Consultations

Official CCC Reponses and Consultations.

[UK] ADVANCING OUR HEALTH: PREVENTION IN THE 2020s

What ideas should the government consider to raise funds for helping people stop smoking?

We believe that innovate harm-reducing alternatives can not only help people reduce harmful exposure, and even help them quit smoking regular tobacco, but also achieve that goal without the need for government funds. 

The UK’s permissive approach to e-cigarettes has shown a positive impact. According to the NHS, between 2011 and 2017, the number of UK smokers fell from 19.8% to 14.9%. At the same time, the number of e-cigarette users rose: almost half of these consumers use e-cigarettes as a means of quitting smoking. Public Health England has confirmed that e-cigarettes are 95% safer than conventional cigarettes. Therefore, consumers should be afforded the choice of vaping. 

We also do not believe that an aggressive approach to the matter will help with smoking cessation. Strict anti-tobacco measures have shown to be regressive, and tend to push and seal consumers in the black market for a long time. Smoking cessation is a difficult task, that can be achieved through harm reducing alternatives, such as e-cigarettes, heat-not-burn products, or snus (which is illegal in the European Union, except for Sweden). 

How can we do more to support mothers to breastfeed?

While breastfeeding is commendable, as it might advance the physical well-being of the child, it should be noted that not all mothers are able to provide the necessary quantity. This can lead to dehydration of the infant, leading to serious medical conditions. For those mothers, infant formula is a necessary alternative. We therefore support the continued zero-rating for VAT on baby milk.

Furthermore, the CCC supports the continuation of the Equality Act 2010, which allows mothers to breastfeed in all public places.

However, breastfeeding remains an individual choice of the mother, and can and should not be imposed. This is an intimate choice to be made by a mother, in which law-makers should not have a say.

How can we better support families with children aged 0 to 5 years to eat well?

It remains a continuous challenge to improve the nutrition of young children. This responsibility lies with the parents, you serve the function of caretakers and educators. In the age range of 0 to 5, this responsibility is most pronounced, and should be taken seriously. The Consumer Choice Center believes that parents have a moral obligation to inform themselves about healthy nutrition for their children. However, the reversal of the food pyramid has shown that institutionalised nutritional guidance can lead to adverse effects. The Harvard School of Public Health has pointed out that the food pyramid “conveyed the wrong dietary advice”. It also says: “With an overstuffed breadbasket as its base, the Food Guide Pyramid failed to show that whole wheat, brown rice, and other whole grains are healthier than refined grains.” The CCC is therefore sceptical about the idea of government-advised diets for children.

The obligation of parents to make informed choices about the nutrition of their children does not end at the age of 5. Quite on the contrary, as children get to the age of being able to be active in sports, they need to be encouraged to do so.

In October last year, Public Health England indicated that more than 37 percent of 10 and 11 year-olds in London are overweight or obese. It is often mistakenly argued, for this age, that this is caused by high energy intake, but the obesity rates are dependent on the physical activity, which according to Public Health England has decreased by 24 per cent since the 1960s. Daily calorie intake in the UK is also decreasing each decade.

Furthermore, the government should look towards relieving regulatory measures that increase the price of healthy foods.

How else can we help people reach and stay at a healthier weight?

It is often mistakenly argued that the obesity crisis is caused by high energy intake, but the obesity rates are dependent on the physical activity, which according to Public Health England has decreased by 24 per cent since the 1960s. Daily calorie intake in the UK is also decreasing each decade.

Physical activity is therefore paramount. Local government should foster and encourage the creation of outdoor fitness places, and facilitate the creation of interesting and safe public walkways, which can be used for physical exercise. The CCC also believes that community sports programmes should be a part of the government strategy on tackling obesity.

Have you got examples or ideas that would help people to do more strength and balance exercises?

Physical activity is paramount. Local government should foster and encourage the creation of outdoor fitness places, and facilitate the creation of interesting and safe public walkways, which can be used for physical exercise. The CCC also believes that community sports programmes should be a part of the government strategy on tackling obesity.

What are the top 3 things you’d like to see covered in a future strategy on sexual and reproductive health?

As of now, the UK applies a VAT rate of 5% on condoms. The Consumer Choice Center supports an exemption of these products from VAT. Condoms are not luxury sanitary products — they are essentially for advancing sexual and reproductive health, and guarantees the choice of consumers.

[UK] The regulation of genetic technologies

Currently, organisms developed using genetic technologies such as GE are regulated as genetically modified organisms (GMOs) even if their genetic change(s) could have been produced through traditional breeding. Do you agree with this?

Answer: No – they should not continue to be regulated a GMO

Please explain your answer, providing specific evidence where appropriate. This may include suggestions for an alternative regulatory approach.

The United Kingdom should strive to be in line with the Cartagena Protocol, and not treat organism developed using GE as GMOs, if they could have been produced through traditional breeding. An accurate risk-assessment should be based on the individual organism, not on the technology that produced it. In that sense, the UK should diverge from existing EU legislation, and the associated ECJ ruling of 2018.

Do organisms produced by GE or other genetic technologies pose a similar, lesser or greater risk of harm to human health or the environment compared with their traditionally bred counterparts as a result of how they were produced?

Please provide evidence to support your response including details of the genetic technology, the specific risks and why they do or do not differ. Please also state which applications/areas your answer relates to (for example: does it apply to the cultivation of crop plants, breeding of farmed animals, human food, animal feed, human and veterinary medicines, other applications/ areas).

The question does not do the complexity of the issue justice. Making general statements of safety for all products derived through genetic engineering is not possible, nor desirable. In fact, the perspective of regulating by technology, not by organism, is a failure of EU policy, which should be revisited. The technology of genetic engineering is a means to an end, of which we cannot make blanket statements.

Are there any non-safety issues to consider (e.g. impacts on trade, consumer choice, intellectual property, regulatory, animal welfare or others), if organisms produced by GE or other genetic technologies, which could have been produced naturally or through traditional breeding methods, were not regulated as GMOs?

 Yes

Please provide evidence to support your response and expand on what these non-safety issues are.

Non-safety issues that are to consider is the legality of GMOs restrictions in the jurisdictions of trading partners. If the European Union does not allow for the import of gene-edited organisms because of its GMO Directive, then this has trade implications that can activate international dispute mechanisms.

There are a number of existing, non-GM regulations that control the use of organisms and/or products derived from them. The GMO legislation applies additional controls when the organism or product has been developed using particular technologies. Do you think existing, non-GM legislation is sufficient to deal with all organisms irrespective of the way that they were produced or is additional legislation needed? Please indicate in the table whether, yes, the existing non-GMO legislation is sufficient, or no, existing non-GMO legislation is insufficient and additional governance measures (regulatory or non-regulatory) are needed. Please answer Y/N for each of the following sectors/activities:

Cultivation of crop plants: Yes
Breeding farmed animals: Yes
Human food: Yes
Animal food: Yes
Human and veterinary medicines: Yes
Other sectors/activities: Yes

Source: https://consult.defra.gov.uk/agri-food-chain-directorate/the-regulation-of-genetic-technologies/

[EU] Tobacco taxation – excise duties for manufactured tobacco products

To whom it may concern,

Beating cancer in the EU remains one of our biggest priorities as a society and therefore, we need to approach this issue in a smart way using a science-based approach that enhances consumer choice.

Taxation is intended to push consumers away from particular products – in this case, cigarettes. What policymakers tend to overlook, though, is that demand for cigarettes is inelastic and taxes – along with other restrictions and bans – cannot substantially affect consumer behaviour. Consumers should be seen as individuals responsible for their wellbeing who make a voluntary informed decision to smoke. The EU should seek to preserve consumer choice and encouragement might be a more balanced way forward.

Moreover, high tobacco taxes drive illicit trade in tobacco products. According to European Union Anti Fraud Office (OLAF), cigarette smuggling and other illicit trade forms in tobacco products cause an estimated EUR 10 billion loss to the EU and national budgets every year. In the legal supply chain, manufacturers, suppliers, distributors, retailers and consumers are all affected by illicit trade. The black market of tobacco targets vulnerable groups in society, undermining strategies for the effort of harm reduction products.

To prevent these risks, the European Union should limit taxation, and do not increase taxation, on tobacco products. Tax increases incentivise consumers to purchase illegal products and make black market alternatives more attractive. Excessive regulation and taxation of tobacco products reduce access to and availability of them without driving down the demand.

The effectiveness of e-cigarettes as a smoking cessation tool is undeniable, keeping in mind that it targets smokers as opposed to non-smokers. Vaping is a life-saving tool, and it has been proven to be 95% less harmful than smoking. International health bodies, Public Health England, New Zealand Ministry of Health and Health Canada have also endorsed vaping for encouraging smokers to switch.

The new tobacco excise strategy should take these facts into consideration and develop a separate regulatory framework for vaping. The United States provides a valuable lesson of the damage that can be caused by excise taxes on e-cigarettes. US researchers found that “a proposed national e-cigarette tax of $1.65 per millilitre of vaping liquid would raise the proportion of adults who smoke cigarettes daily by approximately 1 percentage point, translating to 2.5 million extra adult daily smokers compared to the counterfactual of not having the tax.” We shouldn’t forget that our goal is to beat cancer in the EU, and in order to do that, we needn’t be blind to foreign experience and evidence at hand.

Most importantly, in order to reduce cancer rates, it is vital to ensure that vaping is not only accessible price-wise, but also that smokers are aware of the possibility to switch to a safer alternative that can reduce various health-associated risks. The EU has to encourage the marketing and branding of safe and legal vaping products. Consumer information is necessary in order to help beat cancer in the EU through vaping.

Given the aforementioned arguments, we strongly recommend abstaining from further increases in tobacco excise taxes in order not to incentivise the black market. We also call on the Commission to follow science and be mindful of the fact that vaping – as an effective smoking cessation tool – should be treated differently than conventional smoking. Tighter restrictions and higher taxes will not help us beat cancer in the EU, but putting together a science-based and consumer-friendly framework in regard to smoking and vaping will.

Kind regards,

Maria Chaplia
European Affairs Associate
Consumer Choice Center

Originally published here.

[UK] Advertising Ban

Introducing a total online advertising restriction for products high in fat, sugar and salt (HFSS)

Last month, the UK government launched a consultation on the proposed ban of of all online advertising of foods high in fat, sugar and/or salt (HFSS) which would include everything from promotional emails to Google adverts. 

HFSS products would be classed in scope of the sugar and calorie reduction programmes. Some of the products covered will be ready meals, pizzas, meat products, savoury snack products, sauces and dressings, prepared sandwiches. The plan comes as an extension of the ‘better health’ strategy launched in July.

The scope of advertising restrictions is not limited to but includes commercial newsletters, in-app advertising, mid-roll video ads, and advertisements which are pushed electronically to devices.

Obesity is a pressing issue in the UK. Taking the path of more lifestyle interventionism in the form of taxes and ad bans seems straightforward and is usually pursued out of noble motives. However, such an approach all too often lacks economic and ethical judgement. 

The link between advertising and childhood obesity is too weak to justify ad bans mainly because of several factors at play. When we consider the effects of advertising, we need to also take into account genetics, energy expenditure, parental style, and availability of the advertised product.

We at the Consumer Choice Center do not support the presented proposals. In our view, in order to tackle obesity, the UK should focus on education and innovation instead of opting for interventionist policies that undermine consumer choice.

[EU] Survey on the Pharmaceutical Strategy – Timely patient access to affordable medicines​

Introduction

The EU strives to be a frontrunner in ensuring universal health coverage. In addition, it is a global leader in healthcare research and development and a major trading partner in pharmaceuticals and medical technologies. People across the EU expect to benefit from equal access to safe, state-of-the-art and affordable new and established therapies. Medicines play an important role in this regard, as they offer therapeutic options for diagnosis, treatment and prevention of diseases.
The unprecedented coronavirus pandemic (COVID-19) clearly demonstrates the need to modernise the way the EU ensures that its citizens get the medicines they need. Although this has been thrown into sharp relief by the coronavirus pandemic, it is not a new problem: even prior to the pandemic we witnessed shortages of essential medicines, such as cancer treatments, vaccines and antimicrobials. This calls for a thorough examination of how the supply chain – from the importing of active ingredients, raw materials, and medicines from third countries to internal EU production and distribution – can be made more secure and reliable.

Securing the supply of medicines is not only about existing therapies. There is also a need to ensure that the European pharmaceutical industry remains an innovator and world leader. Innovative technologies such as artificial intelligence as well as data collected from clinical experience (“real world data”) have the potential to transform therapeutic approaches and the way medicines are developed, produced, authorised and placed on the market and used. Innovation needs to be focused on areas of most need.

At the same time, more must be done to ensure that innovative and promising therapies reach all patients who need them: at present, this is not the case, with patients in smaller markets being particularly affected. Health systems, which are also seeking to ensure their financial and fiscal sustainability, need new therapies that are clinically better than existing alternatives as well as cost effective.

Finally, we are more aware than ever of the need to reduce the environmental footprint of medicines. All these challenges will be addressed in the forthcoming EU Pharmaceutical Strategy, which should cover the whole life-cycle of pharmaceutical products from scientific discovery to authorisation and patient access.

More information on the context of the initiative, on the challenges identified so far and on the objectives can be found in the roadmap (https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12421-Pharmaceutical-Strategy-Timely-patient-access-to-affordable-medicines). Whether you are a concerned citizen or a professional in the area of medicines we would like you to let us know if you share our 2 objectives, what actions we should focus on and whether there are any additional aspects that we should cover.

After some introductory questions about yourself, the questionnaire continues with questions on the Pharmaceutical strategy. When replying, please keep in mind that the questions in this survey were developed to address the long-standing issues identified in the EU pharmaceuticals system. These may be related to the problems arising from the coronavirus pandemic but are broader than that. The end of the survey includes dedicated questions on coronavirus related issues.

Please note that in this questionnaire, we do not intend to obtain data relating to identifiable persons. Therefore, in case you will describe a particular experience or situation, please do it in a way that will not allow linking to a particular individual, whether it is you or somebody else. We thank you in advance for your time and input.


Response

[EU] Action plan for the development of EU organic production​

Introduction

The aim of this public consultation is to collect the opinion of stakeholders and the public on challenges and opportunities to increase the production and consumption of organic food. Your answers will feed into a European Commission communication to be published early in 2021. This communication will lay the ground for concrete action in line with the European Commission’s objectives of ensuring that at least 25% of the EU’s agricultural land is under organic farming by 2030 and that there is a significant increase in organic aquaculture. These objectives ultimately aim to both improve the sustainability of the food system and revert biodiversity loss.


Responses

Section 1: General – the state of organic production today

Organic production today covers some 8% of total utilized agricultural area and organic aquaculture accounts around 5% of total aquaculture production in the EU. Although this is a significant increase compared to the past, there is still significant room to increase these shares. The aim of this section is to identify the main bottlenecks to the production and consumption of organic food.

  1. To what extent are the following factors obstacles to greater production and consumption of organic food in the EU today?

at least 15 answered row(s)

 Strongly agreeSomewhat agreeSomewhat disagreeStrongly disagreeDon’t know
Retail price of organic products too highX    
Price of organic products at suppliers too high    X
Not profitable enough for producers X   
Too expensive for consumersX    
Insufficient consumer demandX    
Lack of consumer confidence in organic production methodsX    
Lack of consumer awareness of the EU label  X  
Lack of consumer confidence in the EU label   X 
Insufficient financial incentives for producers to convert to organic production    X
Low interest from retailers in giving organic products shelf-space  X  
Low consumer awareness of the benefits of organic production for climate and the environment   X 
Competition with other ways of producing and/or other schemes    X
Competition with private label products  X  
There are too many ecological food schemes that can be confused with organic   X 

Other (please specify):

For further explanations, we refer to our position paper.

  1. The COVID-19 crisis has had many significant impacts on different sectors, including on the food system and the production and consumption of organic food. To what extent do you agree with the following statements? 

at least 4 answered row(s)

 Strongly agreeSomewhat agreeSomewhat disagreeStrongly disagreeDon’t know
The crisis has strengthened organic farming and its role in EU food supply    X
The crisis has accelerated structural changes in our food consumption in favour of organic farming   X 
The crisis has shown our reliance on seasonal labour in farming X   
In the post-crisis period, the greater demand for organic products reported by the sector will be maintained    X

Section 2: Organic for all – stimulating demand and consumer confidence

Consumption of organic products per capita varies greatly among EU Member States. This section aims to identify concrete measures to stimulate the consumption of organic products and to ensure that consumers feel confident that the organic products they buy are produced according to such standards. 

  1. To what extent do you agree with the following statements?

at least 9 answered row(s)

 Strongly agreeSomewhat agreeSomewhat disagreeStrongly disagreeDon’t know
The EU organic logo is not sufficiently recognised  X  
Information campaigns for the EU organic logo are needed   X 
More awareness is needed on the environmental and climate benefits of organic farming   X 
Campaigns to promote agricultural products should specifically target organic products   X 
Price competitiveness of organic products should be improved    X
Schemes in schools to promote healthy diets should focus on organic products   X 
Food served in public/private offices and canteens should focus on organic products   X 
The range of organic products at retailers should be broader and more visible    X
Authorities should use much more public procurement to boost organic consumption   X 

Other (please specify): We would like to specify that our answer on the price competitiveness as “Don’t know” is due to the fact that the question did not elaborate on whether that refers to an intrusion on price competitiveness by producers and retailers or whether this should be done on an institutional governmental level.

For further explanations, we refer to our position paper.

  1. Demand for organic products also depends on consumer confidence that the products are produced in line with organic standards. To what extent do you agree that the following actions are important?

at least 7 answered row(s)

 Strongly agreeSomewhat agreeSomewhat disagreeStrongly disagreeDon’t know
Reasons for lack of consumer confidence should be explored X   
Consumers should be able to clearly distinguish between the EU organic logo and other environmental/quality schemesX    
It should be easier to trace organic products back to their origin X   
The information on organic producers should be transparent and available for consumersX    
Information technologies such as blockchain (data shared across a network of computers) should be used more often to improve tracing of organic productsX    
Compliance with the rules for organic production must be better controlled by public authoritiesX    
More effort is needed to tackle fraud in the organic sectorX    

Other (please specify):

For further explanations, we refer to our position paper.

Section 3: Promoting organic production

The share of land under organic farming varies considerably across EU Member States, ranging from some 2% in Romania to 24% in Austria. One reason for these differences could be the lack of structures in the supply chain to allow producers to benefit from the added value created by organic production. This section will help identify the main measures to: (i) stimulate conversion to organic agriculture and aquaculture and (ii) strengthen the value-chain for operators who have opted for organic production.  

  1. To what extent are the following measures important to stimulate the production of organic products?

at least 10 answered row(s)

 Strongly agreeSomewhat agreeSomewhat disagreeStrongly disagreeDon’t know
The EU’s Common Agricultural Policy and the support it provides should target organic production   X 
Other financial support for organic production is also needed (e.g. national, local or other public and private initiatives)   X 
Provide sufficient training and advice on organic farming (including visits and pilot farms) to stimulate conversion especially in regions lagging behind the EU average   X 
More research is needed to develop plants with greater resistance to pests and to extreme and variable climate conditionsX    
Investments (including in research and innovation) are needed to scale up labour-saving technologies    X
Improve information and data on developments in the organic market to facilitate decisions for producers    X
Improve information and data on developments in the organic market to support decision making for retailers    X
Help organic producers to better organise (e.g. producer organisations) to improve their bargaining power    X
Investments (including in research and innovation) for organic food processing   X 
Strengthen local and small-scale processing and foster short supply chains    X
  1. Organic animal husbandry must comply with higher standards than conventional animal husbandry. There are also higher standards for organic aquaculture. To what extent do you agree with the following statements? 

at least 4 answered row(s)

 Strongly agreeSomewhat agreeSomewhat disagreeStrongly disagreeDon’t know
Organic animal production should benefit from specific support   X 
Producers should be helped to find appropriate organic feed for animal nutrition   X 
More research is needed to identify and develop best practices on feeding methods suitable for organic feed, and alternative feeding ingredients X   
Aquaculture should be supported to gain more knowledge on breeding and feeding methods, including through research  X  

Section 4: Societal benefits – the contribution to climate and environment

One of the aims of organic farming is to combine agricultural production with respect for the environment and climate. It aims to preserve biodiversity, soil fertility, and aquatic ecosystems while allowing producers to make a decent living. This section will provide us with concrete ideas on how organic farming can be a model for: (i) more sustainable practices in farming and aquaculture, (ii) greater use of renewable resources, and (iii) greater animal welfare, while maintaining European food production.

  1. What are the main environmental advantages of organic production?

at least 8 answered row(s)

 Strongly agreeSomewhat agreeSomewhat disagreeStrongly disagreeDon’t know
Organic farming is beneficial to biodiversity   X 
It responsibly uses energy and natural resources, such as water   X 
It reduces leakage of nitrates into water and thus protects water quality   X 
It protects soil quality   X 
It helps reduce air pollution   X 
It promotes a circular economy by using bio-based materials   X 
It promotes carbon neutrality by reducing emissions of greenhouse gases and storing carbon in soil   X 
It allows for adaptation to a changing climate   X 
  1. To further increase the benefits of organic farming for the environment and climate, to what extent do you agree with the following measures?

at least 6 answered row(s)

 Strongly agreeSomewhat agreeSomewhat disagreeStrongly disagreeDon’t know
Funding to increase the availability of species suitable for organic production, notably through research   X 
More investment on organic agricultural research and innovation   X 
Networks of organic farms to act as demonstration projects and promote best practices    X
Phase out of contentious inputs (e.g. copper) still used in organic farmingX    
Promote the replacement of plastics in packaging with fully recyclable or biodegradable materials   X 
Promote the sustainable use of water in organic farming    X

Section 5: Conclusions – the role of the EU and the road ahead

The EU has actively promoted organic production as a pillar of its Common Agricultural Policy while also supporting the increase of organic aquaculture. However, local producers, national authorities and producer organisations also play an important role. This section will help us understand whether the EU should intensify its actions in favour of organic production and consumption, or whether these actions should be devolved to the national/local level. The final question provides you with an opportunity to present your own proposals for how the production and consumption of organic food can be strengthened, in addition to those proposals identified earlier in the questionnaire.

  1. To what extent do you agree with the following statements?

at least 3 answered row(s)

 Strongly agreeSomewhat agreeSomewhat disagreeStrongly disagreeDon’t know
The main responsibility for promoting organic production and consumption lies at national level    X
The development of organic production should be left to the market with no specific supportX    
The development of the organic sector requires a mix of EU and Member State support as well as private initiatives   X 
  1. Are there any more specific or additional actions that you would suggest?

For further explanations, we refer to our position paper:

DOWNLOAD HERE

[EU] SCHEER Consultation: setting the facts straight

Last month, an EU Committee called the SCHEER launched a “preliminary opinion on e-cigarettes” that is ram-packed full of biased arguments against vaping, is missing crucial facts about vaping and avoids any form of comparison with cigarettes.

As is obliged of them, the SCHEER has sought feedback on their preliminary opinion from the scientific community and stakeholders. As the voice of 19 associations worldwide, representing tens of thousands of vapers, we believe that our voice is important in the debate – in particular, because the consultation is structured to make it challenging for individuals to submit their experiences or testimony 

Therefore, we – as an organisation representing consumers – believe that it is our responsibility and duty towards all the vapers who count on us to protect their rights, to make sure that we set the record straight. Our consultation response was officially submitted on 21 October, and you can read it here.

We wanted to make sure that the facts are out there, in front of the SCHEER Committee. 

  • Fact: “E-cigarettes are 95% less harmful than smoking.”
  • Fact: “Vaping is a gateway OUT of smoking, not the other way around.”
  • Fact: “Vaping is twice as effective as other smoking cessation methods.”

We will be closely following the developments around this opinion and hope to see the committee take into consideration much of the science on vaping that was seemingly ignored in their first draft. 

Meanwhile, we are here to support and amplify the voice of the millions of vapers worldwide who have had their lives changed for the better.

[Denmark] 2020/228/DK – Bill amending the Act on the ban on tobacco advertising / Act on tobacco products / Act on electronic cigarettes /

Introduction

Title
Bill amending the Act on the ban on tobacco advertising etc., Act on tobacco products etc., Act on electronic cigarettes etc. and various other acts (Implementation of the national action plan against smoking by children and young people)

Products Concerned
S00S – HEALTH, MEDICAL EQUIPMENT

Notification Under Another Act
– Directive 2014/40/EU of the European Parliament and of the Council of 3 April 2014 on the approximation of the laws, regulations and administrative provisions of the Member States concerning the manufacture, presentation and sale of tobacco and related products and repealing Directive 2001/37/EC – Article 24(2) and (3)

Main Content
– Display ban:
tobacco products, tobacco substitutes and electronic cigarettes are not to be visible to consumers at points of sale, including on the Internet, until a customer specifically requests them. This does not however apply to:
physical shops that specialise in the sale of cigars, pipes and pipe tobacco respectively, and the sale of electronic cigarettes:
– Stricter ban on advertising and sponsorship:
all forms of direct and indirect advertising and sponsorship are banned and, as an additional element, tobacco substitutes and herbal products for smoking are also covered by the ban.
– Standardised packaging:
all tobacco products, herbal products for smoking and electronic cigarettes must have a uniform appearance. This does not however apply to cigars, pipe tobacco and pipes. The standardisation means, among other things, that the manufacturer and product name must appear in a standardised way, that logos must not stand out and that the colour etc. of the packaging must be standardised. Standardisation can limit the advertising effect of the packaging.
– Smoke-free school time:
to avoid school pupils being confronted with smoking etc. during school hours, it is proposed that school time should be smoke-free in all primary schools, boarding schools, continuation schools and upper secondary education facilities.
– Smoke-free properties:
upper secondary education facilities including children and young people under 18 years of age and not covered by the current requirements for smoke-free properties are proposed to be included.
– Ban on the sale of tobacco, tobacco substitutes, herbal products for smoking and electronic cigarettes and refill containers with and without nicotine in primary schools, boarding schools, continuation schools and upper secondary education facilities.
– Ban on flavourings in tobacco products and electronic cigarettes:
the sale of electronic cigarettes etc. with characteristic flavours other than the taste of tobacco and menthol is banned. The same is proposed for those tobacco products that are not already covered by the ban on characteristic flavours, although not for pipe tobacco and cigars or herbal products for smoking.
– Regulation of tobacco substitutes (nicotine products):
not previously regulated in Danish law, but proposed to be covered by the same regulation as tobacco products with respect to, for example, advertising regulations, age limits, etc. Requirements are also proposed on health warnings on the packaging in line with the current regulations for electronic cigarettes.
– Age control system and stricter penalty levels:
requirements are laid down for all retailers marketing over the Internet to ensure a system that effectively verifies the age of the purchaser, and the penalty of breaching the age limit is proposed to be made stricter.
– Registration scheme for retailers of electronic cigarettes and refill containers with and without nicotine, registration scheme for tobacco substitutes and refill containers without nicotine.
– Stricter penalties for breaches of the Act on smoke-free environments.
– Easier access for municipalities to provide free smoking cessation medication.


Response:

[EU] Consultation on a new digital finance strategy for Europe / FinTech action plan – 2020

Introduction

Digitalisation is transforming the European financial system and the provision of financial services to Europe’s businesses and citizens. In the past years, the EU and the Commission embraced digitalisation and innovation in the financial sector through a combination of horizontal policies mainly implemented under the umbrella of the Digital Single Market Strategy, the Cyber Strategy and the Data economy and sectoral initiatives such as the revised Payment Services Directive, the recent political agreement on the crowdfunding regulation and the FinTech Action Plan. The initiatives set out in the FinTech Action Plan aimed in particular at supporting the scaling up of innovative services and businesses across the EU, for example through enhanced supervisory convergence to promote the uptake of new technologies by the financial industry (e.g. cloud computing) but also to enhance the security and resilience of the financial sector. All actions in the Plan have been completed.

The financial ecosystem is continuously evolving, with technologies moving from experimentation to pilot testing and deployment stage (e.g. blockchain; artificial intelligence; Internet of Things) and new market players entering the financial sector either directly or through partnering with the incumbent financial institutions. In this fast-moving environment, the Commission should ensure that European consumers and the financial industry can reap the potential of the digital transformation while mitigating the new risks digital finance may bring. The expert group on Regulatory Obstacles to Financial Innovation, established under the 2018 FinTech Action Plan, highlight these challenges in its report published in December 2019.

The Commission’s immediate political focus is on the task of fighting the coronavirus health emergency, including its economic and social consequences. On the economic side, the European financial sector has to cope with this unprecedented crisis, providing liquidity to businesses, workers and consumers impacted by a sudden drop of activity and revenues. Banks must be able to reschedule credits rapidly, through rapid and effective processes carried out fully remotely. Other financial services providers will have to play their role in the same way in the coming weeks.

Digital finance can contribute in a number of ways to tackle the COVID-19 outbreak and its consequences for citizens, businesses, and the economy at large. Indeed, digitalisation of the financial sector can be expected to accelerate as a consequence of the pandemic. The coronavirus emergency has underscored the importance of innovations in digital financial products services, including for those who are not digital native, as during the lockdown everybody is obliged to rely on remote services. At the same time, as people have access to their bank accounts and other financial services remotely, and as financial sector employees work remotely, the digital operational resilience of the financial sector has becoming even more important.

As set out in the Commission Work Programme, given the broad and fundamental nature of the challenges ahead for the financial sector, the Commission will propose in Q3 2020 a new Digital Finance Strategy/FinTech Action Plan that sets out a number of areas that public policy should focus on in the coming five years. It will also include policy measures organised under these priorities. The Commission may also add other measures in light of market developments and in coordination with other horizontal Commission initiatives already announced to further support the digital transformation of the European economy, including new policies and strategies on data, artificial intelligence, platforms and cybersecurity.


Response

[EU] Public consultation for the EU climate ambition for 2030 and for the design of certain climate and energy policies of the European Green Deal

Introduction

Global warming is happening and affecting citizens while threatening our long-term sustainability on this planet. The average temperature of our planet has already increased by 1°C and the world is currently not on track to achieve the Paris Agreement objective of limiting temperature change below 2°C, let alone 1.5° C. The 2018 special report of the Intergovernmental Panel on Climate Change on 1.5°C indicated that already at 2°C the world would see dramatic and potentially irreversible impacts due to climate change. Science is also clear on the close link and interdependence of climate change and biodiversity loss.

The EU has taken global leadership in tackling climate change and actively pursues policies to cut its greenhouse gas emissions and to decouple these from economic growth. This allows the EU to modernise its economy and energy system, making them sustainable in the long term and to improve energy security and the health of its citizens by reduced air pollution.

The EU has already adopted climate and energy legislation to reduce greenhouse gas emissions by at least 40% by 2030 compared to 1990 levels. Furthermore, it adopted ambitious energy efficiency and renewable energy legislation, whose full implementation is estimated to reduce greenhouse gas emissions beyond the existing target – by around 45% by 2030. As part of this legislation, Member States develop National Energy and Climate Plans to ensure that common EU objectives will be met. Unless complemented by further policies, the agreed legislation is expected to lead to around 60% greenhouse gas emissions reductions by 2050. In 2018, the Commission proposed for the EU to become climate compensating any remaining GHG emissions by absorptions. The European Parliament neutral by 2050 and the European Council endorsed this objective in 2019. The Commission has proposed to enshrine this objective in the European Climate Law.

According to the latest Eurobarometer survey, 93% of EU citizens see climate change as a serious problem and a significant majority of the EU population wants to see increased action on climate change. As a reflection of this and due to the urgency of the climate and linked ecological challenges, the European Commission has proposed in December 2019 a as one of its priorities including a list European Green Deal of forthcoming proposals to deliver it. The Green Deal aims, among others, to align all EU policies with the 2050 climate neutrality objective, sending an early and predictable signal to all sectors and actors to plan
2 for the transformation.

As part of the Green Deal, the Commission intends to propose to increase the EU’s 2030 target for greenhouse gas emission reductions to at least -50% and towards -55% compared to 1990 levels, in a responsible way. The Commission will thoroughly assess the feasibility and the social, economic and environmental impacts of increasing the 2030 target. This assessment will look into how to increase ambition in a way that enhances EU competitiveness, ensures social fairness and access to secure, affordable and sustainable energy and other material resources, benefits citizens and reverses biodiversity loss and environmental degradation. The Commission intends to present a comprehensive plan to increase the EU 2030 climate target in the third quarter of 2020.

Building on the existing 2030 legislation and the upcoming comprehensive plan, the Commission will review and propose to revise, where necessary, the key relevant energy and climate legislation by June 2021. This will include a coherent set of changes to the existing 2030 climate, energy and transport framework, notably related to the EU Emissions Trading System Directive, the Effort Sharing Regulation and the Land Use, Land Use Change and Forestry Regulation, CO Emissions Performance Standards for Cars and Vans 2 and, as appropriate, the Renewable Energy Directive and the Energy Efficiency Directive.

This public consultation invites citizens and organisations to contribute to the assessment of how to increase the EU 2030 emission reduction ambition in a responsible way. Please note that relevant questions and topics may also be covered under other public consultations such as for instance the Strategy on Sustainable and Smart Mobility, the EU Adaptation Strategy, the “Farm to Fork” Strategy, the Action Plan to implement the European Pillar of Social Rights, the Targeted Consultation for the Evaluation of the Guidelines on State aid for Environmental protection and Energy 2014-2020.


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