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Norwegian Cancer Society

NCS

NCS works continuously to improve society’s attitude to the prevention and treatment of cancer.

Lobbying Activity

Response to Union prevention, preparedness, and response plan for health crises

29 Oct 2025

Consultation response from the Norwegian Cancer Societyregarding the EU Union plan for Health Crisis Prevention, Preparedness and Response The Norwegian Cancer Society (NCS) welcomes the European Commissions initiative to establish a Union Plan for health crisis prevention, preparedness, and response. We strongly support the ambition to strengthen EU-wide coordination and resilience in the face of serious cross-border health threats. As a patient organization for individuals affected by cancer, we wish to highlight several critical areas where the plan should deliver tangible improvements: 1. Antimicrobial resistance (AMR) We commend the inclusion of antimicrobial resistance (AMR) as a strategic priority, as AMR poses a direct and growing threat to cancer care. Antibiotics are a critical component of cancer care. Many cancer treatments, including chemotherapy, radiation therapy and surgery, compromise the immune system, leaving patients highly vulnerable to infection. As many as one in five cancer patients require antibiotics during their treatment. Without access to effective antibiotics, modern cancer care risks being set back decades. Approximately 40% of antibiotics used in Norways primary care are penicillins, yet few European producers remain. Production has largely shifted to countries with lower costs, increasing the risk of supply disruptions due to accidents, contamination, or geopolitical instability. We urge the Commission to: Explicitly recognize cancer patients as a high-risk population in AMR-related preparedness planning. Include oncology-critical antibiotics in EU-level stockpiling and procurement strategies. Invest in antimicrobial research and innovation. 2. Cancer-specific preparedness and access to essential cancer treatment Cancer patients are particularly vulnerable in times of health emergencies. The global supply chain for cancer medicines is fragile and concentrated. Many smaller countries are highly dependent on imports of medical equipment and pharmaceuticals. The Union Plan must ensure that cancer patients have equal and safe access to essential medicines such as antibiotics, vaccines, and cancer treatmentseven during health crises. To address vulnerabilities and protect cancer patients, the plan should: Strengthen EU-level production capacity for essential medicines, including generic oncology drugs. Support diversified, transparent, and resilient supply chains Establish contingency mechanisms for rapid response to shortages, including coordinated stockpiling and joint procurement. Prioritize cancer patients in vaccination strategies, treatment access, and risk communication. Reflect cancer-specific needs in EU preparedness frameworks. Involve patient organizations in planning and decision-making processes. 3. Holistic and climate-responsive approach We welcome the plans holistic approach, particularly its integration of the One Health framework and climate-related health threats, which are increasingly linked to cancer incidence and outcomes. The accelerating climate crisis and shifting geopolitical landscape demand coordinated, cross-sectoral responses. We urge the European Commission to ensure that the Union Plan delivers concrete, lasting improvements for cancer patients across Europe. By addressing AMR, securing access to medicines, protecting vulnerable populations, and embedding cancer into broader preparedness frameworks, the EU can help safeguard the continuity and quality of cancer care both in times of crisis and beyond. The Norwegian Cancer Society remains committed to supporting this process and welcomes further opportunities to contribute.
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Meeting with Stella Kyriakides (Commissioner) and

15 Apr 2024 · Meeting on Europe's Beating Cancer Plan and EU Policy on cancer

Response to Targeted revision of the EU system of tobacco traceability

30 Nov 2022

The Norwegian Cancer Society (NCS) welcomes the invitation for feedback to review the 2017 rules that set out EU standards on tracking and tracing of tobacco products. The system has been running for more than 3 years. In the absence of a report from the Commission we find it difficult to assess its effectiveness. While we strongly supported the establishment of the EU Tracking and Tracing system, we are mindful of its weaknesses. In the EU system, the tobacco manufacturers and importers nominate data repositories and auditors. The industry nomination must undergo approval by the European Commission based on criteria for independence established in secondary legislation. We regret that several of the appointed data repositories had long standing, documented relationships with the tobacco industry. Consequently, there is evidence to indicate that the control mechanisms may be under the influence of the tobacco companies which pay and choose the auditors. In addition, the scope of the duties for auditing is too limited. According to Article 15.8, auditors should assess any irregularities in relation to access of the data storage facilities, but not whether the companies which generate the unique identifiers for the Member States use questionable software from the providers that have links with the tobacco industry. Parties to the FCTC, including the EU and 18 of its Member States, adopted and ratified the Protocol to Eliminate Illicit Trade in Tobacco Products (ITP). The ITP requires Parties to establish independent tracking and tracing systems and not to delegate their responsibilities under the Protocol to the tobacco industry. It is apparent to NCS that the European Commission is shirking some of its responsibilities by delegating them to the tobacco industry. NCS recommends that, in line with Article 8 of the Protocol, industry involvement in the EUs tracking and tracing system be limited strictly to absolutely necessary involvement and we suggest the following steps for achieving this: - strengthening the independence criteria for data storage facilities and companies who generate the unique identifiers - selecting auditors and data storage facilities by Member States or the Commission - publishing the auditors reports and the names of the auditors - extending the scope of audits to assess the way unique identifiers are generated particularly without the use of questionable software.
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Response to Revised recommendation on smoke-free environments

18 Jul 2022

It is estimated that more than 25% of Europeans currently smoke. Tobacco consumption kills nearly 700 000 Europeans every year. Second-hand smoke increases the risk of cancer, particularly of the lung, even in people who have never smoked themselves. A report by the European Environment Agency focusing on second-hand smoke estimates that on average, 31% of the European population is exposed to second-hand tobacco smoke at home, at work, during leisure activities, in educational institutions or in public settings. That exposure can be significantly reduced by implementing total smoking bans in public places. There is no safe level of exposure to tobacco smoke. Conservative estimates concluded that more than 70 000 non-smokers in the EU died in 2002 due to exposure to tobacco smoke. 100% smoke-free environments are proven ways to adequately protect the health of people from the harmful effects of second-hand tobacco smoke. Smoke-free laws protect the health of non-smokers. They are popular among both tobacco users and non-users. An opinion poll conducted in Norway in 2021 shows that 95% of the population believe that smoking should be forbidden in cars where children are present, 91% support smoke-free playgrounds, 80% are for smoke-free sports arenas, smoke-free outdoor terraces of bars and restaurants. Polls in Sweden produced similar results. Smoke-free policies contribute to prevent smoking initiation as well as encourage smokers to quit. In addition to the health impact of tobacco smoke, tobacco-related waste (empty packs, cigarette butts, etc.) are common litters on our streets, sidewalks, beaches, station platforms, bus shelters, portions of the street at the exit of nurseries, schools and public buildings, outdoor playgrounds for children, café terraces and restaurants, among others etc. The Norwegian Cancer Society (NCS) is for as many tobacco-free environments as possible. This includes indoor, outdoor and quasi-outdoor spaces. Smoking around families, children, or elderly people should be prohibited. Smoking is a habit which should not be allowed to threaten the health of non-smokers. The Council must act swiftly to keep our forests, streets, parks, rivers and gardens clean from tobacco smoke and waste. Public health should trump individual freedom and smoke-free spaces should be the norm. European authorities should adopt regulations which prioritise their citizens’ health and the environment over the interests of commercial actors. The scope of the recommendations of the European Council should be extended to heated tobacco products (HTPs) and electronic cigarettes (e-cigarettes). HTPs expose users to toxic emissions, many of which cause cancer and other non-communicable diseases (NCDs). There is not enough evidence to suggest that HTPs are less harmful than conventional cigarettes. Evidence on the effects of second-hand emissions produced by HTPs at present is also lacking, but it is proven that emissions from these products contain harmful and potentially harmful chemicals. So, they should not be used in areas where combustible cigarettes are prohibited. A Systematic review of global evidence on the health outcomes of e-cigarettes commissioned and funded by the Australian government clearly emphasise that regulations on the promotion and use of e-cigarettes and HTPs should be tightened. The report provides strong evidence that the use of e-cigarettes can cause respiratory disease. The more serious health impacts of traditional combustible cigarettes are manifested 40 to 60 years after initiation. E-cigarettes and HTPs have been used for less than 20 years. Therefore, it is premature to conclude that they are safe or less harmful to use. Where e-cigarettes are not banned, the WHO recommends that they be strongly regulated to minimize health risks for users and protect non-users from exposure to their aerosols/ emissions. The NCS fully endorses the WHO’s recommendations and urges the EU to do the same.
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