Cabinet of Vice-President Věra Jourová)

10 Sept 2021 · transparency and access to documents

Meeting with Sarah Wiener (Member of the European Parliament) and Association Internationale de la Mutualité

6 Sept 2021 · Marketing of nutrionally poor food to children

Response to Animal welfare labelling for food

23 Aug 2021

Considering the current sustainability and health challenges posed by food systems, and in the context of the implementation of the Farm to Fork and Biodiversity Strategies, but also considering the newly updated Veterinary Medicines and Medicated Feed Regulations, the European Public Health Alliance (EPHA) welcomes the revision of the European animal welfare legislation to open the way towards more sustainable animal farming. EPHA would specifically like to highlight two crucial issues: the relationship between high density animal farming operations, excessive farm antibiotics use and the risk of antimicrobial resistance (AMR) and the need for transparent, harmonised and mandatory animal welfare labelling across the European Union (EU). 1) On AMR AMR is a major health threat, and the overuse of antibiotics in animal farming, which may be used to compensate for poor animal husbandry conditions, an important contributing factor. Some practices, such as avoiding long transportation of young animals or increasing space allowances to create less crowded living conditions, would lower related stress level and the spreading of diseases such as diarrhea or respiratory issues, thereby helping farmers to reduce dependency to regular use of antibiotics. In this light, higher and harmonised animal welfare standards among European Member States would facilitate antibiotics use reduction and help to prevent the development and spread of zoonotic diseases. 2) On animal welfare labelling Consistent with the revision of EU marketing standards for agricultural products, EPHA welcomes option 1 & 3 of the inception impact assessment on animal welfare labelling. After the successful introduction of a mandatory system of labelling eggs according to the method of production, EPHA supports the extension of this type of system to all animal and fish-based products across EU Member States. Please find our full position attached.
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Meeting with Stella Kyriakides (Commissioner) and European Patients' Forum (EPF) and

30 Jul 2021 · Meeting with civil society representatives regarding the EU4health programme.

Response to Review of the EU school fruit, vegetables and milk scheme - EU aid

27 Jul 2021

The European Public Health Alliance (EPHA) considers that in view of the evolution of European Union (EU) policies in the areas of food systems and public health, following especially the adoption of the Farm to Fork Strategy, Europe's Beating Cancer Plan and the European Child Guarantee, the EU school fruit, vegetables and milk scheme should be revised to achieve its full potential to enhance the consumption of products that contribute to healthy and sustainable diets. In this light, EPHA recommends focusing on some aspects that appear necessary for the EU school scheme to benefit both health, farmers and public budgets alike and thus to contribute to the objectives presented in the above-mentioned political strategies. First, the potential of the scheme is undermined by a small budget and an ineffective use of the allocated envelope by the member states; while the EU school fruit, vegetables and milk scheme should benefit all 76,2 million European pupils enrolled in the European education system (Eurostat, 2020) throughout their school years, from nurseries to upper secondary level education, to effectively promote “healthy eating habits and the consumption of local products” from the youngest age. From a public health perspective, the EU school scheme contributes to efforts to reduce overweight and obesity by simultaneously promoting the consumption of fresh or processed fruit and vegetables but also of milk and selected milk products in line with national dietary recommendations and food based dietary guidelines. School schemes’ main long-term value is when children effectively discover and become accustomed to new products, building acceptance, especially of vegetables, at a young age and providing a knock-on effect for food choices throughout life (EPHA, 2016). However, exceptions exist, and some products distributed through the scheme may contain “limited” quantities of added sugar, salt and/or fat. Thus, EPHA welcomes the proposal made in the inception impact assessment to reconsider these current exceptions and the further possibility to include other products, such as plant-based drinks and/or whole grains, which are part of a healthy and sustainable diet. Finally, beyond suggestions for specific improvements, EPHA invites to consider an update to the basic nature of the school scheme to improve its contribution to the transition towards sustainable food systems in line with EU policy. This could be achieved by transforming the EU school scheme into a wider instrument to financially support the advancement of healthy and sustainable public food procurement in schools. Please find our full position attached.
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Response to Revision of Food Information to Consumers for what concerns labelling rules on alcoholic beverages

22 Jul 2021

The European Public Health Alliance (EPHA) is a leading European civil society alliance in Brussels, made up of 80 public health NGOs, patient groups, health professionals and disease groups, working to improve health and strengthen the voice of public health in Europe. EPHA is pleased to contribute to the Inception Impact Assessments of the Proposal for a revision of Regulation (EU) No 1169/2011 on the provision of food information to consumers (FIC), for what concerns labelling rules on alcoholic beverages. Alcohol is not an ordinary commodity. Alcohol consumption is responsible for a wide a range of harms to health, including non-communicable diseases (NCDs), such as different cancers and liver cirrhosis, injuries and infectious diseases. It is a psychoactive substance with dependence-producing properties. Alcohol consumption is a leading risk factor for the burden of disease in the European Union (EU), and a major cost to public budgets. EPHA shares the Commission’s assessment that there are no objective grounds to justify the exemption of alcoholic beverages containing more than 1.2% by volume of alcohol from the obligation to provide information to consumers on ingredients and nutrition information . EPHA is highly critical of the current self-regulatory approach to labelling, which has led to incoherent approaches between beverages, and has usually fallen short of addressing the interests of consumers and of public health. Among the options presented, EPHA strongly favours Option 2, which is the minimum option to remove above mentioned inconsistency. EPHA strongly opposes Options 0 and 1 which are unsatisfactory. Providing parts of the information off-label will fall heavily short of effectively informing consumers. It is well-known that on-label information is more readily available, especially within in-store environments, and is more likely to be seen and read, particularly with population groups that are less inclined to seek out such information. EPHA assumes that once the exemption for alcoholic beverages is removed from the FIC Regulation, all alcoholic beverages will be covered by the front-of-pack labelling provisions that will be proposed under the Farm to Fork Strategy. Front-of-pack labelling is a far more effective way of informing consumers on the nutritional contents of products. Having said this, EPHA believes that removing the current inconsistency under the FIC Regulation is just a very first, and basic, step towards an appropriate and tailored approach to regulating the appearance of alcohol products. Considering the special properties of alcohol, which are not comparable to food products, EPHA looks forward to a ‘lex specialis’ approach that recognises the specific characteristics of these products and introduces legislation adapted to these characteristics. Such rules include health warning labels, committed to under Europe’s Beating Cancer Plan. Such new legislation can draw inspiration on the success of the Tobacco Products Directive. The latter also includes provisions regulating the marketing of products, which is an important enabler for the success of information-based strategies.
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Meeting with Annukka Ojala (Cabinet of Commissioner Stella Kyriakides), Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides) and

22 Jul 2021 · VTC meeting on Framework legislation for sustainable food systems

Response to New EU urban mobility framework

25 May 2021

The European Public Health Alliance (EPHA) is the largest European umbrella NGO advocating for better public health. Our 85 member organisations encompass public health NGOs, patient groups, health professionals, disease groups, academia and population group representatives working together to improve health and strengthen the voice of public health in Europe. Summary EPHA welcomes the European Commission's intention to adopt a new EU urban mobility framework to upgrade the EU sustainable urban mobility toolkit. Our NGO underlines the importance of incentivising the transition towards zero-emission mobility and making sustainable, safe and active transport solutions available to everyone. Especially considering the consequences of the COVID-19 pandemic, the European Union needs a public health-driven, green mobility recovery, to help fight the climate and health crisis. To this end, the new urban mobility framework shall support the European mobility transition to a sustainable and healthy continent.
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European Public Health Alliance urges stricter antimicrobial import controls

4 May 2021
Topic — Updating EU rules to monitor antimicrobial use in imported animal-source products.
Message — The group supports establishing systems to ensure imported products meet EU standards. They want import requirements to also cover routine use, prophylaxis, and metaphylaxis for animals.12
Why — Stricter oversight helps the group's mission by mitigating global drug-resistant infection threats.34
Impact — Foreign exporters lose their competitive advantage by being forced to meet strict European standards.5
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EPHA urges tougher drug data standards and shortage controls

27 Apr 2021
Topic — This consultation reviews the EU's legal framework for ensuring affordable, innovative medicines.
Message — EPHA demands "comparative randomised double-blind clinical trials" to ensure higher quality data. They also want "mandatory constitution of safety stocks" and "dissuasive sanctions" for shortages.123
Why — These reforms would directly help the alliance achieve its core health advocacy goals.45
Impact — Pharmaceutical manufacturers would lose flexibility and face monetary fines for failing supply obligations.67
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European Public Health Alliance backs animal antibiotic curbs

23 Apr 2021
Topic — The initiative establishes criteria for designating specific antimicrobials to be reserved for human treatment.
Message — EPHA calls the initiative an important step in curbing the risk of resistance. They argue overuse in animal production contributes to the development and spread of drug resistance.12
Why — Preserving medicine effectiveness ensures the treatment of human infections remains possible in Europe.3
Impact — The farming and aquaculture sectors face new limits on using antibiotics for animal production.4
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Response to Information and promotion measures for agricultural and food products in the internal market and in non-EU countries

25 Feb 2021

The European Public Health Alliance (EPHA) considers that in view of the evolution of European Union (EU) policies in the areas of food systems and public health, following especially the adoption of the Farm to Fork Strategy and Europe's Beating Cancer Plan, the EU policy for the promotion of agricultural products is no longer fit for purpose and needs to be fundamentally revised. In this light, EPHA questions some of the conclusions in the Commission's recent report evaluating the application of promotion policy (COM/2021/49 final). This especially concerns the observation that "Coherence of promotion policy with other EU policies differs depending on the products promoted." This characterisation implies that the policy is sometimes coherent, and sometimes incoherent, shifting focus onto the products promoted, rather than the objectives underlying the policy. Such approach to evaluating coherence is unsatisfactory. Rather, promotion policy needs a renewed objective that will drive an intervention logic that is fundamentally coherent with the new overarching vision for food systems. For EPHA this new objective should be to help create changes in demand to provide producers with market incentives that are consistent with a transition towards healthy diets, a nutrition-sensitive agriculture, and environmentally, socially and animal welfare friendly food systems. This new objective will need to be accompanied by a full revision of the logic by which funding is allocated: 1) Promotion funding should be dedicated to: -- Health-enhancing products that are currently under-consumed, especially fresh or minimally processed fruit and vegetables, whole grains, pulses and nuts. -- Products from organic agriculture and, subject to the availability of credible certification systems, other models using sustainability-enhancing production methods. Only those animal-sourced products falling under this category should be eligible for support. A maximum ceiling should be established for this type of products, considering their current high levels of consumption in Europe. 2) Alcoholic drinks, including wines, beers, ciders and spirits, should be excluded from eligibility for promotion support. 3) Considering the need to promote changes in demand in support of a sustainable food systems transition, and the economic risks of relying on export-oriented supply chains, promotion funding should focus on the EU internal market and shift away from its current priority of promoting exports. The remaining promotion projects to third countries should demonstrate they do not entail the risk of disrupting local markets thereby endangering livelihoods of smart-scale producers. 4) Special provisions should be made to support projects that promote the development of local and/or direct supply chain models, including peri-urban to urban linkages, and rural markets. 5) Products with a geographical indication (GI) should no longer be automatically considered as priority products for promotion. GIs appear to leave space for considerable heterogeneity in product requirements, questioning the ability of the current schemes to consistently represent higher added value in terms of sustainability. Please find our full position attached.
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Response to European Health Emergency Response Authority

24 Feb 2021

The COVID-19 pandemic has shown that Europe has paid the price of not being prepared in the biomedical research & innovation (R&I) front. Moreover, the lacking supply and grossly inequitable global access to Covid19 vaccines is a stark reminder of why such fundamental public health questions must not be left to a profit-driven industry to decide. HERA is a great opportunity to build on the excellent European science, to learn the lessons from the ongoing crisis and ensure that the public acts as a wise investor which steers meaningful, public health needs-driven innovation. It should be a purely public organisation with a clear public health mission, not to be conflated with areas of industrial policy. It should have a sizable budget which will provide for independent long-term planning. In acting as wise investors, governments should be ready to invest significant amounts of public money. They should be mindful of the fact that not all R&D projects will come to fruition and some of them will not deliver the desired results. The possibility of failure and the financial risk should be endorsed from the start, especially, as HERA will invest in risky competitive projects including the boosting of manufacturing capacity. The new Agency (option number 3) will have to be independent, sustainable and protected from political pressure and evolving political priorities, jeopardising the continuity of its work. It should address the current lack of coherence between EU and national funding schemes and ensure that discoveries made with the support of EU funds will be translated into large scale industrial development across the EU. HERA should have enforceable rules on Open Access (i.e. data sharing) following Horizon Europe. HERA should build on – but go beyond – existing access initiatives (e.g. the Medicines Patent Pool) and develop more transparent and efficient incentive mechanisms that de-risk private sector activity but at the same time guarantee universal access and public return on public investment. Its governance structure should be transparent and balanced, including patient, public health organisations, and representatives of the research community. Whilst the industries will be important partners, they should not be part of any governance structure of this new public organisation. The definition of global unmet needs will be done by the public health sector only and the goal will be to engage in the development of new products to bring them to the market. This means that HERA will go well beyond the Innovative Medicines Initiative (IMI). The EU should be willing to exercise judgment that is independent of the pharmaceutical industry, and design solutions that are public health driven (for example, in the field of tackling Antimicrobial Resistance (AMR)). It also means that affordability, availability, accessibility, socially responsible licensing and transparency conditions will be attached to the end products to reflect the substantial and multifaceted public support and investment. To this end, reasonable pricing clauses should be envisaged. HERA will need to coordinate with the EMA and the ECDC but not only. It will have to integrate and streamline efforts throughout the value chain from basic research to large-scale manufacturing and distribution, across public and private sectors. Building of vaccine manufacturing facilities that are on standby to be mobilised in response to emerging infectious threats should be considered as the covid19 vaccine debacle has proven that rapid vaccine production at scale is a major challenge. At present, the landscape of EU research funding instruments is quite fragmented and insufficiently driven by the principle of public return on public investment. HERA can be instrumental in aligning means with priorities with a clear legal framework, a substantial, sustainable budget and a strong leadership for a new independent and autonomous Agency with a clear public health mission.
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Response to Revision of EU marketing standards for agricultural products

12 Feb 2021

The European Public Health Alliance (EPHA) strongly supports a comprehensive transition towards sustainable food systems, with health and well-being as a key pillar of sustainability. Considering the new framework for EU food and agricultural policy established by the Farm to Fork Strategy, there is a need to ensure that all EU food-relevant policies and regulations contribute to the aims and priorities therein. This includes tackling diet-related non-communicable diseases (NCDs), reversing the rise in overweight and obesity and minimizing antibiotics use in animal agriculture. In this light, EPHA supports the need to re-assess the role of EU marketing standards for agricultural products in providing consumers with relevant information and setting minimum quality requirements for food products. Specifically, EPHA wishes to highlight two aspects related to this revision: 1) Product composition criteria. The Commission should assess whether the current revision of marketing standards should go hand-in-hand with the Farm to Fork Strategy action to “launch initiatives to stimulate reformulation of processed food, including the setting of maximum levels for certain nutrients” (initiative No. 15 in the Action plan). Setting maximum levels for certain nutrients in a number of products, such as foods for babies and infants and certain other regularly consumed products, should be considered as part of revisiting marketing standards. 2) Method of production labelling. The EU has successfully introduced a mandatory system of labelling eggs according to method of production, which is already in place for many years. EPHA supports the extension of this type of system to all animal and fish products and calls on the Commission to launch a process to this effect. Method of production labelling should classify products according to farming method used, reflecting a number of sustainability criteria, including animal husbandry conditions. The resulting classification should be displayed in a clearly visible and understandable way on each concerned product. EPHA will closely follow and contribute to further reforms and improvements to EU marketing standards.
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Response to A European Health Data Space

3 Feb 2021

EPHA welcomes the European Health Data Space as a Commission priority and is pleased that it is seen as a way to increase the ability of digital health to reduce inequalities and provide high-quality healthcare. The Combined Evaluation Roadmap / Inception Impact Assessment appears to be well aligned with the Commission’s Communications on enabling the Digital Transformation of Health and Care and on the European Strategy for Data, as well as with the more specific approaches seeking to develop an ethical approach to making the most effective use of Artificial Intelligence in the health domain. As mentioned among the problems the legislative framework seeks to address, digital health is still not a reality for the vast majority of patients across Europe, apart from those MS (e.g. EST, DK, FIN) and regions (e,g. in ES, IT) which have continuously invested in making progress in this area. In most other settings, features of digital health are beginning to appear – accelerated by the COVID-19 crisis and the need to safeguard continuity of care – but the picture remains fragmented and even EHRs and ePrescriptions are only being introduced. This makes it difficult to fully grasp the issues at play in various countries across the Union and also means that “accessing and controlling one’s own health data” remains a vision, including within national territories. The problem analysis makes reference to a host of other obstacles in the way of a functional EHDS. Overall, EPHA agrees with the three objectives of the EHDS legislative proposal and thinks that the baseline scenario is unsatisfactory. For years we have advocated the development of end user-centric digital solutions fully integrated into European health systems, including in a cross-border context, which bring tangible improvements for health workers, patients and vulnerable groups. Moreover, EPHA has been calling for investments to greatly increase digital health literacy among the general population and skills training for healthcare professionals. We understand that such funding will be made available across a range of EU funds including EU4Health, but it would be advantageous to establish clear links with the implementation of the EHDS and tackling the digital divide. As current debates over coupling vaccination certificates with travel privileges demonstrate, it is also crucial to protect fundamental rights, especially for society’s weakest. The integration of an objective related to patients' rights and tackling inequalities would therefore be a good idea. The goal of providing better access to patients’ data in healthcare provision and research must go hand in hand with strong legal safeguards, coupled with continuous updates of data and privacy protection as technology evolves – better cybersecurity also means greater risks of exposure. The eHealth Network can continue to play an important role in producing guidelines and engaging in best practice exchanges, but ultimately a more even legal eHealth landscape will be needed – taking the form of a binding Regulation - as health and digital health become more closely intertwined. As health data are an increasingly important resource for public health decisions (e.g. track and trace apps), and a whole array of digital health solutions used in hospitals and other care settings are dependent on vast sets of data, more clarity of the different uses and their ethical implications is needed. Independent Ethical Review Boards could be set up to decide on the use of certain data sets and their processing in cases where individual consent cannot be obtained. Mobility for work and education has long become a reality for Europeans, and while Codes of Conduct, common standards, labels, etc. are important to build up trust and conduct research, it is time to go beyond these by agreeing on a range of basic digital health services accessible to all Europeans regardless of the different health systems they are situated in.
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Response to Setting of nutrient profiles

2 Feb 2021

The European Public Health Alliance (EPHA) has for many years supported front-of-pack (FOP) nutrition labelling as part of a wider policy mix to create health-enabling food environments. A well-designed FOP labelling scheme can help consumers identify healthier food options, promote the uptake of healthier diets and foster the reformulation of products. Please find enclosed EPHA's full submission, or access it through this link: https://epha.org/wp-content/uploads/2021/02/fop-labelling-road-map-epha-response-02-2021.pdf
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Meeting with Renate Nikolay (Cabinet of Vice-President Věra Jourová) and Corporate Europe Observatory

21 Jan 2021 · Transparency in tobacco lobbying

Meeting with Annukka Ojala (Cabinet of Commissioner Stella Kyriakides) and European Environmental Bureau and

20 Jan 2021 · VC Meeting - Discussion on minimum sustainability criteria for public procurement.

Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans) and European Environmental Bureau and

20 Jan 2021 · Discussion on minimum sustainability criteria for public procurement

European Public Health Alliance urges full WHO alignment on air standards

14 Jan 2021
Topic — Revision of EU air quality standards to align with WHO health recommendations.
Message — The organization requests that EU air quality standards be fully aligned with the latest WHO Air Quality Guidelines. They call for an ambitious action plan with concrete actions, binding timelines and goals to prevent pollution at its source. They emphasize that quick approval and immediate implementation is crucial to improve air quality and save lives.123
Why — This would reduce the 400,000 annual premature deaths from air pollution in the EU.45
Impact — Polluting industries lose public financing and face stricter vehicle emission standards and zero emission requirements.678
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Response to Cross-border acquisitions of excise goods by private individuals

5 Jan 2021

The European Public Health Alliance (EPHA) together with Corporate Europe Observatory (CEO) welcome the initiative to review this policy. The Inception Impact assessment (IIA) correctly identifies the main problems of the current policy, which have been further highlighted by the COVID-19 pandemic, as several member states with closed borders have noted sharp increases in alcohol or tobacco duty income while consumption has remained stable or decreased. Distortion of public revenue, excise fraud, negative pressure on excise duty rules as a result of the current policy all contribute to worsening public health outcomes. Revising these rules is a win-win-win situation for the European Union: it will improve health outcomes, strengthen many national budgets, and help combat organised crime and fraud. We are glad to see that the IIA rejects the industry argument that limiting cross-border purchases would distort the internal market – instead it is clear that it would strengthen it, and reinforce member states’ ability to implement effective public health policies on tobacco and alcohol. Tobacco and alcohol are significant causes of premature death and significant burden of disease in the EU. For example in 2016, 800 people died every day due to harmful use of alcohol, according to the WHO. Nearly 700,000 people die per year in the European Region due to tobacco use and around 50% of those deaths are premature (on average 14 years earlier), while in general smokers and heavy drinkers spend more life years in poor health and suffering from many forms of non-communicable diseases (NCDs). Tobacco and alcohol consumption also disproportionally affect the health of the EU’s poorest and most disadvantaged. It is positive that this review is framed in the context of the EU’s planned Beating Cancer Plan and this - along with the EU’s international and treaty obligations to uphold a high level of public health protection (SDGs, TFEU Art.168 and the FCTC) - must be leading for the review. According to the WHO, taxation is one of the most effective policy instruments to reduce consumption of unhealthy commodities like alcohol and tobacco, and thereby the prevalence of a range of NCDs, including several cancers. The input and perspectives of health actors must be included throughout the legislative process. The main policy options (bar the ‘no change’ option) identified in the Inception Impact Assessment provide a good basis for the review. Many countries have also expressed a desire for similar rules as to purchase of fuels to apply to alcohol and tobacco. EPHA & CEO call for: • Member States to be given the flexibility to limit individual cross-border purchases so as not to diminish the impact of their current tax policies, • The guide levels to be adapted to set concrete and easily enforceable quantitative limits, • Excises duties to be levied in the place of consumption, • the focus to be kept on maximising positive health impacts, • Enforcement to be taken into account when assessing the proportionality of policy options, considering that easily enforceable rules contribute to effectiveness and reduce administrative burdens. As noted by the Commission, cross-border purchases are also driven by divergences in excise duties between member states, so it is crucial that these two issues are addressed in tandem, to ensure coherence, and improved outcomes for public health. Finally, this change must be complemented by other tobacco control actions including strengthening existing efforts to curb tobacco industry influence at EU level, via improved implementation of FCTC article 5.3 and the European Ombudsman’s recommendations thereon.
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Response to Tobacco taxation – revision of EU rules

5 Jan 2021

The European Public Health Alliance (EPHA) together with Corporate Europe Observatory (CEO) welcome the review of this policy and support comprehensive taxation to reduce consumption of tobacco products of all types, including “roll/make-your-own” and novel tobacco products. Taxation is one of the most effective policy instruments to reduce tobacco consumption, and thereby the prevalence of a range of related health issues. Taxation is a particularly effective deterrent for younger consumers, and data shows that 93% of European smokers start before the age of 25. Tobacco remains the most significant cause of premature death and cause of a significant burden of disease in the EU. Nearly 700,000 people die per year in the WHO European Region due to smoking, around 50% of whom die prematurely (on average 14 years earlier), while in general smokers spend more life years in poor health, suffering from many forms of non-communicable diseases (NCDs). Tobacco consumption also disproportionally affects the EU’s poorest and most disadvantaged. It is positive that this review is framed in the context of the EU’s Beating Cancer Plan. This - along with the EU’s international and treaty obligations to uphold a high level of public health protection (SDGs, TFEU Art.168 and the FCTC) - must be leading for the review. The input and perspectives of health actors must be included throughout the legislative process. This is key to ensure that debunked industry arguments regarding supposed illicit trade and lack of data do not weaken ambition in this area. EPHA & CEO calls for the review to: • increase excise duties and taxation on all traditional tobacco products, • include e-cigarettes and other novel products as an equivalent product to tobacco regarding excise duty, • introduce the objective to reduce current tobacco use by 30% by 2025 as a clear benchmark for success of the directive, • aim to achieve upwards convergence of tobacco prices across member states, • subject roll-your-own/fine cut tobacco products to the same duties as manufactured cigarettes. Achieving a 30% reduction could result in 18.5 million fewer smokers across the EU, while achieving upwards convergence of tobacco prices across the EU would help reduce cross-border purchases. We welcome the recognition of the need to add novel products, such as e-cigarettes and heated tobacco, into the directive. The excise treatment of these products should be brought into line with conventional tobacco products. This upholds the precautionary principle: while the long-term effects of e-cigarette use remain unknown, caution should prevail. Emerging evidence indicates that health risks for e-cigarette users and second-hand smokers are moderate, suggesting long-term negative cumulative effects. Studies have shown that novel products act as a gateway to conventional tobacco use, refuting claims that they principally help existing smokers quit. Issues of dual smoking (i.e. using both novel and traditional products), addictiveness and the tobacco industry using novel products to target a new generation of smokers means it is vital to reduce the normalisation of such products by treating them in the same way as traditional products in terms of excise duties. The directive must therefore prioritise preventing novel products from acting as a gateway. The current COVID-19 pandemic has underlined the importance of this policy: smoking of traditional manufactured tobacco increases the risk of contracting the virus, developing the disease and complications, even leading to death. New data suggests consumption of e-cigarette has a very similar effect on individuals’ susceptibility to COVID-19. Finally, the strengthening of excise taxes must be complemented by other tobacco control actions including strengthening existing efforts to curb tobacco industry influence at EU level, via improved implementation of FCTC article 5.3 and the European Ombudsman’s recommendations thereon.
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Response to 8th Environment Action Programme

31 Dec 2020

The European Public Health Alliance (EPHA) is the largest European public health NGO advocating for better health, present in all European member states via its 81 member organisations, including both European and national organisations. It encompasses public health NGOs, patient groups, health professionals, disease groups, academia and population group representatives working together to improve health and strengthen the voice of public health in Europe. Summary The 8th Environment Action Programme (8th EAP) should be the enabler to connect the various policy initiatives under the European Green Deal with public health purposes and EU health policy, ultimately following the “One Health approach”. The 8th EAP is an opportunity to implement the Health in All Policies (HiAP) and demonstrate the added value of EU environmental policies to the European Health Union initiative. There is a need to develop a comprehensive approach to EU environmental policies for tackling the effects of the existential crises: the climate emergency, the biodiversity loss and the consequences of the COVID-19 pandemic. Only the 8th EAP duly taking into account the Treaty on the Functioning of the European Union (TFEU) article 168 and the HiAP obligation can facilitate efficiently a public health driven, green recovery to lead the European transition to a sustainable and healthy continent.
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Response to Revision of the EU legislation on medicines for children and rare diseases

18 Dec 2020

Small biotechs, university spin-offs and other research institutions are now at the heart of pharmaceutical R&D conducting the early-stage research, financed by venture capitalists, hedge funds and private equity. Large pharmaceutical companies perform less research in-house while they scan the horizon for promising products and companies. They subsequently acquire them. The cost of these acquisitions is substantial and is factored into the prices of medicines. This contributes to price inflation. Additionally, companies tend to bring to market, reformulations of existing medicines. Such a strategy reduces risk and enables companies to maximize profit through all sorts of anti-competitive tactics such as: Ever-greening strategies which extend IP-based monopoly protection, introduction of pseudo-generics, filing patent clusters to delay generic/biosimilar entry, drug repurposing (product hopping) with excessive prices, artificial withdrawals from markets etc. We notice the above happening in the areas of these two important pieces of EU legislation (orphans & paediatrics). In general, incentives need to be proportionate, balanced and fair. It is now the time to assess the cost of the patent-based monopolies and exclusivities and consider alternative incentives which do not consolidate monopolies, do not deter nor distort competition, reward proper innovation as opposed to excessive profits and ensure affordable prices, to name but a few elements. In both areas (paediatric & orphan medicines), the role of public support into biomedical R&D and manufacturing is important and multifaceted (direct funding of basic science and clinical trials, building physical infrastructure such as laboratories and registries, through the scaling up of genome programmes globally, the training medical forces workforces, tax credits and discounts to name but a few). This needs to be acknowledged and factored into the eventual incentives structure to ensure transparency throughout the value chain and a return on this multilayered substantial public investment needs to be guaranteed. To this end, the critical review and possible scale back of existing incentives needs to start by looking at the patentability criteria, the eligibility criteria (for orphan medicines), the profit margins of companies, the effect on the quality of innovation and on the availability of products. Overall, current rewards and incentives are generous and imbalanced. Subsequently, oftentimes, numerous products do not make it on markets across the EU even after years since the initial marketing authorisation. Patients are therefore held hostage of companies' business and marketing strategies while companies benefit from the incentives generously granted by EU legislators. We would therefore favour a scale back of the incentives where necessary to avoid the overcompensation of companies, a definining criterion in their R&D priority setting which becomes an access barier for patients. Companies need to be encouraged to share with the public an analytical breakdown of their R&D and manufacturing costs too. Additionally, it is important to move in a direction of evaluating the performance and business conduct of pharmaceutical industries (inputs, activity and outputs). This would look at how the industries respond to health care needs taking into account their resources and how they are used. Furthermore, it would contribute to more transparency in the pharmaceutical systems. The lack of transparency exacerbates the information asymmetry. This consequently leads to power imbalance(s) and market failures often observed in the fields of orphan and paediatric medicines.
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Response to Contingency plan for ensuring food supply and food security

16 Dec 2020

The European Public Health Alliance (EPHA) shares the concerns about food security and the resilience of food systems uncovered by the COVID-19 crisis. At the same time, the fact that food supply has, by and large, remained intact in the European Union (EU) is an important and positive observation. Actors in the food chain, including farmers, fishers, aquaculture producers and food workers, have played a central role in keeping food on the shelves. This despite the often sub-standard labour conditions observed in the food and agricultural sectors.[1] However, what has not received sufficient acknowledgment and emphasis in this debate is the degree to which food systems are embedded in the wider functioning of societies. Europe’s physical infrastructure, its social and healthcare systems, and ability to mobilise considerable financial resources have, while in many cases proven deficient, played a critical role in protecting supply chains from the sharpest shocks. While many countries in the world faced similar shocks as those observed in the EU,[2] including drops in demand, restrictions to movement, loss of jobs, health impacts on workers, these factors led to far greater disruptions and food insecurity risks when adequate security, societal infrastructures and support systems were unavailable.[3] Critically, inside the EU too, food supply functioned only for those with access to adequate socio-economic support.[4] EPHA believes that the work on the Contingency plan must be seen as an opportunity for wider reflection and for creating a plan of action to tackle food insecurity in light of food systems reform, which includes ensuring good labour conditions for food workers and making sure that no EU policy or action hampers third countries in achieving food security. This, importantly, involves embracing a proper definition of food security.[5] Unlike often portrayed in food policy debates, food security is not only about having a sufficient food supply to cover the calorie needs of a population. Food security encompasses six dimensions, which clearly indicate that without good nutrition and environmental sustainability, food security cannot exist. These dimensions are: 1) Availability 2) Access (economic, social and physical) 3) Utilization (having an adequate diet) 4) Stability 5) Agency 6) Sustainability An estimated 11% of the EU population (49 million people, EU-27) are unable to afford a quality meal every second day [6] and over 20% of the population are at risk of poverty or social exclusion.[7] It should be recognised that this state of affairs throws a long shadow over efforts to achieve a fair, healthy and environmentally-friendly EU food system. It should also be recognised however, that food policy cannot solve such deep, structural and multifaceted socio-economic issues.[8] Social and economic policy instruments must be aligned with EU’s food policy aims to enable the emergence of truly sustainable food systems.[9] This was also acknowledged in the SCAR’s 5th Foresight report, which considers that developing social welfare systems will be crucial for ensuring access to healthy diets for all. [1] Joint Statement (2020) https://bit.ly/3gQCfY8 [2] Committee on World Food Security (2020) https://bit.ly/34i0SI6 [3] Global Network Against Food Crises (2020) https://bit.ly/3atDkUX [4] The Guardian (2020) Mafia distributes food to Italy's struggling residents, https://bit.ly/3nu4G0E [5] High Level Panel of Experts on Food Security and Nutrition (2020) https://bit.ly/3p15oTB [6] EUROSTAT [7] EUROSTAT [8] Daniel (2020) Social Science & Medicine, https://doi.org/10.1016/j.socscimed.2020.112823 [9] WHO (2019) https://bit.ly/2IUiYIR [10] 5th SCAR Foresight Exercise (2020) https://bit.ly/37qcL0W
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Public health groups demand binding EU zero-pollution targets

28 Oct 2020
Topic — The EU initiative to create a zero-pollution action plan for air, water, and soil.
Message — The European Public Health Alliance calls for tangible actions with binding timelines and goals aligned with WHO air quality guidelines. They urge the EU to phase out fossil fuel subsidies by 2025 and align the Common Agricultural Policy with green goals.123
Why — These measures would reduce the incidence of chronic diseases and protect vulnerable groups from environmental health threats.4
Impact — The fossil fuel and intensive agriculture sectors face significant financial losses from ending subsidies and stricter regulations.56
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Meeting with Stella Kyriakides (Commissioner)

10 Sept 2020 · Exchange of views on the pharmaceutical strategy

Response to Sustainable use of pesticides – revision of the EU rules

4 Aug 2020

The extensive use of pesticides in agriculture over the last decades has led to widespread exposure to such agrochemicals. Pesticide and herbicide residues are pervasive, posing multifacetted risks for public health. Such risks extend to farmers, farm workers, inhabitants of areas exposed to application, as well as consumers and the wider population. There are, for instance, mounting concerns about the impacts of persistent low-dose exposure to pesticides, notably on the human endocrine system, and cumulative effects with other chemicals. Health risks also manifest through the impacts of pesticides on non-target species and entire ecosystems. Pesticides, for instance, are implicated in the loss of pollinators, whose activities are critical for the cultivation of a wide range of highly nutritious foods, as well as the degradation of soil quality, thereby posing risks for food security and nutrition. The revision of the Sustainable use of pesticides directive (SUD) should be carried out with the firm aim of driving a systemic transition to reduce the dependence on pesticides use, while incentivising and enabling producers. The widespread roll-out of integrated pest management techniques will be crucial. This not only to reduce the quantities of pesticides used in line with the target in the Farm to Fork Strategy, but also as a constitutent part of a wider transformation towards more ecological production models, which goes well-beyond an improved efficiency in use alone. The 2020 Scientific opinion “Sustainable food system” by the European Union’s (EU) Chief Scientific Advisors, recommends using regulatory and fiscal measures as the core drivers of a transition towards food sustainability, as those tend to be most effective in achieving change. The limited effectiveness of the SUD to date, as admitted by the Commission, increases the relevance of this observation.
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Response to EU Methane Strategy

4 Aug 2020

As a major greenhouse gas and a precursor to ozone, which contributed to 14.000 air pollution-related premature deaths across the European Union (EU) in 2016 (European Environment Agency, 2019), excessive methane emissions represent a challenge to public health. EPHA welcomes an EU strategy on methane, and stresses the need to ensure an effective and equitable response to tackling emissions, with all emitting sectors subject to making a contribution. In formulating a response, the 2020 Scientific opinion “Sustainable food system” by the EU’s Chief Scientific Advisors, should be considered. It recommends the use of regulatory and fiscal measures as the core drivers of transition, as those tend to be most effective in achieving change. Just over half the EU’s methane emissions derive from agriculture (EEA, 2019) with most of it from animal farming. Reducing methane emissions from agriculture should be conceived as part of a wider co-benefits strategy towards sustainable food systems, encompassing a transition towards healthier, more sustainable diets with more fruit and vegetables, whole grains, pulses, nuts, and ‘less and better’ animal products, consistent with the EU Farm to Fork Strategy. The question of intensification or extensification of animal production and the wider sustainability implications should be a key question in designing a policy response. For instance, while intensified ruminant systems may reduce methane emissions per unit of food, they are likely to lock in greater use of fossil fuels for feed production and housing. This additional energy demand may make overall decarbonisation more difficult (see more in: Food Climate Research Network (2020) Methane and the sustainability of ruminant livestock). Likewise, consistency with other food policy aims, such as antibiotics use reduction and enhanced animal welfare should be considered, as well as the socio-economic and biodiversity benefits of permanent pasture-based production systems.
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Response to Delivering for children: an EU strategy on the rights of the child

4 Aug 2020

Article 24 of the Convention on the Rights of the Child (CRC) recognises the “right of the child to the enjoyment of the highest attainable standard of health” (i.e. the right to health). Childhood overweight and obesity has reached epidemic levels across the European Union (EU), entailing significant risks to child and (young) adult’s health and well-being. An obese child faces a lifetime of increased risk of various diseases, including cardiovascular disease, diabetes, liver disease and certain forms of cancer. Even during childhood, obesity increases the risk of these diseases, and is a significant cause of psychological distress. There is convincing evidence that exposure of children to the marketing of foods high in fat, sugar and salt (unhealthy food) influences what and how much children eat. Tackling marketing as part of childhood obesity policy has featured prominently in multiple EU policy documents, including the 2017 Council Conclusions on childhood obesity and the EU Action Plan on childhood obesity 2014-2020. While obesity was not considered a global threat yet during the adoption of the CRC, like other human rights instruments, it should be interpreted to provide guidance to new challenges. For this reason, food and alcohol marketing are increasingly perceived as raising children’s rights issues. As a result, the advantages of adopting a child rights-based approach to food and alcohol marketing are becoming more documented, see for instance: -- General Comment No. 16 to the CRC, which reads that “The activities and operations of business enterprises can impact on the realization” of children’s rights. The marketing to children of products such as “foods and drinks high in saturated fats, trans-fatty acids, sugar, salt or additives” is provided as an example. -- Unicef report on A Child Rights-Based Approach to Food Marketing – A Guide to Policy Makers (April 2018) --Joint briefing by Unicef and Hilal Elver (UN Special Rapporteur on the Right to Food) for the 30th Anniversary of the UN Convention on the Rights of the Child on Protecting Children’s Right to a Healthy Food Environment (November 2019) Therefore, EPHA urges to include the protection of children from harmful commercial practices, such as the marketing of unhealthy foods and alcohol, as a core component of the EU’s framework of action on promoting and protecting the rights of the child. This especially considering that legislative action to tackle child exposure to health-harming marketing practices has been deemed inadequate across the EU,* despite CRC signatories’ obligation to respect, protect and fulfill human rights. This also considering the added value of adopting a child rights approach to EU obesity prevention policy, described for instance in: -- A. Garde et al, “For a Children’s Rights Approach to Obesity Prevention: The Key Role of an Effective Implementation of the WHO Recommendations”, European Journal of Risk Regulation 8(2) (2017) 327 * For more see: WHO (2018) Evaluating implementation of the WHO set of recommendations on the marketing of foods and non-alcoholic beverages to children. Progress, challenges and guidance for next steps in the WHO European Region
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Response to Fitness Check of the EU legislation on animal welfare

29 Jul 2020

Animals are sentient beings and deserve the highest levels of protection. The assertion that the European Union (EU) has one of the world’s highest standards of animal welfare cannot serve as proof that these standards are sufficient. Apart from the intrinsic value of protecting animals, a strong link exists between the health of people, the health and welfare of animals and the health of the planet. This set of interlinkages is captured by the One Health concept, which, for instance, features prominently in the EU’s approach to tackling antimicrobial resistance (AMR). While pursuing a high level of animal welfare protection is an important objective in itself, improved and expanded animal welfare legislation can also tie-in with other elements of a sustainable food systems transition, as envisioned in the Farm to Fork Strategy. For instance, higher welfare standards can lead to less crowded conditions for food producing animals and lower stress, thereby facilitating antibiotics use reduction and helping prevent the development and spread of zoonotic diseases. It can also result in lower environmental pressures linked to large scale, intensive animal farming. One Health should therefore be a leading principle in the review of the EU’s animal welfare legislation in order to maximise systemic co-benefits. More specifically, enhanced animal welfare should be conceived as the core enabler to achieving the EU’s farm antibiotics use reduction commitments. Also, expanding the classification system currently used for eggs (0-3) to capture other animal species and production systems should be considered.
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Response to Sustainable and Smart Mobility Strategy

19 Jul 2020

The European Public Health Alliance (EPHA) is the largest European public health NGO advocating for better health. Our 82 member organisations encompasse public health NGOs, patient groups, health professionals, disease groups, academia and population group representatives working together to improve health and strengthen the voice of public health in Europe. Summary EPHA welcomes the Commission's intention to adopt a comprehensive strategy to reduce transport-related greenhouse gas emissions by 90% by 2050. Our NGO underlines the importance of prescribing zero-emission vehicles and making sustainable, safe, and active transport solutions available to everyone. Especially considering the consequences of the COVID-19 pandemic, the European Union needs a public health-driven, green mobility recovery, to help fight climate and health crisis. To this end, the European Green Deal shall be strengthened to lead the European mobility transition to a sustainable and healthy continent. EPHA’s position A European Sustainable and Smart Mobility Strategy should bear in mind two different, yet interlinked, health aspects: fighting the climate emergency, and improving air quality. Cf. our document
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EPHA Urges End to Monopoly Abuse in Pharma Sector

7 Jul 2020
Topic — EU strategy addressing pharmaceutical supply chains, innovation, and affordable medicine access.
Message — Review IP-related exclusivities and monopolies to improve medicine accessibility and affordability. Adopt alternative de-linkage models that separate research costs from final prices. Strengthen obligations for manufacturers to supply markets and introduce non-compliance sanctions.123
Why — Lower medicine costs would improve patient access and healthcare system sustainability.45
Impact — Pharmaceutical companies would lose market dominance and profits from reduced patent protections.67
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Response to EU Strategy on Adaptation to Climate Change

30 Jun 2020

The European Public Health Alliance (EPHA) is the largest European public health NGO advocating for better health. Our 82 member organisations encompasses public health NGOs, patient groups, health professionals, disease groups, academia and population group representatives working together to improve health and strengthen the voice of public health in Europe. Summary There is a need to develop a comprehensive approach for tackling the effects of the climate emergency. Especially considering the consequences of the COVID-19 pandemic, the European Union needs a public health driven, green recovery to help fight the climate crisis. To this end, the European Green Deal shall be strengthened to lead the European transition to a sustainable and healthy continent. EPHA’s position The climate emergency is a major threat to public health. According to the 2015 The Lancet report, systemic changes in ecological conditions and social dynamics will have far-reaching effects on human health and well-being, including via air pollution, heat waves, floods, water shortages, infectious diseases, respiratory and cardiovascular diseases, under-nutrition and mental ill-health. Therefore, the climate emergency is undermining the foundations of good health. However, the response to the climate emergency could also be the greatest global health opportunity of the 21st century and no one should be left behind. In 2020, the COVID-19 pandemic clearly demonstrated that the current economic model is not sustainable, and that the coronavirus outbreak is linked to climate and biodiversity. By lowering GHG emissions and air pollution levels, we can help the most vulnerable in their fight against COVID-19 and any other future pandemics. In many Member-states, the lockdown has significantly reduced GHG emissions. However, to prevent going back to pre-pandemics GHG emission levels, sustainable policies should be put in place to achieve low level emissions on the long-term. These goals could be achieved by ambitious European Green Deal targets. ....
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Response to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services

30 Jun 2020

The European Public Health Alliance (EPHA) appreciates the opportunity to provide feedback on the combined roadmap and inception impact assessment (IIA) for the Digital Services Act package: deepening the Internal Market and clarifying responsibilities for digital services. This initiative is particularly important given that the e-Commerce Directive was adopted 20 years ago when many of the current digital services (e.g. cloud-based services or large multi-service online platforms) and practices (e.g. widespread social media use), could not be foreseen. Moreover, it comes at a timely moment given that the COVID-19 pandemic has catapulted data-driven health and care services to the top of the public health agenda, with growing ethical concerns about the use of personal health data to strengthen health systems and enable better cooperation for pandemic surveillance. Overall, EPHA supports the idea of “creating an effective EU-wide governance of digital services through a sufficient level of harmonisation of rules and procedures”. The DSA package should contribute to addressing the problem identified in the Roadmap/IIA, ‘Risks for the safety of citizens online and the protection of their fundamental rights”. Establishing clear levels of accountability and ensuring that services established in third countries without legal establishment in the EU are covered by the EU legal framework, will be crucial in this regard. Many of EPHA’s member organisations represent the interests of vulnerable populations (homeless, migrants and Roma, older people, children, people with mental health conditions, etc.) who are more prone to online fraud, data misuse, and the influence of online advertising services promoting health-harmful products. Moreover, they are often victims of discrimination and stigma, and potentially more easily influenced by disinformation. For them, the increased deployment of Artificial Intelligence can both be a source of empowerment and of exclusion. However, when it comes to the specific problem of tackling health-harmful commercial communications, we strongly advocate the creation of a governance regime that, while striving for the highest possible standards of public health protection across the Union, provides Member States with the ability to maintain, adopt and enforce national legislation, especially where the latter goes beyond the applicable EU legislation. This is especially important in the context of minimising exposure to health-harmful commercial communications, such as for alcohol and unhealthy food. The Roadmap/IIA rightly points to the challenges posed by the dissemination of harmful content through digital advertising and the need to uphold the rights of the child. However, “harmful content” should not only be understood as disinformation through political advertising, and protecting children should go beyond addressing illegal content, such as hate speech or the dissemination of sexual abuse material. Several EU Council Conclusions (9977/17) (14082/17) call for a more effective approach to tackle the exposure of children and adolescents to unhealthy food and alcohol marketing, especially with a view to the rapid developments in digital media. Likewise, the Rights of the Child include the ‘right to health’, which can only be fulfilled with an effective approach to online marketing [UNICEF (2018) A Child Rights-Based Approach to Food Marketing: A Guide for Policy Makers]. Furthermore, alcohol use and unhealthy diet are important risk factors for non-communicable diseases, including cancers, and tackling them would contribute to the aims of Europe’s Beating Cancer Plan. In this light, the DSA package should address the ambiguities that exist today on the application of the e-Commerce Directive to online advertising. It should ensure that Member States can decide on their preferred level of public health protection and enforce the rules established within their own jurisdiction.
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Meeting with Stella Kyriakides (Commissioner)

11 Jun 2020 · Farm to Fork Strategy.

Meeting with Stella Kyriakides (Commissioner) and European Federation of Pharmaceutical Industries and Associations and

29 May 2020 · Video call with Pharmaceutical Industrial Associations, the European Medicines Agency and the European Centre for Disease Prevention and Control, to discuss Possible shortages of medicines and medical devices for the Covid-19 outbreak

Response to Development of Euro 7 emission standards for cars, vans, lorries and buses

24 Apr 2020

The European Public Health Alliance welcomes the European Commission’s initiative to develop stricter emissions standards for all petrol and diesel cars, vans, lorries, and buses. Especially in light of the consequences of the COVID-19 pandemic, the European Union needs a public health driven, green recovery to help fight the climate crisis. To this end, the European Green Deal shall be strengthened in order to lead the European transition to sustainable mobility, including zero-emission vehicles. The new European vehicle emissions standards “Euro 7/VII” will be vital in this strategy. The last EU vehicle emission standard must be implemented as soon as possible, to make sure that vehicles on European roads no longer endanger any lives due to their emissions. EPHA believes that the new Euro 7/VII standards shall contribute to a modal shift from car-based cities to walking, cycling, and public transport, wherever possible. These are the healthiest, the less polluting and most efficient transport options. Non-internal combustion engines should be preferred over conventional fossil fuel-powered vehicles because they are non-exhaust emission sources. For health, climate protection and environmental reasons, the vehicle emissions of air pollutants should be drastically reduced. Many pollutants emitted from automotive engines are dangerous to human health. Yet, they are poorly regulated or not regulated at all under the current Euro regulation nor the EU Air Quality Standards: all must be regulated. EPHA demands the EU air quality standards to be aligned with the latest WHO guidelines. Consequently, the Euro emissions standards and their enforcement should be strengthened. EPHA urges the European Union to end the sale of new diesel and petrol cars by 2028 (2032 for heavy duty vehicles larger than 26 tonnes), while progressively phasing out existing polluting vehicles from urban areas. It is important to strengthen the emissions regulation, especially the removal of the conformity factor for all pollutants, to ensure that vehicles meet the emission limits on the road, for all pollutants, under all possible driving conditions. Effective implementation is as important as the limits themselves. EPHA policy recommendations EPHA stresses the importance of more stringent Euro 7/VII standards as strict and as possible as soon as possible, and more crucially, alternative to combustion engines. That overarching principle should be mainstreamed and implemented in the technical regulation. The new standards must be aligned with the “zero pollution” ambition of the European Green Deal and with the goal of net zero greenhouse emissions by 2050. Limits must apply under all conditions all the time, including during DPF regeneration and throughout the vehicles’ lifetime. Particle pollution from brakes and tyres should be regulated as part of Euro 7/VII. The new standards must also introduce a roadmap to achieving 100% zero emission vehicles by 2028 (2032 for heavy duty vehicles larger than 26 tonnes).
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Response to 2030 Climate Target Plan

15 Apr 2020

The European Public Health Alliance (EPHA) is the largest European public health NGO advocating for better health. Our members encompasses public health NGOs, patient groups, health professionals, disease groups, academia and population group representatives working together to improve health and strengthen the voice of public health in Europe. The climate emergency is a major threat to public health. According to the 2015 The Lancet report, systemic changes in ecological conditions and social dynamics will have far-reaching effects on human health and well-being, including via air pollution, heat waves, floods, water shortages, infectious diseases, respiratory and cardiovascular diseases, under-nutrition and mental ill-health. Therefore, the climate emergency is undermining the foundations of good health. However, the response to the climate emergency could also be the greatest global health opportunity of the 21st century and no one should be left behind. EPHA calls for an ambitious plan at European level to reduce EU emissions and to become a climate-neutral continent. Indeed, based on the Emissions Gap Report 2019 by the United Nations Environment Programme (UNEP), the EU’s aim at cutting its greenhouse gas (GHG) emissions by at least 55% (instead of 40%) by 2030 compared to 1990 levels might not be sufficient to keep global heating to 2°C. The European Environmental Agency (EEA) also urges immediate and concerted action. Their “European Environment — State and Outlook 2020” study makes it clear that Europe is not making enough progress in addressing climate and environmental challenges. The EU commitment made in December 2019 is not up to the challenge anymore and more significant actions are needed to prepare for the next pandemic. In March 2020, the COVID-19 pandemic clearly demonstrated that the current economic model is not sustainable and that the coronavirus outbreak is linked to climate and biodiversity. By lowering GHG emissions and air pollution levels, we can help the most vulnerables in their fight against COVID-19 and any other future pandemics. In many member states, the lockdown has significantly reduced GHG emissions. However, in order to prevent going back to pre-pandemics GHG emission levels, sustainable policies should be put in place to achieve low level emissions on the long-term. These goals could be achieved by ambitious 2030 Climate targets. EPHA encourages the European Commission to go a step further. EPHA suggests a reduction of 65% GHG emissions by 2030 in order to be aligned with the Paris Agreement objective to keep temperature rise below 1.5°C. The UNEP report underlines that, to limit temperature rise to 1.5°C, all countries need to reduce their GHG emissions by 7.6% yearly between 2020 and 2030. It means that the European Union should have an emission reduction target of at least 65% by 2030 and should aim at climate neutrality by 2040.
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Response to EU post-2020 Roma policy

16 Mar 2020

The complexity of the social, economic and environmental factors affecting the health of Roma population requires an inclusive and comprehensive approach which looks beyond the area of health alone. Policy solutions should address all the factors responsible for the poorer health experienced by Roma communities and meet the needs of disadvantaged groups. Improving access to quality healthcare is not sufficient to close the gap in health as far as unemployment, spatial segregation, substandard living conditions, lack of clean water and sanitation, air pollution harm individual health. The European Public Health Alliance (EPHA) reiterates its recommendations on the post-2020 framework which remain valid and still await reaction from the European institutions. EPHA also calls for better cooperation between all stakeholders, including Roma communities in the development of social, economic, environmental, agriculture and human rights policies. Such synergies will strongly support the achievement of the objective of combatting social exclusion of Roma across Europe. Therefore, the framework should promote the bridge between Roma-related policy and major European policy initiatives such as Europe’s Beating Cancer Plan and European Green Deal to limit the climate consequences on Roma health and contribute to reaching the European objectives designed to achieve “a just transition” for all.
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Response to Farm to Fork Strategy

10 Mar 2020

The European Public Health Alliance (EPHA) strongly supports a comprehensive transition towards sustainable food systems, with health and well-being as a key pillar of sustainability. Together with other civil society organisations, EPHA views the Farm to Fork (F2F) Strategy as an important opportunity to deliver a coherent response to food-related challenges and pave the way towards an integrated, sustainable food policy for the European Union (EU). In the attached submission, EPHA highlights a number of priorities, stressing the need for: (A) genuinely transformative action; (B) the inclusion of an action plan for the creation of healthy and sustainable food environments; (C) to effectively tackle antibiotics use in animal farming; (D) to ensure adequate financing for the transition; and (E) to drive a global sustainable food systems transformation. A central pillar of the F2F strategy should be to facilitate the uptake of more healthy, plant-rich diets with less and better animal products. Addressing food consumption patterns is not about telling people what to eat, or about ‘imposing a global diet’. It means creating enabling food environments where the healthy and sustainable food options become the default, most attractive and affordable ones. Many good quality policies exist for the creation of health-enabling food environments: 1) Tackle unhealthy marketing and advertising through regulatory action; 2) Ensure easy-to-use and reliable consumer nutrition information; 3) Introduce healthy pricing policies; 4) Support sustainable public food procurement; 5) Drive product (re)formulation; 6) Create healthy retail, restaurant, urban and school environments; 7) Ensure independent nutrition education and information. To ensure the roll-out of such policies at both EU and national levels, as appropriate, the F2F Strategy should introduce a dynamically evolving “Action Plan for the creation of healthy and sustainable food environments”. This Action Plan should be (a) driven by targets, (b) guided by sustainable dietary recommendations, and (c) led by good policies. It should (d) introduce a dedicated framework of action towards less and better meat, dairy and eggs consumption and production in the EU, and (e) mainstream food and nutrition security into EU social policy initiatives. This Action Plan should be underpinned by an inclusive, transparent and structured governance processes that can evolve over time to address different actions to reshape food environments for the benefit of people and planet. EPHA emphasises that an exclusive focus on consumer information will neither be sufficient to advance the necessary food systems transition, nor deliver the necessary results for the European Green Deal and Europe's Beating Cancer Plan, nor answer to the aspirations of Europeans for a healthy, equitable and ecologically thriving continent. Rather, creating food environments that enable and empower healthy and sustainable choices will require a mutually reinforcing package of measures (see above). The F2F Strategy is the opportunity to put forward a framework for action in this field: an opportunity that must be taken.
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Response to Europe’s Beating Cancer Plan

3 Mar 2020

The European Public Health Alliance (EPHA) welcomes Europe’s Beating Cancer Plan as a flagship health initiative that can deliver real added value for Europeans. In response to the Road Map, EPHA highlights the following considerations: 1. The Plan should include a thorough and effective prevention pillar with special attention to tackling challenges common to all non-communicable diseases (NCDs). Cancers and other NCDs, such as cardiovascular disease, respiratory diseases and type 2 diabetes, are to a high degree preventable and share a number of common, modifiable risk factors - especially tobacco and alcohol use, unhealthy food environments, insufficient physical activity and air pollution. These risk factors are best addressed through cross-sectoral, population-based policies and legislation creating health-enabling living environments, rather than through excessive focus on behaviour change interventions which tend to put the burden on individuals. To reduce the incidence of cancers and other NCDs bold action on all the main risk factors will be required. 2. The Plan should prioritise the affordability, accessibility and availability of medicinal products in the field of oncology. Across Europe, unjustifiably high prices of medicines constitute one of the key barriers for patients in having access to cancer treatment. At the same time, it is imperative to evaluate the quality of innovation and to ensure that meaningful, needs-driven (as opposed to profit-driven) innovation reaches the patients. From a patient’s perspective, a drug that sits on a shelf because of its excessive price is not innovation but a mere invention that misses out on societal added value. 3. The Plan should recognise that patients from socially disadvantaged groups face higher rates of NCDs, including cancers, and are exposed to poorer access to healthcare and preventive services. As a consequence, survival rates among vulnerable groups are lower compared to population groups having a better socio-economic status. Therefore, prevention measures, as well as measures for early diagnosis should take into consideration the socio-economic dimension of cancer in order guarantee the access to appropriate services for the most vulnerable, including availability and affordability. 4. The Plan should recognise the importance of fighting antimicrobial resistance (AMR) as antibiotic resistant bacteria could threaten cancer care and its effectiveness. Immunocompromised patients such as cancer patients rely on antibiotics for infection prevention and treatment, and thus have a higher risk of developing resistance. Such resistance can have detrimental consequences especially since bacterial infections are one of the most common complications among cancer patients following radiation therapy and chemotherapy. 5. The Plan should contribute to the EU’s health in all policies mandate and should be effectively mainstreamed in other EU policies, including industrial, agriculture, transport and trade. It should consider introducing a monitoring and reporting mechanism about the measures taken in other policy areas to turn Europe’s Beating Cancer Plan into a success. 6. The Plan should recognise that cancer survivorship can have an impact on patients’ mental health and this should be considered and linked to the EU’s actions on mental health. 7. The Plan should be accompanied by meaningful funding streams and should ensure positive synergies with the work done under the Cancer Mission Board.
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Meeting with Annukka Ojala (Cabinet of Commissioner Stella Kyriakides), Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides)

28 Feb 2020 · Farm to Fork Strategy

Response to Climate Law

6 Feb 2020

The climate emergency is a major threat to public health. Runaway climate change will lead to systemic changes in ecological conditions and social dynamics with far-reaching effects on people's health and well-being, including through air pollution, heat waves, floods, water shortages, infectious diseases, respiratory and cardiovascular diseases, under-nutrition, mental ill-health and migration. [https://www.thelancet.com/climate-and-health/2015] The 2019 The Lancet Countdown on Health and Climate Change report demonstrates that the life of every child born today will be profoundly affected by the climate emergency, with populations around the world increasingly facing extremes of weather, food and water insecurity, changing patterns of infectious disease, and a less certain future. Without accelerated intervention, this new era will come to define the health of people at every stage of their lives. However, an alternative pathway with high policy ambition—which limits the global average temperature rise to “well below 2°C”—is possible, and would transform the health of a child born today for the better, throughout their lives. http://www.lancetcountdown.org/2019-report/ The Intergovernmental Panel on Climate Change (IPCC) identifies “low GHG-intensive food consumption” as a main pathway towards not exceeding a 1.5°C increase in global temperatures. A transition to sustainable, healthy diets can bring significant co-benefits for economy, climate and health. It can also create space to tackle antimicrobial resistance and other food systems challenges. Reducing GHG intensive consumption can contribute to lower agriculture related, air pollution EPHA 8 recommendations to be included into the EU climate law: 1. It shall be declared that the climate crisis has overarching, negative impact on public health and it endangers the health and the future of new generations. 2. The EU shall commit to immediate and concerted action, engaging diverse policy areas and actors across society in enabling systemic change to ensure climate neutrality before the middle of this century. 3. It shall reinforce the rigorous implementation of existing EU policies as regards climate and health pollutant emissions 4. All future EU policies shall include a climate impact assessment including health and well being impacts (the Lancet Countdown Climate change and health indicators could be a good basis for that https://www.thelancet.com/journals/lancet/article/PIIS0140-6736(19)32596-6/fulltext) 5. Include a legally binding target for greenhouse gas emissions reductions from agriculture. The global food system is responsible for up to 30% of anthropogenic greenhouse gas emissions. A significant body of academic literature shows that without a transition in food systems the required emissions reductions will not be reached. 6. The EU shall commit to mobilise its resources to invest in walking, cycling and improved public transport infrastructures, to achieve the shift in mobility and encourage modal shift 7. The EU shall explore and support with the legal, financial, coordination or promotion tools it has within its competences to foster ambitious policy options to make the commitments into tangible reality such as o revision of climate and health harmful air pollutant limits, o urban policies (including ultra low emission zones, congestion charging parking policies, car free days) o scrappage schemes, o kilometer tools, o tax measures and incentives, o expand zero emission vehicles, o encourage car sharing 8. The EU shall aim to end all sales of conventional fossil fuel-powered cars by 2028 and phase out all petrol and diesel cars by 2045.
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Meeting with Vytenis Andriukaitis (Commissioner) and

11 Sept 2019 · EU Platform for action on Diet, Physical Activity and Health

EPHA Urges Health Impact Assessment in Farm Policy Evaluation

14 Jun 2019
Topic — Evaluation of the Common Agricultural Policy’s contribution to rural socioeconomic development and cohesion.
Message — EPHA requests that health considerations be included as part of the impact assessment process. They highlight the obligation to pursue a high level of health protection.12
Why — Including health assessments would help ensure agricultural policies better support public well-being.3
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Meeting with Anne Bucher (Director-General Health and Food Safety)

20 Jan 2019 · courtesy visit, presentation of activities

Response to Establishing a legal limit for the industrial trans fats content in foods

25 Oct 2018

The European Public Health Alliance (EPHA) welcomes the European Commission’s intention to introduce a mandatory limit on trans-fats in food. Limiting the content of industrially produced trans-fat to a maximum of 2 grams per 100 gram of fat is appropriate to minimise related health harms. It also aligns with existing measures introduced in several European countries, including Denmark, Austria, Hungary, Latvia, Slovenia and Lithuania. The introduction of a legislative limit is firmly supported by evidence, which finds that a legal limit has the largest impact on reducing trans-fat consumption, and is probably the only option to effectively limit trans-fat intake in all population groups [1] [2]. Given the important health benefits to be achieved from this measure, EPHA urges all European Union (EU) Institutions to ensure a speedy adoption. The long transition period proposed however is regrettable. "strictly limiting prevalence of industrially produced trans fatty acids in all foods marketed in the EU could save about 50 000 lives every year. It may also save billions of euros in cardiovascular-related healthcare costs.” [3] [1] Downs et al. (2017) The Impact of Policies to Reduce trans Fat Consumption: A Systematic Review of the Evidence [2] World Health Organization Regional Office for Europe (2015) Eliminating trans fats in Europe – A policy brief [3] European Heart Network (2015) Trans fatty acids and heart disease
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Response to Evaluation of the EU agricultural promotion policy

7 Aug 2018

The European Public Health Alliance (EPHA) welcomes the opportunity to comment on the planned evaluation of the EU promotion policy for agricultural products. EPHA is of the opinion that the evaluation should not only assess how the policy is implemented, but should also focus on evaluating the relevance, effectiveness, efficiency, coherence and EU added value of the regulatory framework itself, in particular Regulation (EU) No 1144/2014. It should be pointed out that promotion policy is a demand-oriented policy, financing information and promotion campaigns that have the ultimate aim to increase the market share and consumption of certain European food products. This requires a special reflection on coherence with EU policies and commitments in the area of consumption, including those of Member States. The policy should also be analysed in light of coherence with the EU Treaties, especially Article 3(1) TEU, Articles 168 and 208 TFEU and Article 35 EU Charter of Fundamental Rights. Promotion policy is implemented in a context in which non-communicable diseases (NCDs), such as cardiovascular disease, diabetes and cancer, are responsible for 86% of all deaths and 77% of all diseases in Europe, amounting to healthcare costs of around €700 billion per year [European Commission (2014) Chronic Diseases: The health challenge of our Times]. Unhealthy diet and the excessive intake of alcohol are leading, and largely preventable, risk factors for NCDs, both in Europe and worldwide [Global Burden of Disease]. Increased awareness about the human and economic burden of consumption-related ill-health is prompting international policy action aimed at creating healthier food and drink environments and tackling alcohol-related harm. For consumers, health is an increasing concern as well. A future-oriented strategy to enhance the competitiveness of the European agricultural and food sectors would therefore focus on promoting those products that form the basis of diverse, healthy and sustainable diets, as set out in dietary guidelines. A methodology for linking the policy to these guidelines should be elaborated with input from qualified, independent experts. This evolved framework would entail the exclusion of alcoholic drinks from promotion policy. The continued allocation of public resources to the promotion of alcohol, while the harmful use of alcohol is a leading causes of premature mortality, is not a legitimate or efficient use of public funds. The continuous support for alcohol promotion is incompatible with the EU’s efforts to deliver on the Sustainable Development Goals (SDGs) and impairs policy coherence with other EU objectives, such as the 2006 ‘European Union strategy to support Member States in reducing alcohol related harm’ and policy coherence for development [Art 208 TFEU]. EPHA looks forward to continued engagement in the policy evaluation process.
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EPHA urges EU to align agricultural policy with health goals

2 Aug 2018
Topic — This consultation addresses the legislative framework for the Common Agricultural Policy’s strategic plans.
Message — EPHA requests the reform prioritize outcomes that promote health and prevent diseases. They demand a Health Impact Assessment and better availability of nutritious products.123
Why — Policy alignment would help the group fulfill its mandate of protecting well-being.4
Impact — Wine producers lose significant public subsidies currently used for alcohol promotion.5
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Meeting with Annika Nowak (Cabinet of Commissioner Vytenis Andriukaitis) and DSW (Deutsche Stiftung Weltbevoelkerung) and GLOBAL HEALTH ADVOCATES

18 Jul 2018 · Horizon Europe

Meeting with Alina Timofte (Cabinet of Commissioner Vytenis Andriukaitis), Annika Nowak (Cabinet of Commissioner Vytenis Andriukaitis) and European Chronic Disease Alliance

18 Jul 2018 · Non communicable diseases

Meeting with Vytenis Andriukaitis (Commissioner) and

1 Jun 2018 · Pharmaceuticals in the environment

Meeting with Vytenis Andriukaitis (Commissioner) and

15 May 2018 · HTA

Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström), Pedro Velasco Martins (Cabinet of Vice-President Cecilia Malmström) and

15 May 2018 · Access to medicines in poor countries

Meeting with Marco Valletta (Cabinet of Commissioner Vytenis Andriukaitis) and WWF European Policy Programme and Greenpeace European Unit

25 Apr 2018 · Common Agricultural Policy reform

Response to Protecting citizens against health threats

23 Apr 2018

The European Public Health Alliance (EPHA), Europe’s largest public health umbrella organisation, welcomes the European Commission’s initiative to strengthen its activities related to global health security and public health emergency preparedness and response. In particular, we endorse the One Health approach of the Roadmap and would like to underline that, in a globalised world marked by international flows of trade and people, it is essential to ensure policy coherence between actions against infectious diseases and other threats to public health including antimicrobial resistance (AMR), healthcare-associated infections (HAI), and pharmaceuticals in the environment. Therefore we are pleased that this initiative complements the EU One Health Action Plan against AMR, as well as EU activities to strengthen cooperation against vaccine-preventable diseases. Moreover, it is a positive sign that the One Health approach will be applied given the growing importance of combatting outbreaks of zoonotic infectious diseases and to adopt a holistic vison that couples safeguarding of human and animal health with ensuring sustainable food production and environmental protection. However, the scope of the Roadmap is too limited; it should also include actions to address tuberculosis (TB), hepatitis and HIV/AIDS, diseases that continue to be a major global health burden and whose treatment and further spreading is directly affected by the lack of a joined-up vision that connects them to other cross-border threats like AMR. For example, multi-drug resistant tuberculosis remains a serious problem in some Member states (e.g., Romania), and the European Centre for Disease Prevention and Control (ECDC) highlights that only about 35% of MDR TB patients have a successful treatment outcome in the EU/EAA, which is well below the 75% treatment success target defined by the Tuberculosis action plan for the WHO European Region 2016–2020. Overall, it is very important that the European Commission assumes a leading role in developing a comprehensive yet actionable One Health strategy given Europe’s economic and social power to influence other regions of the world, its public health capacity, and its vital importance as a global hub for research and innovation. European leadership is particularly important with a view to attaining the UN Sustainable Development Goals, the majority of which are either directly or indirectly dependent on the need to strengthen global health security. To ensure better collaboration between the EU and its national and global partners, EPHA supports that the ECDC’s remit and funding are significantly increased in order for the Agency to expand its work and establish the necessary epidemiological connections between the areas mentioned above. Moreover, we highlight the need to formally include civil society organisations in One Health discussions in order to contribute “real world” evidence and ensure that actions against infectious diseases, AMR, vaccination and related areas do not occur in isolation. To this purpose, the Commission should consider extending the composition and scope of the AMR-One Health Network to broaden the debate.
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Meeting with Jerzy Bogdan Plewa (Director-General Agriculture and Rural Development) and Freshfel Europe - the forum for the European fresh fruits and vegetables chain and European Heart Network

27 Mar 2018 · exchange of view on the Communication on Food and Farming

Meeting with Frans Timmermans (First Vice-President) and Stichting BirdLife Europe and CSR Europe, The Business Network for Corporate Social Responsibility

20 Mar 2018 · handover of the position paper of the SDG multi-stakeholder Platform on MFF

Response to VAT rates proposal

19 Mar 2018

The European Public Health Alliance (EPHA), Europe’s leading NGO alliance advocating for better health, welcomes this opportunity to comment on the Commission's VAT proposal. There is consistent evidence that price interventions can be effective health promotion tools. A 2015 World Health Organization technical meeting concluded that there is "reasonable and increasing evidence" [1] that appropriately designed financial tools can create healthier food and drink environments, thereby enabling better consumption choices. There is full consensus on the health benefits of fruit and vegetables, and the need to promote their consumption. Reducing the cost of fresh/minimally processed fruit and vegetables to consumers has been consistently identified as one of the most promising strategies to this end. In France a modelled 3.4% reduction in VAT on fruit and vegetables increased mean consumption by 4.8 g/day [2]. A Finnish study modelled the removal of VAT on fresh fruit and vegetables resulting in increased demand. A Dutch intervention study in a web-based supermarket found that a 25% discount on fruit and vegetables was effective in stimulating a considerable increase in the purchase of those products [3]. In this light, EPHA welcomes the flexibility this proposal provides for Member States to reduce VAT rates below the 5% threshold in pursuit of an "objective of general interest." EPHA recommends that the potential to vary VAT rates for the benefit of healthier nutrition is referenced in the recitals to the Directive, and that public health is specifically highlighted as one of the objectives of general interest that can be pursued by Member States. A consistent health-based VAT system would also apply higher rates to non-essential foods, such as energy dense, highly-processed foods high in fat, sugar and/or salt. It should be noted in this regard that vulnerable populations, including low-income consumers, are most price-responsive and, in terms of health, benefit most from changes in the relative prices of foods and beverages. [1] World Health Organization (2015) Fiscal Policies for Diet and Prevention of Noncommunicable Diseases, http://bit.ly/2dKV2nW [2] http://bit.ly/2u03drJ [3] http://bit.ly/2GH7DGH [4] http://bit.ly/2u1nxsE
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Response to Evaluation of the CAP measures applicable to the wine sector

7 Dec 2017

The European Public Health Alliance (EPHA) is Europe’s leading alliance advocating for better health. As a member of DG AGRI Civil Dialogue Groups, EPHA welcomes the European Commission’s initiative to evaluate the impacts of Common Agricultural Policy (CAP) measures applicable to the wine sector. Article 168 of the Treaty for the functioning of the EU states “A high level of human health protection shall be ensured in the definition and implementation of all Union policies and activities.” This evaluation provides an important opportunity to fulfil this obligation and assess the coherence between public health and CAP wine measures. It is particularly crucial that the public health impact of wine sector measures should be considered in this evaluation because, as an alcoholic product, wine is a health sensitive product. EPHA calls on the Commission to consider the following aspects. Purpose and scope - In the evaluation of the new rules regarding vine planting, the impact on production area (increase or decrease) should be covered. The vine planting rules which require Member States to authorise 1% increase in vine planting annually, has been projected to potentially result in a 16% increase in production area by 2030. [Article 63 CMO Regulation] - The evaluation should analyse the use of public funds that have been spent under the Common Market Organisation article 39 (which enables the attribution of EU funds to Member States “to finance specific support measure to assist the wine sector”) and to what extent this funding, in particular for vineyard restructuring and wine promotion, is consistent with the aims pursued under Article 168 TFEU. - Following the 2014 European Court of Auditors warning that CAP support to the wine sector leads to administrative burden and that the promotional element often constitutes a hidden operational subsidy for wine [ECA, 2014, http://bit.ly/2n1QSPP], it is important to evaluate the impact and the market orientation of funds for wine. - In considering the impact of labelling rules, the evaluation should cover the impacts on public health and consumer interests of including ingredients lists, nutritional values and warning labels on wine labels. - In evaluating the added value of the measures, the Commission should include a consideration of the external costs of increased or subsidised alcohol production covering the consumption part of the product chain, e.g. healthcare costs related to alcohol use and alcohol harm, rather than simply the impacts upon production. - As part of the fitness check, the relationship between the national allocation of CAP promotion funds for wine beyond the EU and consumption trends in those countries should be investigated. The links between this funding and alcohol harm and the incidence of non-communicable diseases (NCDs) related to alcohol consumption in these countries should also be analysed. - Lastly, the scope should include the evaluation of hypothetical measures to support farmers to diversify their production away from wine in order to tackle oversupply. The evaluation should cover the impacts this would have on farmers income, productivity, product quality and public health, in comparison with current measures. Consultation - As part of the consultation, public health actors should be directly consulted, as well as being included via Civil Dialogue Groups and the online public consultation. - The Commission’s online consultation should include questions on how the CAP’s wine sector measures have contributed to EU health goals, including the Sustainable Development Goals (especially SDG 3) and the fulfilment of EU treaty provisions (e.g. art. 168) - Finally, we emphasise that the public consultation should include questions on the public health effects of the relevant measures and not focus only on practical experiences of their implementation. Please find attached more detail on the CAP's wine measures and public health.
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Response to Initiative to improve the Food Supply Chain

22 Aug 2017

The European Public Health Alliance (EPHA) is Europe’s leading NGO alliance advocating for better health. EPHA, as member of the High Level Forum on the Better Functioning of the Food Supply Chain, DG AGRI Civil Dialogue Groups, the EU platform for action on diet, physical activity and health, and other forums welcomes the European Commission’s commitment to improve the functioning of the food supply chain. The food supply chain is central to the well-being of European citizens, the economy and environment. The 2017 consultation on the future of the EU Common Agricultural Policy showed wide support among all stakeholders for the objective that agricultural policy should encourage the “supply of healthy and quality products” to the European market. Today, unhealthy diet is the single largest risk factor for all healthy life years lost in the EU (Global Burden of Disease, http://ihmeuw.org/468u). The 2016 EU Council Conclusions on food product improvement note that the “prevalence of overweight, obesity and other diet-related non-communicable diseases in the European population is too high and is still rising. This has a negative impact on life expectancy, reducing Union citizens' quality of life and affecting society”, and that “for people's diet to improve, the healthy choice should be the easy choice”. EPHA calls on the Commission to consider the following aspects under this road map: • It is noted that unfair trading practices (UTPs) could stifle innovation in the food chain. The Commission should add consideration whether UTPs could prevent the entry onto the market of new suppliers or new products that offer healthier options to citizens. Should this be the case, this could warrant more robust action among the presented policy options i.e. 3 or 4. • The health-promoting qualities of fresh fruit and vegetables are well-known, but Europeans do not consume enough of them. The EU-OECD publication Health at a Glance 2016 (http://bit.ly/2jA9yEE) notes that “the availability of fruit and vegetables is the major determinant of consumption”. The Commission should ensure that the policy options it presents will afford sufficient protection for producers of these perishable, and thus extra vulnerable, products in order to improve the prospects of farmers in the horticultural sector. • The 2013 JRC publication on Short Food Supply Chains and Local Food Systems in the EU (http://bit.ly/1WYqU97) notes that there is evidence that short chains can deliver social and economic benefits for both producers and consumers as well as for rural development and “may even result in behavioural changes (eating habits with public health effect e.g. on obesity”. Next to addressing the unfair trading practices, the Commission should consider options on how to enable the flourishing of such short chains and local food systems by considering which incentives may be required and which barriers to be removed. This should be an integral part of the commitment to create a better functioning food system in the EU.
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Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella), Lanfranco Fanti (Cabinet of Vice-President Karmenu Vella)

18 Jul 2017 · Pharmaceuticals in Water

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

16 Jul 2017 · Action plan on Antimicrobial Resistance & roadmap on pharmaceuticals

Public health group urges CAP climate review to address diets

5 Jul 2017
Topic — This consultation evaluates the Common Agricultural Policy's contribution to climate mitigation and emissions.
Message — EPHA calls for the evaluation to use complete data, including emissions from imports and land use. They recommend assessing production shifts toward plant-based diets and modeling healthy eating patterns.12
Why — Including health metrics in agricultural policy helps EPHA promote nutritional security and sustainable consumption.3
Impact — The meat and dairy sectors face scrutiny and potential loss of production incentives.4
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Meeting with Ann Mettler (Director-General Inspire, Debate, Engage and Accelerate Action)

15 Jun 2017 · Public Health and the Future of Europe

Meeting with Annika Nowak (Cabinet of Commissioner Vytenis Andriukaitis), Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis), Paula Duarte Gaspar (Cabinet of Commissioner Vytenis Andriukaitis)

28 Apr 2017 · Antimicrobial resistance and the outlook for the forthcoming action plan, as well as health in the Semester and Social Pillar

Meeting with Vytenis Andriukaitis (Commissioner) and

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

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

27 Jan 2017 · • discussion of how to build on collaboration with civil society to further develop and support EU health policy

Health groups urge EU to adopt stricter vehicle emission rules

7 Dec 2016
Topic — Consultation on the third package of real-world driving emission standards for light vehicles.
Message — The coalition demands that national experts endorse the new testing rules immediately. They want the 2018 deadline maintained and require that emission test results are made public.123
Why — Stricter rules will lower healthcare spending by reducing chronic diseases caused by pollution.4
Impact — The car industry would lose the flexibility to exceed particulate number emission limits.5
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Meeting with Vytenis Andriukaitis (Commissioner) and

17 Nov 2016 · Roundtable on the future of the General Food Law Regulation

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

6 Sept 2016 · To discuss the final confeserence session and how EPHA could support the EFC on AMR

Meeting with Annika Nowak (Cabinet of Commissioner Vytenis Andriukaitis)

26 Nov 2015 · AMR

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

28 Oct 2015 · Better Regulation agenda, Health in all policies approach and civil society involvement

Meeting with Vytenis Andriukaitis (Commissioner) and

19 Mar 2015 · Chronic Disease - EU Action

Meeting with Frans Timmermans (First Vice-President) and EUROPEAN TRADE UNION CONFEDERATION and

3 Mar 2015 · Better regulation