Consultations

Official CCC Reponses and Consultations.

[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.


Response:

[EU] Tax fraud and evasion – better cooperation between national tax authorities on exchanging information

About this initiative

Summary

New business models such as the digital economy create challenges for national tax authorities in terms of tackling tax fraud and evasion.
This initiative aims to strengthen the framework so tax authorities can better exchange information on taxpayers working in the digital economy. This will help ensure they report what they earn and pay adequate tax.
It will also create a more efficient tax environment so compliant businesses can benefit from the single market and sustain economic growth.

Topic: Taxation
Type of act: Proposal for a directive
Digital platforms

The phenomenon of digital platforms facilitating peer-to-peer sale of goods or services between users – including the “collaborative economy” or so-called “sharing” and “gig” economy – is growing rapidly.

Many different services can be accessed through digital platforms. Some examples include:

  • accommodation services ( such as renting an apartment when going on holidays);
  • transportation services (such as car sharing);
  • food-related services (such as home delivery);
  • household services (such as gardening or babysitting);
  • professional services (such as accounting or legal services);
  • collaborative finance services (such as crowd-funding).

While the emergence of these digital platforms can have strong positive effects on the economy, they also raise a number of issues, including making sure that participants selling goods or services via those platforms (platform sellers) are aware of and fully comply with their tax obligations.

Given the nature of these platforms – highly mobile, operating internationally and often with no real physical presence – it can be challenging for tax administrations to gain timely access or even detect relevant information on transactions carried out or income obtained through digital platforms. These developments present risks of distorting competition with traditional businesses and leading to taxable income not being reported, and having the potential of becoming a vehicle for the shadow economy.

There are concerns that some income obtained by platform sellers is not declared to the relevant tax authorities. A number of EU countries (e.g. Italy, France, Denmark or Estonia) have already introduced unilateral reporting measures requiring platforms to communicate to the tax authorities revenues received by platform sellers, while others are planning to introduce similar measures in the near future. However, it is also recognised that unilateral measures are inefficient, as enforcement of the rules proves difficult – if not impossible – in a flexible and remotely operated business model. Additionally, each (unilateral) approach may include different registration and compliance requirements. This may lead to different regulatory models between EU countries and Single Market fragmentation, with an inherent administrative burden for both platforms and users.

[EU] Evaluation of marketing standards [Regulation (EU) No 1308/2013]

Evaluation of EU marketing standards (contained in the Common Market Organisation (CMO) regulation, the “breakfast directives” and CMO secondary legislation)

17. Are you familiar with any EU marketing standards in any of the following product sectors? (CCC Responses are in Green)

×Olive oil and table olives×Poultry meat Coffee and chicory extracts
 Fruit and vegetables Spreadable fats Cocoa and chocolate products
 Processed fruit and vegetable products Hops Fruit jams, jellies and marmalades
 Bananas×Beef and veal Fruit juices
 Live plants Wine Honey
 Eggs Milk and milk products None of the above

18. In your opinion, to what extent have the EU marketing standards, in the product sectors you are familiar with, contributed to supplying the market with products of a standardised and satisfactory quality ?

 Very strong positive contribution Moderate negative contribution
 Strong positive contribution Strong negative contribution
 Moderate positive contribution Very strong negative contribution
×Had no effect No opinion

19. In your opinion, to what extent have the EU marketing standards, in the product sectors you are familiar with, contributed to improving the conditions for production and marketing and creating a level-playing field in these sectors ?

 Very strong positive contribution Moderate negative contribution
 Strong positive contribution Strong negative contribution
×Moderate positive contribution Very strong negative contribution
 Had no effect No opinion

20. In your opinion, to what extent have the EU marketing standards, in the product sectors you are familiar with, contributed to providing adequate and transparent information to consumers ?

 Very strong positive contribution Moderate negative contribution
 Strong positive contribution Strong negative contribution
 Moderate positive contribution Very strong negative contribution
×Had no effect No opinion

21. In your opinion, to what extent have the EU marketing standards, in the product sectors you are familiar with, contributed to providing the purchaser with value for money ?

 Very good value for money
 Good value for money
×Limited value for money
 No value for money
 No opinion

22. In your opinion, to what extent could efficiency be improved by harmonising the control and reporting requirements of the different marketing standards ?

 Very strong potential for improvement
 Strong potential for improvement
 Moderate potential for improvement
×No potential for improvement
 No opinion

23. In your opinion, what could be simplified, and how, in order to improve the management and implementation of the EU marketing standards ?

Authorities should gather specific data on consumer consultation of marketing information, in order to identify consumer priorities. It is not sensible to increase compliance costs (resulting in higher consumer prices) for information that consumers are not interested in to begin with. The CCC also believes that new technologies already offer non-regulatory information carriers (through mobile applications and barcodes) that need to be considered as a substitute mechanism.

24. In your opinion, to what extent are the EU marketing standards, in the product sectors you are familiar with, consistent to other EU policy interventions in these sectors?

 Very strongly consistentStrongly consistentModerately consistentNot consistentNo opinion
EU rules on food safety   X 
Food information to consumers   X 
Geographical indications X   
Organic products   X 

Please specify:

On organic products: EU organic product labelling does not address the potential health implications of pesticide use in organic farming.

25. In your opinion, to what extent are the EU marketing standards, in the product sectors you are familiar with, consistent with international marketing standards and with private marketing standards?

 Very strongly consistentStrongly consistentModerately consistentNot consistentNo opinion
International marketing standards – Codex Alimentarius (CODEX)    X
International marketing standards – United Nations Economic Commission for Europe (UNECE)    X
Private marketing standards    X

26. In your opinion, has the implementation of the EU marketing standards caused any unexpected or unintended effects in terms of food waste ?

 Yes
 No
×No opinion

27. In your opinion, has the implementation of the EU marketing standards caused any unexpected or unintended effects in terms of animal welfare ?

 Yes
 No
×No opinion

28. In your opinion, has the implementation of the EU marketing standards caused any potential of abuse by market actors ?

×Yes
 No
 No opinion

29. In your opinion, to what extent do the EU marketing standards, in the product sectors you are familiar with, fit with the needs of the supply chain in these sectors (i.e. producers, processors, traders, retailers) ?

 Fit very well
 Fit well
 Fit moderately well
 Did not fit
×No opinion

30. In your opinion, to what extent do the EU marketing standards, in the product sectors you are familiar with, fit with the needs of consumers ?

 Fit very well
 Fit well
 Fit moderately well
×Did not fit
 No opinion

31. In your opinion, to what extent do the EU marketing standards, in the product sectors you are familiar with, fit with the needs of Member States administrations ?

 Fit very well
 Fit well
 Fit moderately well
 Did not fit
×No opinion

32. In your opinion, what are the most essential benefits of the EU marketing standards that cannot be achieved by the Member States/sectors acting on their own ?

N/A

33. Do you have any suggestions on how EU marketing standards could further improve product quality and production/marketing conditions in these sectors ?

N/A

34. In your opinion, has the implementation of the EU marketing standards caused any unexpected or unintended effects in regard to the sustainability of the food chain ?

 Yes
 No
×No opinion

35. Please feel free to upload a concise document, such as a position paper. The maximum file size is 1MB.

Please note that the uploaded document will be published alongside your response to the questionnaire which is the essential input to this public consultation. The document is optional and serves as additional background reading to better understand your position. 

The Consumer Choice Center (CCC) is an advocacy group standing up for the rights of consumers who want to make their own choices on a free and fair market. While product information and oversight is key, regulators need not overburden the regulatory framework with too many well-intended rules. It so happens that compliance costs in the field of fast-moving consumer goods are paid by consumers, acting as a tax on the consumption of ordinary people. Therefore the Consumer Choice Center encourages opposes “better regulation” to “more regulation”, in a spirit of streamlining the process of compliance. While market access regulations should be harmonised and permissive, product information should be adapted to local needs. A product being “made in Italy” is not helpful for an Italian consumer seeking Southern Italian products – particularly since producer addresses do not necessarily reflect the lieu of production. In this example, Italy should have the possibility to establish more than just country of origin, but even region of origin. In a comparable application of the same principle, countries wishing to keep up with agro-tech innovations (that have been proven to be safe for consumption by national authorities), should never need to require labelling of products that do not need labelling for public health concerns, since it would needlessly stigmatise certain products and mislead consumers. The CCC therefore opposes strict horizontal regulation of marketing standards across all sectors, and draws attention to the fact that paragraph 70 – which stipulates that consumers being misled “as a result of their expectations and perceptions” – opens the door with arbitrary interpretations of what those expectations and perceptions are. Labelling requirements — as for instance suggested for harmonisation in paragraph 104 for wine — do not respect regional priorities on the matter, and should be left to national authorities.Furthermore, we also believe that Regulation (EU) No 1308/2013 creates market interventions that can lead to price distortions, for example through state aid on private storage (paragraphs 10, 17, 18, 21), quantitative limitations and price fixing (paragraphs 5, 11, 14), or purchase terms (in the case of sugar) (paragraph 118).The CCC supports the Commission’s effort to support educational facilities with fruits and vegetables, with the aim of diversifying diets and making them more healthy (paragraphs 24, 25, 26, 27). Adding to that, we would like to add that physical exercise programmes have proven to be more efficient than radical dietary changes, so efforts need to be coordinated with other educational programmes, in order to achieve the desired goalsThe Consumer Choice Center declares its interest as a stakeholder to take part in further consultations and is happy to contribute to studies undertaken. We agree to the publication of these statements.

[UK] POST IMPLEMENTATION REVIEW OF TOBACCO LEGISLATION

The Tobacco Advertising and Promotion (Display) (England) Regulations 2010

These regulations apply to the display of tobacco products in small and large shops (display ban) and came into force on 6 April 2012 in larger shops and 6 April 2015 for all other outlets. The regulations prohibit the display of tobacco products in small and large shops, allowing trading to continue but preventing them from being used as promotional tools. All retailers are required to cover up cigarettes and hide all tobacco products from public view.

The full Tobacco Advertising and Promotion (Display) (England) Regulations 2010 are published on Legislation.gov.uk

1. Do you think the display ban of tobacco in small and large shops has helped to reduce the number of children and young people smoking?

Answer: I don’t know if it has or not.

Current scientific evidence points to the fact that smoking susceptibility amongst young people has dropped following the introduction of the display ban on tobacco in small and large shops. 

A decrease in smoking susceptibility does not necessarily equate to a decline in smoking rates, since this decrease also correlates with a number of other factors, on both the regulatory and the educational side, as well as innovations such as harm-reducing products. A negative side-effect of a display ban can be that smoking is perceived as an ominous and secretive act, which encourages certain youth to pick it up. In a comparable fashion, illicit narcotic substances are also purchased in large numbers by youths, without any advertising or display. We know through evidence in countries that have legalised or decriminalised these substances (particularly in the case of cannabis) that youth consumption rates normalise as the handling of the substance reaches social acceptance.

It would be ill-advised for the government to recreate the bad side-effects of prohibition in the case of tobacco. 

2. Do you think the tobacco display ban has encouraged and supported adult smokers to quit?

Answer: I don’t know if it has or not.

Scientific evidence presented by the World Health Organization (WHO) points to the example of New Zealand, where a display ban coincided with a decrease in smoking prevalence from 9% to 7%.

Correlation does not mean causation. The measure also has overlap with both the regulatory and educational measures, as well as innovations such as harm-reducing products. Further scientific research in the United Kingdom would be necessary to determine whether a decline in adult smoking cessation can be related to display bans.

3. What impact do you think the display ban has had on:

(a) general population

(b) retailers

(c) manufacturers

(d) other stakeholders

For consumers, the implementation of a display ban reduces the amount of information available for tobacco. Cigarettes are a legal product in the United Kingdom, yet consumers are now unable to identify differences between brands and are unexposed to new upcoming products. Added to that, a display ban creates uncertainty on the legal market, as the practice of selling cigarettes “under the counter” is equally present in the case of retailers engaging in the sales of illicit cigarettes.

Some of our members have reported to us to have received counterfeit products when purchasing cigarettes in UK corner stores. The display ban might make it easier for vendors of counterfeit cigarettes to hide their illicit products from consumers and law enforcement until the moment of sale.

4. Is the display ban an effective way to protect children and young people from taking up smoking and supporting those who wish to quit?

Answer: No, I don’t think it is.

Given the insufficient amount of evidence on the question of effectiveness and the clear risks that the Consumer Choice Center has listed in an answer on the impact of the display ban, we do not believe that the measures constitute an effective way to protect children and young people from taking up smoking and supporting those who wish to quit.

We believe that harm-reducing products such as e-cigarettes represent an innovative way towards smoking cessation. 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.

5. Were there any economic losses or gains (for individuals, businesses and wider society) associated with implementing the display ban on tobacco products?

Answer: Yes, I think there were some economic losses or gains.

With a loss in brand awareness and the creation of consumer uncertainty on the legal market, the Consumer Choice Center believes that a loss in consumer choice has been created by the display ban. We also think that this has fuelled the shadow economy and allowed vendors with bad intentions to sell more illegal cigarettes to consumers.


The Tobacco and Advertising (Specialist Tobacconists) (England) Regulations 2010

These regulations apply to the display of tobacco products in Specialist Tobacconists and came into force on 6th April 2015.

These regulations provide exemptions for specialist tobacconists to the general prohibition of the display of tobacco products. They allow tobacco products to be displayed within specialist tobacconists as long as they are not visible from outside the shops. Additionally, the legislation permits tobacco advertising provided it is in, or fixed to the outside of premises of a specialist tobacconist and complies with prescribed conditions.

The full Tobacco and Advertising (Specialist Tobacconists) (England) Regulations 2010 are published on Legilsation.gov.uk.

1. Do you think the display ban of tobacco in specialist tobacconists has helped to reduce the number of children and young people smoking?

Answer: I don’t know if it has or has not.

Current scientific evidence has analysed the situation in regular commercial establishments. The purpose of a specialist tobacconist shop is to sell tobacco, with other items for sale being proportionally secondary. Evidence would need to be gathered in order to make concrete statements on the effect of the display ban in this instance.

2. Do you think the display ban in specialist tobacconists has encouraged and supported adult smokers to quit?

Answer: I don’t know if it has or has not.

Current scientific evidence has analysed the situation in regular commercial establishments. The purpose of a specialist tobacconist shop is to sell tobacco, with other items for sale being proportionally secondary. Evidence would need to be gathered in order to make concrete statements on the effect of the display ban in this instance.

3. Has the display ban within specialist tobacconists had any further impacts not covered in the questions above?

Answer: I don’t know if it has or has not.

Provided the exemptions in the current law surrounding display bans, the case of specialist tobacconists is different from regular retailers and needs to be examined separately.

4. Is the display ban in specialist tobacconists an effective way to protect children and young people from taking up smoking and supporting those who wish to quit?

Answer: I don’t know whether it is or it is not effective.

Provided the exemptions in the current law surrounding display bans, the case of specialist tobacconists is different from regular retailers and needs to be examined separately.

We believe that harm-reducing products such as e-cigarettes represent an innovative way towards smoking cessation. 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.

5. Were there any economic losses or gains (for individuals, businesses and wider society) associated with carrying out this regulation in the community?

Answer: I don’t know if there were or not economic losses or gains.

Given the insufficient amount of evidence on the question of effectiveness, and the clear risks that the Consumer Choice Center has listed in an answer on the impact of the display ban, we do not believe that the measures constitute an effective way to protect children and young people from taking up smoking and supporting those who wish to quit.

We believe that harm-reducing products such as e-cigarettes represent an innovative way towards smoking cessation. 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.


The Tobacco and Advertising (Display of Prices) (England) Regulations 2010

These regulations impose requirements on the display of prices of tobacco products in small and large shops and came into force on 6th April 2015.

The regulations permit only three types of tobacco price displays within retailers:

  1. Poster style lists (up to A3 in size) which can be permanently on show but must not exceed 1,250sq centimetres in size
  2. A list including pictures of products, which must not be left on permanent show, but can be shown to any customer aged 18 or over who asks for information on tobacco products sold; and
  3. Price labels, which can be placed on shelving, storage units or tobacco jars. One price label is permitted for each product either on the covered shelf where the product is stored or on the front of the storage unit.

The full Tobacco and Advertising (Display of Prices) (England) Regulations 2010 are published on Legislation.gov.uk

1. Have the restrictions on the display of prices of tobacco products helped reduce the number of children and young people smoking?

Answer: I don’t know if they have or have not.

Current scientific evidence on this matter is scarce. Existing evidence suggests that price display bans can reduce smoking prevalence. However, the same research also suggests that price policies need to be accompanied by certain minimum price rules. Therefore, the immediate effectiveness of price display bans in themselves are questionable and cannot be proven with existing evidence.

2. Have the restrictions on the display of prices of tobacco products helped encourage and support adult smokers to quit?

Answer: I don’t know if they have or have not.

Current scientific evidence on this matter is scarce. Existing evidence suggests that price display bans can reduce smoking prevalence. However, the same research also suggests that price policies need to be accompanied by certain minimum price rules. Therefore, the immediate effectiveness of price display bans in themselves are questionable and cannot be proven with existing evidence.

3. What impact do you think the restriction of display of prices of tobacco products has had on the following:

(a) general population

(b) retailers

(c) manufacturers

(d) other stakeholders (please specify)

Please give reason(s) and evidence for your answers.

Restricting price indications at retail deprives consumers of information about tobacco, a product which can be purchased legally with some restrictions in the United Kingdom. Consumers are vulnerable to be misled by retailers about the product they are buying, and are not afforded the necessary transparency to make an informed purchase.

4. Is restricting the display of prices of tobacco products an effective way to protect children and young people from taking up smoking and support those who wish to quit?

Answer: I don’t know if it is or is not effective.

Current scientific evidence on this matter is scarce. Existing evidence suggests that price display bans can reduce smoking prevalence. However, the same research also suggests that price policies need to be accompanied by certain minimum price rules. Therefore, the immediate effectiveness of price display bans in themselves are questionable and cannot be proven with existing evidence.

We believe that harm-reducing products such as e-cigarettes represent an innovative way towards smoking cessation. 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.

5. Were there any economic losses or gains (for individuals, businesses and wider society) associated with carrying out this regulation in the community?

Answer: I don’t know if there were economic losses or gains.

Restricting price indications at retail deprives consumers of information about tobacco, a product which can be purchased legally with some restrictions in the United Kingdom. Consumers are vulnerable to be misled by retailers about the product they are buying, and are not afforded the necessary transparency to make an informed purchase.


The Smoke-free (Private Vehicles) Regulations 2015

The regulations came into force as of 1st October 2015 and apply in England. Regulation 5; penalties and discounted amount also applies in Wales.  These regulations make it an offence for:

  • A person to smoke in a private vehicle when someone under the age of 18 is present
  •  A driver not to stop a person smoking when someone under the age of 18 is present.

The regulations are thought to have minimal impact in business. Police Authorities are the designated enforcement offices, with the power to issue Fixed Penalty Notices (FPN) to anyone found to be non-compliant with the law.

The full Smoke-free (Private Vehicles) Regulations 2015 are published on Legislation.gov.uk.

1. Have the Smoke-free (Private Vehicles) Regulations helped prevent people from smoking in vehicles with children?

Answer: No, I don’t think they have.

There is no sufficient amount of evidence in England that would allow for a thorough conclusion on this matter. Existing evidence from Portugal showed that despite widespread support for the regulation, “high smoking prevalence and poor enforcement contribute to low compliance”.

2. What impact do you think Smoke free (Private Vehicles) Regulations have had on: general public, retailers, manufacturers, other stakeholders (please specify)

The Consumer Choice Center believes that though the intent of the legislation is commendable, the costs involved with enforcing the measure thoroughly far exceed the benefits. Law enforcement work on lifestyle matters should be focused on preventing sales of tobacco to young people, and combating illicit trade.

3. Do you believe prohibiting smoking in private vehicles is an effective way to protect children and young people from harms of tobacco and second-hand smoke?

Answer: I don’t know if it is or if is not.

There is no sufficient amount of evidence in England that would allow for a thorough conclusion on this matter. The question is not whether smoking in private vehicles is unhealthy to children and young people from a health perspective, but whether legislation is the correct approach to solving this issue. A prohibition on this matter can also lead to complicated law enforcement situations. A family car that smells of tobacco because the parent smoked in the vehicle prior to picking up children could offset a fine, even though the driver did not break the law.

We believe that education through the schooling system is the correct way to pursue public health objectives.

4. Were there any economic losses or gains (for individuals, businesses and wider society) associated with carrying out this regulation in the community?

Answer: I don’t know if there were economic losses or gains.

There is no sufficient amount of evidence in England that would allow for a thorough conclusion on this matter. Existing evidence from Portugal showed that despite widespread support for the regulation, “high smoking prevalence and poor enforcement contribute to low compliance”.

Increased law enforcement in this area would increase costs for taxpayers.

[EU] OPC: Ex post evaluation of the impact of the trade chapters of the EU’s Association Agreements with six EuroMed countries

Objective of the consultation:

The aim of this public consultation is to collect information, views and opinions on the effectiveness, efficiency, coherence and relevance of the EU-Mediterranean Association Agreements’ trade chapters with Algeria, Egypt, Jordan, Lebanon, Morocco and Tunisia. The results of the consultation serve as input for the evaluation of the impacts of these Agreements, a project jointly conducted by Ecorys, CASE and FEMISE on behalf of the European Commission. For more background information on the project please consult the following website. The consultation will be open for 12 weeks.

1. Were you aware of an FTA between the EU and the Southern Mediterranean region prior to hearing about this evaluation?

Yes

2. To what extent do you believe that the FTAs have met the following objectives related to the bilateral relations between the EU and the Southern Mediterranean region?

 Strongly DisagreeDisagreeNeutralAgreeStrongly AgreeNo opinion / do not know
The FTAs have promoted trade relations     X 
The FTAs have promoted fair competition    X 
The FTAs have expanded harmonious economic relations    X 
The FTAs have expanded harmonious social relations    X 
The FTAs have established the conditions necessary for the gradual liberalisation of trade in goods, services and capital    X 

3. Please provide an explanation of how the FTAs have led to this impact:

Trade is not zero-sum, it is an exchange from which consumers on both sides benefit hence why FTAs are so important. An increase in the supply of particular goods and/or services from abroad under FTAs boosts competition and thus leads to lower prices. On the other hand, trade protectionism gives an unfair advantage to domestic producers at the expense of consumers. FTAs should aim to create a fair and equitable environment in which domestic and foreign producers are encouraged to compete based on the value they have to offer to consumers. Additionally, FTAs tend to mitigate anti-foreign bias by building cooperation bridges between various nations. FTAs are about interstate cooperation, increased choice, and cheaper products.

4. To what extent do you believe the FTAs have met the following objectives related to regional cooperation?

 Strongly DisagreeDisagreeNeutralAgreeStrongly AgreeNo opinion / do not know
The FTAs have increased trade and cooperation within the Southern Mediterranean region  X   
The FTAs have increased trade and cooperation between the region and the EU and it Member States   X  

5. Please provide an explanation of how the FTAs have led to this impact:

Despite the number of regional trade agreements, intra-regional trade in the Southern Mediterranean region is still poorly developed. The EU, as the largest trade partner of the region, has played an important role in encouraging the creation of the Southern Mediterranean free trade area. However, it is crucial that the region itself first makes a choice in favour of building stronger regional ties and then acts upon it keeping in mind all its economic, political and cultural particularities.

6. To what extent are the FTAs between the EU and Southern Mediterranean region coherent with the following policies? (Click on the name of the policy for more information.)

 IncoherentPartially CoherentFully CoherentNo opinion / do not know
European Neighbourhood Policy  X 
Association Agreements  X 
Action Plans  X 
Partnership Priorities  X 
Current EU Trade policy  X 

70. What are the most positive aspects of the FTAs between the EU and the Southern Mediterranean region?

The fact that the number of EU imports from the Southern Mediterranean region has been continuously growing since 2016 is definitely one of the key successes. Additionally, the FTAs have clearly fostered cooperation and international understanding between regions.
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