EU Consultations

[EU] Public Consultation on the Taxation of Tobacco Products and New Products

As a global consumer group representing millions of consumers in Europe and globally, we have been working on spreading the harm reduction message to help spread awareness about vaping as a life-saving tool both among smokers and non-smokers. In light of the EU Beating Cancer plan, Dutch vape flavour ban, and proposed German tax on nicotine e-liquids, it appears that the European Union and Member states have decided to turn a blind eye to smokers and push them into abstinence through coercion. Such an approach is disastrous and should be reconsidered.

We urge the EU Commission to follow science and keep the interests of smokers and former smokers in mind as well as the economic costs of excessive taxation of both vaping and tobacco products.

Vaping is a lifesaving tool

Vaping has been proven to be 95% less harmful than smoking and has been endorsed by multiple international health bodies as a safer alternative. While some critics have argued that vaping is a gateway to smoking, the opposite is true. Vaping is a gateway from smoking, and has been used by millions of adults to reduce the health risks associated with tobacco consumption. 

Higher taxes on vaping products are particularly harmful to the lower income brackets of the population

The highest proportion of current smokers are from low income population segments. “[Higher taxes on] 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” in the United States. With tax increases in the EU, similar consequences would be seen in Europe.

Overregulation of tobacco products boosts illicit trade

Smoking should be seen as a matter of consumer choice and personal responsibility. Tobacco products should not see any further scrutiny. The evidence regarding the effectiveness of taxes, marketing and other restrictions is too weak to justify such drastic interventions. Furthermore, such policies encourage illicit trade. Tobacco price disparity between the EU and other countries in Europe is a contributing factor; however, that also demonstrates that despite anti-tobacco efforts, demand for cigarettes doesn’t go away. 

Adult consumers should be encouraged to make responsible choices bearing in mind the consequences of their actions. Policies based on respect for consumer choice such as education should be preferred over restrictions.

Response:

[EU] First phase consultation of social partners under Article 154 TFEU on possible action addressing the challenges related to working conditions in platform work

This position is in response to the 1st-phase consultation on platform work regulation by the European Commission. The Consumer Choice Center is a consumer organisation, thus not amongst the categories called upon to react to this consultation. That said, with this response we express the urgent call that the consumer point of view is very important in the regulation of platform work, and that we deserve our place in upcoming considerations of the European Commission. Given the status of organisation as a consumer group, we cannot speak in detail on the specific labour regulations. That said, regulation on one area has vertical ramifications on other sectors, meaning that the regulation of platform work has the side-effect of altering, in a positive or negative way, the availability of products and services to consumers.We therefore ask you to consider our point of view in the upcoming consultation process.

  1. Do you consider that the European Commission has correctly and sufficiently identified the issues and the possible areas for EU action?

    The European Commission has provided an extensive overview on the issue, and has contextualised the challenges associated with the issue. The quotes from the document underline this fact. “At the macro-level, not addressing the issues faced by people working through plat-forms in the EU may have repercussions for European labour markets and societies aggravating labour market segmentation and inequalities and potentially leading to a diminished fiscal base for EU governments and thus reducing the effectiveness of social security systems.”

    and

    “Overly restrictive regulation could have a stifling effect on innovation and job creation potential, especially for smaller-scale European scale-ups and start-ups and self-employed persons, depending on its scope.”

    This displays a differentiated view on the issue of platform work and the implications of incoming regulation. However, we believe that the Commission has underestimated the consumer perspective in its analysis. All actors, including platform workers themselves, are benefactors of the sharing economy — through its potential for reducing cost and efficiency, as well as thorough environmental benefits.

    Ride-sharing platforms have given the opportunity to reduce costs for all consumers in major cities, allowing market entry to a new set of consumers, i.e. those consumers who were previously unable to afford a ride in the traditional taxi market.

    This does not only apply to short rides with platforms such as Uber, Bolt, or Heetch, but also to long-distance travel through carpooling sites such as BlaBlaCar. These services have enabled a more social experience, all while being more environmentally-friendly due to the optimisation of resources.

    Other sharing economy services have provided more flexibility and work-life balance to all consumers and those who use the services, for instance through co-working spaces. Adding to that, businesses have found new opportunities, such as through the connection of smart delivery services. The European Commission should account for the added value of platform work for consumers.
  2. Do you consider that EU action is needed to effectively address the identified is-sues and achieve the objectives presented?

    EU action can help facilitate coordination between member states, particularly when a service crosses borders. For instance, an Uber crossing from one country to another. That said, we do not believe that there is a legitimate need for EU action on this topic, due to the diverse nature of sharing economy services. Member states face different challenges in the area of housing, mobility, and other consumer products and services, and therefore a blanket legislative approach would not be appropriate. Each member state should make the necessary regulatory decisions.

    This does not only apply to the question of consumer policy, but also in the realm of labour regulations. Knowing that there are different social security requirements in all member states, a regulatory alignment in one sector could excessively complicate the interior rules system of each country. Adding to that, this approach does not allow for regional specificities. For instance, the mobility sector might be burdened with a restrictive licensing system, which can only be alleviated with the introduction of a ride-sharing platform. Making it more difficult for the latter to be introduced would hurt consumers.

    If we are to follow the principles of the single market, the European Commission should uphold the legality of ride-sharing services throughout the bloc.

[UK] A consultation on the Tobacco and Related Products Regulations 2016 and the Standardised Packaging of Tobacco Products Regulations 2015

Health text and picture warnings

Question 1: How far do you agree or disagree that the introduction of rotating combined (photo and text) health warnings on cigarette and hand rolling tobacco has encouraged smokers to quit?

  • strongly agree
  • agree
  • neither agree or disagree
  • disagree
  • strongly disagree
  • don’t know

Disagree. Despite a persistent belief that nannying consumers out of smoking, health warning labels haven’t proved to be effective in helping smokers quit. For example, in 2012, the US Court of Appeal stated the following: “The Food and Drug Administration has not provided a shred of evidence—much less the “substantial evidence”— showing that the graphic warnings will “directly advance” its interest in reducing the number of Americans who smoke.” Сonsumers are already knowledgeable about the harms and risks associated with smoking, which is why there isn’t much evidence to suggest that the warnings actually deter tobacco use.

It is especially difficult to establish a clear causal relationship between the introduction of health warning labels and its impact on the reduction of smoking rates. Furthermore, the potential causality is complicated by the distinction between heavy and non-heavy smokers, and how they respond to health warning labels. The very same applies to all sorts of marketing and branding bans.

A 2019 experiment published in Health Education Research found that the presence of graphic health warning labels did not influence participants’ purchase of cigarettes as a main effect. The said study also found that smokers who were highly dependent on nicotine dependence were slightly more likely to purchase cigarettes when graphic health warning labels were present. It might also be likely that health warning labels have the opposite effect and entice defensive reaction and, in the end, fail to achieve the expected goal of reducing the smoking rates.

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.

Tobacco products should not see any further scrutiny. The evidence regarding the effectiveness of health warning labels is, therefore, inconclusive. Adult consumers should be encouraged to make responsible choices bearing in mind the consequences of their actions. Long-shot policies based on respect for consumer choice such as education should be preferred over health warning labels. 

Question 2: How far do you agree or disagree that the introduction of rotating combined (photo and text) health warnings on cigarette and hand rolling tobacco has deterred young people from smoking?

Disagree.

First, taking into account the arguments mentioned above, health warnings on cigarettes haven’t proved to be successful in deterring smokers, especially heavy smokers, from smoking. Young people should be educated about smoking and freedom to choose so that they become responsible adult consumers later in life. 

For instance, a 2019 study conducted in Australia found that both smoking and non-smoking university students perceived current cigarette packaging warnings in Australia as having lost much of their effectiveness as tobacco control interventions. Non-smokers perceived health warnings on cigarettes as preventive and needed to raise awareness about smoking. Smokers, on the contrary, were pessimistic about such interventions.

Question 3: Should all tobacco products have a combined (photo and text) health warning on their packaging?

Characterising flavours

Question 4: How far do you agree or disagree that the prohibition of characterising flavours has helped smokers quit smoking?

Question 5: How far do you agree or disagree that the prohibition of characterising flavours has deterred young people from taking up smoking?

E-cigarettes

Question 6: How far do you agree or disagree that the current regulations on e-cigarettes have been proportionate in protecting young people from taking up use of these products?

A report commissioned by PHE in early 2020 affirmed that nearly two-thirds of 11-to-17-year-olds in the United Kingdom who currently vape more than once a month had bought products themselves. Numbers like this often lead to prohibitionist calls for further bans and restrictions on vaping products. However, it is crucial to strike a balance between the need to ensure that teens should not be able to purchase vaping products while encouraging adult smokers to quit.

Another report commissioned by the PHE showed that 38% of smokers believed that vaping is as harmful as smoking while 15% believed that vaping is more harmful. This misconception of risk is a huge concern, because it discourages many current smokers to switch to the less harmful alternative – vaping. It is crucial that smokers are educated about the possibility to switch and reduce health risks associated with conventional smoking. Marketing of vaping products needs to be encouraged so that consumers have access to the necessary information about vaping as means to quit.

Further bans of vaping products will drive more consumers to illegal products on the unregulated black market, where there is no guarantee of safety or quality. A larger black market will make it even easier for minors to purchase vaping products with no age verifications at all. 

However, the use of vaping products among adolescents isn’t widespread. Out of 11-18 year olds never smokers only 0.1% vape more than once a week. 

Question 7: How far do you agree or disagree that the current regulations have ensured that e-cigarettes are available for those smokers who wish to switch to these products?

Agree. The UK’s pro-vaping approach should be applauded: it saves lives, and other countries should follow the UK’s example. In particular, that concerns other European countries since as long as the UK continues to remain open to innovation aimed at reducing rates, there is a chance that they might choose to drift away from paternalism that doesn’t stand up to scrutiny. Despite calls to restrict access to vaping, in particular those that seek to frame vaping as a gateway to smoking, the UK should preserve its role as a global harm reduction advocate.

An analysis of 61 countries showed that 196 million smokers could switch to vaping if other countries treated vaping in the same way as the UK.

However, the UK should further improve its current regulatory framework to achieve its smoke-free 2030 goal (see question 8).

Question 8: What effect do you think the regulations have had on smokers considering switching to e-cigarettes?

Unfortunately, as was mentioned previously, 38% of smokers in the UK believe that vaping is as harmful as smoking while 15% believed that vaping is more harmful. Many regulations have made it more difficult for current smokers to obtain correct information about vaping. The EU Tobacco Products Directive has prevented switching efforts, and after Brexit, the UK has a unique chance to walk away from the EU’s restrictive approach. Excessive bans on advertising of vaping should be lifted in order to ensure smokers – especially heavy smokers – are able to gain all the necessary information about vaping. Significant communication efforts should be channeled to help raise awareness about vaping as a safe means to quit smoking.

Question 9: Do you consider the restrictions on e-cigarette advertising to be an effective way to discourage young people and non-smokers from using e-cigarettes?

Agree, we should not tolerate teen vaping, and any rise in numbers is concerning. Still, we cannot at the same time deprive millions of adult smokers of safer alternatives (according to Public Health England, vaping is at least 95% less harmful than traditional smoking) because of activities that are already illegal. All studies and surveys show that regular use among minors is rare, so the effort should be placed on helping adult smokers quit or for those who do not want to or are not able to quit to switch to vaping or similar alternatives. It is, therefore, crucial to distinguish between communication regarding age restrictions and access to e-cigarettes for minors as such and that aimed at adult smokers.

Novel tobacco products

Question 10: How far do you agree or disagree that the requirements of TRPR on novel tobacco products are proportionate?

Strongly agree, it is crucial that the ucomining legislation update distinguishes between TRPR and conventional tobacco. Vaping was initially invented as a safer alternative aimed at reducing health-associated risks and should be seen as such. We need an on-ramp for harm reduction that is vaping: endorse e-cigarettes as an effective tool to help smokers move to a safer alternative to consume nicotine and eventually quit if they desire to do so.

Enforcement

Question 11: Do you agree or disagree that the penalties for a breach of the regulations are an effective deterrent to ensure compliance with the regulations?

Agree. In the United Kingdom, a video game seller can be fined up to 20,000 GBP for selling age-restricted games to underaged customers. At the same time, a vendor selling vaping liquids to minors comes with a maximum fine of merely 2,500 GBP, an eighth compared to video games. Given that one study found that 5 out of 9 shops sell vaping products to minors, the UK’s fines might need to be adjusted upwards.

The UK should abstain from stricter regulation that target adults, and consequently discourage them from switching. Better and smarter enforcement of existing restrictions on sales should be the focus.

Other question

Question 12: How far do you agree or disagree that there has been an economic impact of TRPR, either positive, negative or both?

Anything else on TRPR?

Question 13: Is there anything else you would like to share on negative or positive impacts the regulations have had on topics not covered above? If so, please explain and include any evidence and research you may have to back your response.

As a global consumer group representing millions of consumers in Europe and globally, we have been working on spreading the harm reduction message to help spread awareness about vaping as a life-saving tool both among smokers and non-smokers. We applaud the UK’s progressive approach to vaping and believe it can do even better after Brexit. In particular, that concerns advertising restrictions and stricter enforcement of the rules concerned with teen vaping. 

We are hopeful that the UK doesn’t give in to scientifically unjustified calls against vaping, and remains an advocate of harm reduction. Added to that, it is also crucial to ensure that the upcoming legislation doesn’t unintentionally target adult smokers in pursuit of reducing vaping rates among teens. Although the UK is the example for Europe and the world, there is room for improvement.

SPoT requirements

Question 14: How far do you agree or disagree that the requirements on the packaging and labelling of tobacco products have been an effective way to protect young people from taking up smoking?

Neither agree or disagree. The only way to protect young people from taking up smoking is through education and enforcement of age restrictions. Moreover, plain packaging as a policy hasn’t proved to be effective in the long.

Question 15: How far do you agree or disagree that the requirements on the packaging and labelling of tobacco products have helped existing smokers quit?

Regardless of noble motives in place, the failures of plain packaging are numerous and evident. In 2012, Australia passed a nation-wide plain packaging decree. The goal was to reduce smoking rates. During the first years of the ban, more young people started to smoke. The smoking rates among Australians in the age range of 12-24-year-olds increased from 12 per cent in 2012 to 16 per cent in 2013. Little or no improvement was made among people aged 30 or older between 2013 and 2016. People aged 40–49 continued to be the age group most likely to smoke daily (16.9%) and the smoking rates among this age group went up from 16.2% in 2013. At the same time, Australia has seen an enormous increase in roll-your-own cigarettes: 26% in 2007, to 33% in 2013 and to 36% in 2016. 

Plain packaging, like taxation, is intended to push consumers away from particular products considered by governments to be harmful, unhealthy and detrimental to the wellbeing of society. What policymakers tend to overlook, though, is that demand for cigarettes is inelastic and thus neither taxes nor branding bans can substantially affect consumer behaviour. 

Question 16: SPoT regulations apply to cigarettes and hand rolling tobacco. How far do you agree or disagree that SPoT regulations should be restricted to cigarettes and hand rolling tobacco (and not other tobacco products)?

Pack size

Question 17: How far do you agree or disagree that the introduction of a minimum pack size or weight is an effective way to protect young people from taking up smoking?

The UK government should abstain from introduction of further interventions not only because those are costly and paternalistic, but also because they haven’t proved to be successful in achieving the set goal. Instead, the government should focus on endorsing vaping as a means to quit smoking

Appearance of cigarettes

Question 18: How far do you agree or disagree that the requirements on the appearance of cigarettes are proportionate?

Enforcement

Question 19: Do you agree or disagree that the penalties for a breach of the regulations are an effective deterrent to ensure compliance with the regulations?

  • agree
  • disagree
  • don’t know

Other question

Question 20: How far do you agree or disagree that there has been an economic impact of SPoT, either positive, negative or both?

Anything else on SPoT?

Question 21: Is there anything else you would like to share on negative or positive impacts the regulations have had on topics not covered above? If so, please explain and include any evidence and research you may have to back your response.

CONSULTATION IS AVAILABLE HERE

[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/

[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:

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