Santen SA
Santen Pharmaceutical is one of the world’s leading specialist ophthalmic pharmaceutical companies, founded in Japan over a century ago and now serving patients all over the world.
ID: 398745794163-67
Lobbying Activity
Response to Digital Fairness Act
15 Oct 2025
We welcome the Commissions initiative to regulate digital fairness and protect consumers, notably children and youth, from unfair digital practices. This submission is provided by Santen, supported by a Joint Policy Statement on childrens eye health developed with a multistakeholder coalition, attached for reference. While the primary emphasis of the Digital Fairness Act is rightly placed on protecting children online from manipulative practices such as unfair personalisation and harmful addictive design features, we urge consideration of the deeper public health consequences linked to prolonged digital exposure in children. Excessive time spent online, propelled by addictive digital features, has a direct and escalating impact on childrens eye health, particularly driving the epidemic rise in myopia (near-sightedness) among European youth. The Joint Policy Statement highlights how digitalisation and sedentary lifestyles are significantly increasing screen time from an early age, intensifying eye strain and disrupting childrens visual development. Projections indicate that up to 50% of the global population will be myopic by 2050, with school-leavers in Europe expected to reach this threshold by 2035 if current trends persist. The Digital Fairness Acts scope to curb addictive design and promote digital well-being offers a vital entry point to address these public health challenges linked to excessive screen time. Prolonged exposure to digital screens significantly increases risks of eye strain, dry and irritated eyes, and myopia progression, conditions which affect childrens visual comfort and long-term eye health. Beyond physical eye health, these vision problems have profound educational consequences: children with impaired vision learn less effectively, with research indicating such children may achieve only half as much as their peers with healthy eyesight, impacting their academic performance and lifelong opportunities. Moreover, the mental health effects associated with poor eye care and chronic visual impairment include increased anxiety, mood disorders, social exclusion, and lowered self-esteem. Excessive screen time driven by addictive digital features compounds these issues by fostering sedentary behavior and reducing time outdoors a key protective factor against deterioration of vision. Integrating these health dimensions into the Digital Fairness Act can help protect children from a multifaceted harm landscape that includes educational setbacks, mental health challenges, and increased healthcare burdens. We recommend the Act explicitly incorporate public health safeguards linking digital fairness to childrens visual health, including: Requiring platforms to minimise addictive digital features that promote prolonged screen time, especially in childrens content and educational tools. Encouraging digital education models that balance screen use with time outdoors and breaks to protect eye health. Promoting transparency and user empowerment about potential health risks associated with digital products. Supporting access to regular vision screening and timely interventions to detect and manage early eye health issues aggravated by digital exposure, including promoting outdoor activities to reduce eye health disorders risk (especially myopia); conducting regular eye health examinations to catch progressive conditions early, including through in-school screenings; establishing referral pathways between primary care, schools, and specialised eye care; and providing timely treatment interventions following screenings. Childrens eye health is a fundamental but often overlooked dimension of digital fairness. Aligning the Digital Fairness Act with evidence-based health strategies will strengthen protections for the well-being of young Europeans, supporting healthier digital environments today and better visual outcomes tomorrow. [For references, kindly refer to the Joint Policy Statement]
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