Consumer Choice Center

No more future booze bans, please!

Research shows that the lockdowns spurred growth in the black market in alcohol.

What happens when something people really want is banned? Do they stop wanting it? Or do they find other ways to access it? Our experience with the lockdown alcohol ban answers this question and must give policymakers pause when considering their future plans.

According to the Transnational Alliance to Combat Illicit Trade (Tracit), liquor bans have spurred the growth of the black market in alcohol. Research from the Institute for Security Studies supports this conclusion, as does statements from the South African Revenue Service.

And it simply stands to reason: People are not robots and do not suddenly stop craving and desiring certain products just because some politicians said it must be so. Readers of this article likely know very well from personal experience that, on the ground, the booze did not stop flowing. For the formal, lawful alcohol industry, however, South Africa’s alcohol bans have been disastrous.

The justification for the bans was quite intuitive: Expecting a rise in Covid-19 patients to arrive at South African hospitals, government wanted to reduce the number of patients suffering from an alcohol-related condition taking upward space. The healthcare sector needed time, so went the reasoning, to expand its capacity.

The first alcohol ban was imposed between March 27, and June 1, 2020, the second from July 12 to August 17, and the most recent was from 28 December 2020 to 1 February 2021, when it was mostly lifted.

On Monday, 24 August 2020, health minister Zweli Mkhize announced that they “have no started to dismantle some of the field hospitals [because additional] beds are no longer necessary”. This was mere days after the lockdown was downgraded from level 3 to level 2. Cooperative governance minister Nkosazana Dlamini-Zuma cautioned South Africans against the very real possibility of a second wave in the near future as restrictions on their liberties were being taken away.

In December, when he was announcing the renewed alcohol ban, President Cyril Ramaphosa noted how hospitals were being overwhelmed with alcohol-related trauma cases.

Government did expand hospital capacity then dismantled it, knowing well that a second wave was likely on the horizon. It is the stuff of spiteful, arbitrary governance, then, to punish a massive sector of the economy, not to mention the South African public, for government’s own short-sighted planning.

While the lockdown alcohol ban might at the time of writing have been lifted, Dlamini-Zuma has made it clear that banning liquor again was not out of the question. The alcohol industry is therefore now caught in a position of impossible uncertainty.

Minister Dlamini-Zuma says the ban’s intention is not to cause harm to the industry, but such an assurance is cold comfort in light of the facts.

The alcohol industry by 2019 had supported the livelihoods of a million South Africans and contributed more than 3% of GDP, not to mention the more than R15 billion in tax revenue it brought in for government. Indeed, the money the alcohol industry lost due to the lockdown booze ban would have gone a long way to financing South Africa’s vaccine drive.

Tracit found that there was a 900% increase in pineapple sales after the alcohol ban came into effect. The obvious reason for this is that many people started homebrewing pineapple beer, and presumably selling it on the black market.

Even supermarkets, seizing the opportunity, “started selling the fruit as a package with sugar and yeast”. During the ban, the police also reported the smuggling of alcohol contraband from neighbouring states, and losses to the lawful industry in the illicit trade, according to Tracit, were expected to rise to about R13 billion per year.

While the illicit trade is entirely understandable, given the ill-considered policy decisions made by the government, consumers should nonetheless beware of the health risks of purchasing homebrewed booze. Whereas the lawful alcohol industry is subject to strict quality standards, someone selling beer they had just made in their garage is not. Dozens of reported deaths have already resulted from such dangerous consumption.

Some who do not partake in the consumption of alcohol (myself being among them), have admitted the damage this ban has done economically, but do not sympathise with the alcohol industry, who they credit with the exploitation of South Africa’s poor population.

This perspective, unfortunately, misses the point that the “alcohol industry” is not all directly concerned with alcohol. Glass bottling firms, retailers, transportation companies, restaurants, and a multitude of other enterprises are part of this industry and many, in indirect ways, are dependent upon it. Must the staff, and their families, of bottling companies and restaurants also suffer, simply to show up the beverage makers?

Consumer freedom of choice is guaranteed by the Constitution, and means other people – the poor included – may decide to do things that the chattering classes disagree with. This includes consuming alcohol. The marketplace is all about suppliers meeting demand and creating value for their consumers, and this is exactly what those in the alcohol trade are doing. It is not only economically devastating for government, supported by a small elite of intellectuals who disapprove of alcohol consumption, to interfere in this freedom, but it is also profoundly condescending and immoral.

Tracit rightly recommends that bans and prohibition should not be regarded as a legitimate means of responding to Covid-19, for such a response lacks discernible benefits and the consequences are dire for the alcohol industry, the economy, the government, and the entire South African society. It is far safer for South Africans, whose demand for alcohol is not going anywhere, to be able to access it in the lawful market, where it is subject to quality standards and where the point of sale is subject to social distancing and hygienic regulations.

No economy can function efficiently in the presence of the kind of policy uncertainty presently reigning in South Africa. Government must reassure the alcohol industry that further bans are off the table. Otherwise, we should expect further disinvestment by the industry and the further growth of the illicit trade, even now while the ban has been suspended.

While certain common-sense measures to combat Covid-19 can be retained, it is high time for South Africa to return to a healthy respect for freedom of choice.

Martin van Staden is South African Policy Fellow with the Consumer Choice Centre.

Originally published here.

[UK] Advertising Ban

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

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

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

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

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

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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.

Public Health Agencies Care More About Controlling You Than Prepping For Pandemics

May 13, 2020
By jstier
In Healthcare, Public Health, Recent Media
0 comments

What were public health officials at every level of government doing last year? Were they preparing for a pandemic? Or were they using their office to meddle with your lifestyle choices?

The partisan political sniping over Covid-19 is completely predictable and counter-productive. There’s plenty of fault to go around, but the blame-gaming should be ignored or discounted for what it is: self-aggrandizing grandstanding.

It is, however, worthwhile to examine a tension that has been brewing in the public health world for decades. That dichotomy is: should we focus on communicable diseases, as has long been the mission of public health institutions, or do we have enough bandwidth and resources to venture out into the much more controversial area of non-communicable diseases (NCDs)?

To get to the answer, think about this. What were public health officials at every level of government doing last year? Five years ago? Were they first ensuring that their track and trace systems were in place for a pandemic? Or were they using their office to meddle with your lifestyle choices?

The discipline of public health has long been rooted in fighting contagious diseases. For the most part, it has done very well. Notwithstanding the current Covid-19 pandemic, sanitation, vaccines and therapies—mainly drugs—have dramatically reduced the toll of communicable diseases.

That success has led many in public health agencies, especially in the United States, to argue that we must now use our limited resources to combat NCDs, and that we can address both effectively. It isn’t exactly working out that way.

Efforts to fight non-contagious diseases such as heart disease and diabetes frequently raise questions about individual liberty, including the freedom to make poor choices. All too often, the politicized debate causes both sides to overstate or manipulate the science supporting their viewpoints.

When former New York City Mayor Michael Bloomberg, the biggest booster of today’s public health movement, campaigned against sugary drinks like soda, it landed the city’s health department in hot water. For instance, a taxpayer-funded ad campaign created by the Department of Health showed a photo of a man purportedly with amputated legs. The city’s ad agency had Photoshopped his legs out of the photo to support the valid claim that Type 2 diabetes can lead to amputations.

The Bloomberg administration’s antics, which even elicited criticism from within the health department, indicates the degree to which his wing of the public health movement has lost sight of its most primary and unifying functions: preparedness.

This lack of preparedness is not partisan. It exists in the current Republican administration, as it did in the prior Democrat administration. Cities, counties, and states long governed by each party were equally ill-prepared for a pandemic.

Commentators on the left and the right have referred to Coronavirus and Covid-19 as a “black swan event.” But it doesn’t meet the definition. A pandemic of this type was not only predictable, it was something communicable disease experts have warned about rather specifically for many years. The warning signs were ignored, and we were ill-prepared.

A 2007 review article in the American Society for Microbiology’s publication, Clinical Microbiology Reviews, entitled, “Severe Acute Respiratory Syndrome Coronavirus as an Agent of Emerging and Reemerging Infection,” concluded: “Coronaviruses are well known to undergo genetic recombination, which may lead to new genotypes and outbreaks. The presence of a large reservoir of SARS-CoV-like viruses in horseshoe bats, together with the culture of eating exotic mammals in southern China, is a time bomb. The possibility of the reemergence of SARS and other novel viruses from animals or laboratories and therefore the need for preparedness should not be ignored.”

Rather than marshal finite resources towards preparedness for a coming communicable disease, lots of public health resources, including taxpayer dollars, media attention, and legislative priorities, were deployed to address non-communicable diseases, from domestic violence to gun regulation.

Think back to a different time not so long ago. During the second half of 2019, federal, state and city health officials throughout the country were busy confronting a new and scary lung disease. The health reporters covering them churned out news articles, regularly garnering front-page placement. Major charities such as Bloomberg Philanthropies were making large public health grants. So it should come as no surprise that the American public and political leaders were keenly focused on this emerging health threat.

The disease wasn’t Covid-19, of course. It was a something the Centers for Disease Control called e-cigarette or vaping product use-associated lung injury, or EVALI.

At the time, public health activists were, for years, calling for bans on the types of e-cigarettes used to quit smoking. Despite strong evidence that nicotine e-cigarettes are 95 percent less harmful than smoking and can help smokers quit, public health agencies treated e-cigarettes as the most important threat to public health. Yet they still failed to convince policymakers to institute widespread bans on the most popular e-cigarettes.

But as consciousness of EVALI reached a crescendo, states began to ban most flavored e-cigarettes, and the FDA further tightened the regulatory screws on nicotine-containing e-cigarettes.

It turned out that none of these nicotine e-cigarettes were ever responsible for the lung disease that bears their name. It took until late December for the Centers for Disease Control to (partly) acknowledge that the lung injuries were caused not by vaping liquid nicotine e-cigarettes such as Juul, but by the use of THC oil contaminated with vitamin E acetate.

Public health agencies were so ideologically opposed to e-cigarettes as a tool for tobacco harm reduction that they sowed panic, promulgated misinformation, and actually caused a failure to identify the true culprit in a life-saving and timely way. Still, nobody has been held accountable.

So, back to the question about communicable and non-communicable disease: Has public health been able to “do both” well? It turns out, that when purportedly trying to do both, public health hasn’t been able to do either effectively.

I’m not suggesting that public health’s EVALI scandal was the only or even primary culprit for the failure of public health departments around the country to ensure that their communities had an adequate supply of personal protective equipment in the event of a predictable communicable disease outbreak, or that the CDC was otherwise preoccupied. Instead, the EVALI episode was more of a symptom of something wrong in public health.

The institution of public health has largely been co-opted by those with a desire to control individual choices to such a degree that it has largely lost sight of its fundamental role of pandemic preparedness. At this point, taxpayers should realize that we are giving the keys to the public health car to people who have long been driving in the wrong direction.

Originally published here.

The CCC represents consumers in over 100 countries across the globe. We closely monitor regulatory trends in Ottawa, Washington, Brussels, Geneva and other hotspots of regulation and inform and activate consumers to fight for #ConsumerChoice. Learn more at consumerchoicecenter.org

Hidden Dangers of Nannying Revealed by Pandemic

One of the fundamental questions raised by the pandemic is whether individuals can be entrusted to follow social distancing rules voluntarily or whether government force is necessary to accomplish that end. Most governments have channelled the latter assumption in the fight against COVID-19. After years of ratcheting our lifestyle of freedoms, that doesn’t come as a surprise.

From cannabis to tobacco and sugar consumption, lifestyle regulations infantilise consumers by “nudging” them toward what some government officials believe is best for them. The psychology behind such an approach is straightforward: if we continuously tell somebody they are incapable of choosing for themselves, they eventually come to believe it. Nannying consumers from A to Z and then all of a sudden expecting them to skip a Thursday pub night for the sake of social distancing is inconsistent, to say the least.

There are of course some good intentions behind various lifestyle regulations. Tobacco plain packaging and taxes, for instance, are meant to deter consumers because of both look and price. The plain packaging of sweets, crisps and sugary drinks is intended to drive down our consumption of sugar. Thus, branding bans are seen as a major tool by some in public health. But these measures beg two questions. First, do they have any propensity for success? Second, in light of the pandemic, can we afford to diminish the culture of individual responsibility through paternalism?

We know plain packaging doesn’t work. In 2012, Australia passed a nationwide plain packaging decree on all tobacco products. The goal was to reduce smoking rates. During the first years of the ban, more young people took up smoking. 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, whereas it had been declining naturally in the years prior. 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.

Consumers should have access to all the information they can get about products and then, crucially, have the freedom to decide for themselves. Branding bans block their access to information about the products they buy and consume. Information is dispersed through branding, and therefore branding bans remove that possibility.

We need individual responsibility more than ever. Our fast-developing and incredibly interconnected world is likely to face more pandemics, and we should be prepared as individuals. The line between collective responsibility — to socially distance for example — and individual responsibility is a thin one. The consequences of the former might affect other people, while the latter concerns only us as individuals.

When we choose to consume sugar, we are the ones responsible for the repercussions and we should be encouraged to bear that responsibility. Going out and shaking hands knowing that we have symptoms of COVID-19 puts at risk other people while staying at home limits our personal freedom. It is only through individual responsibility that we can learn to be socially responsible.

Paternalism destroys our ability to choose for ourselves and be burdened with the consequences. In the case of a pandemic, our failure to exercise our responsibility and sensibility leads to a collective failure and provides a ground for government force, lockdowns and all sorts of questionable interventions.

Ideally, aware of their responsibility and risks, each and every person could have voluntarily chosen to self-isolate, as many people did. But how can we expect individuals to follow public health decrees if we know some of them are ineffective?

First, governments paternalise us through branding bans and other nudges, and then they want us to act responsibly when the pandemic kicks in. This has to change, and we should encourage individual freedom followed by responsibility instead of infantilising consumers.

Originally published here.

Pregnancy health warning labels are biased and flawed

When I was in the 7th form, our biology teacher showed us a smoker’s lung model followed by a brief explanation of the negative effects of smoking. But the model of the damaged lungs itself was enough to educate me, a 13-year-old, about the health consequences I would have to deal with if I ever choose to smoke. This is the essence of freedom that penetrates our adult lives: free choices made in full awareness of the responsibility that follows. Be it alcohol, cigarettes, or sugar. Complex maths formulas we are taught in school are important, but learning about the importance of preserving our consumer choice in the face of nannyism even more so.

By introducing various obligatory warning labels such as “smoking can cause a slow and painful death”, governments all around the world have been trying to compensate for failures of their education systems to effectively convey these messages. Because if everyone knows that smoking isn’t the healthiest habit, they won’t do it, right?

No, they would and should be free to do so. If a consumer is determined to buy a pack of cigarettes, no warning label, and no tax will affect his behaviour. With a plethora of lifestyle regulations, nannying is now seen as inherent to governments. But this is wrong. It is the role of educational establishments to educate us about the effects of smoking or alcohol, but governments are there to guarantee we are able to exercise our freedom to choose as long as we do not cause harm to other people.

In February, Food Standards Australia and New Zealand announced its intention to make labelling on alcoholic drinks mandatory. The new label will include the words “health warning” in bold red text, and “alcohol can cause lifelong harm to your baby”. How obvious, one would say. According to a poll conducted by YouGov, 70 per cent of Australians were aware that drinking while pregnant contributed to Fetal Alcohol Syndrome Disorder. And yet some 70 per cent of respondents supported changing labels on alcohol bottles.

Nothing is wrong with Australians wanting to see warning labels on their alcoholic beverages. The question is whether it’s achieved through government compulsion or voluntarily. In Australia, the existing rules adopted in 2011 make using a symbol with a line through a silhouette of a pregnant woman drinking a glass of wine voluntary. It is of course in the interest of the industry to live up to the expectations of its consumers, but changes to the new labels would cost $400 million in producing new labels. The higher the price of production, the higher the price for consumers.

What about adult male and female (non-pregnant) consumers of alcohol? Is it fair that they would need to pay a higher price for alcoholic products to educate pregnant women about the negative effect of consuming alcohol during pregnancy? Pregnancy health warning labels are biased and ignore the interests of a far wider group of consumers who are hurt by such regulations. It really is cheaper, more sustainable and generally more socially beneficial to invest in proper school education.

At a time when governments are increasingly targeting our consumer choice, we should be prepared to fight back. One drop of nannyism doesn’t make a storm cloud, but a huge accumulation of them does. I don’t like living in a world where I’m treated like a child who doesn’t know that an excess of alcohol, smoking, sugar and [insert other product deemed dangerous] else may cause harm and so needs to be directed away from them. You?

The Consumer Choice Center is the consumer advocacy group supporting lifestyle freedom, innovation, privacy, science, and consumer choice. The main policy areas we focus on are digital, mobility, lifestyle & consumer goods, and health & science.

The CCC represents consumers in over 100 countries across the globe. We closely monitor regulatory trends in Ottawa, Washington, Brussels, Geneva and other hotspots of regulation and inform and activate consumers to fight for #ConsumerChoice. Learn more at consumerchoicecenter.org

Tobacco plain packaging policies have been chasing their own tail

March 12, 2020
By Maria Chaplia
In Blog, Consumer Goods/Lifestyle, Tobacco, Vaping
1 comment

Since 2012, many countries have outlawed branding on tobacco products, and yet more are considering taking this step. One of the most recent examples comes from Ukraine, where a group of parliamentarians have pledged to follow the Australian example of banning all brands by plain packaging as a means of reducing smoking rates. But do such policies actually achieve their desired outcomes?

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. From this perspective, plain packaging coupled with extensive bans on cigarette advertising as a policy solution is useless. Do we really care about the branding of sugar or salt? We buy them anyway.

Smoking has no substitutes per se, but thanks to innovation there are healthier ways to consume nicotine. Vaping has been proven to be 95% less harmful than smoking and has been endorsed by international health bodies as a safer alternative. Public Health England, New Zealand Ministry of Health and Health Canada have all endorsed vaping for encouraging smokers to switch.

Governments that try to outlaw smoking and consumer groups such as the Consumer Choice Center have a shared goal: to uphold public health. We are lucky to live at a time when innovative solutions have made it possible for us to find healthier smoking alternatives. Instead of making futile attempts to fight smoking with taxes and plain packaging, we should create conditions under which smokers can opt for vaping and are encouraged to do so through advertising.

Tobacco plain packaging policies have been chasing their own tail. They simply don’t work and end up becoming another ambitious yet flawed policy that sounds great on paper but doesn’t stand up to scrutiny.

“Think of the children!” – How Lancet researchers parodise themselves

March 4, 2020
By Bill Wirtz
In Brands Matter, Consumer Goods/Lifestyle, Recent Media
0 comments

The Lancet’s new “A Future for the World’s Children?” report is once again some heavy nanny-stating. But this time, it goes right into real-life parody, argues Bill Wirtz.

The once well respected, but increasingly loony Lancet has in recent years endorse some of the harshest Nanny State policies around. From advertising restrictions to taxation of sugary drinks, the Lancet has yet to find a paternalistic policy it doesn’t like. In its newest release, the medical journal is going after advertising to children, which it views as a major threat to children and young adolescents.

Lancet Editor-in-Chief Richard Horton recently told policy-makers in a press release that marketing for cigarettes, electronic cigarettes, alcohol, and junk food is increasingly worrying, and worsening public health concerns. This new report even calls for an optional protocol to be added to the U.N. Convention of the Rights of the Child that would mandate governments to regulate or ban marketing to children for things like sugary drinks and alcohol. “We are living in a fossil fuel-based, consumptive, production driven economy, which creates the conditions for harming the health of children”, Horton adds, saying that “I don’t think any of us can be happy that this is the world that we’re creating.”

The Lancet’s claim that companies are deliberately marketing unhealthy food and other vices to children is hard to grasp. Reading this, all readers are certainly questioning if tobacco companies are putting their cigarettes in strollers. Nothing of the sort has, obviously, happened so far.

Equally, the Lancet continues to condemn that children are subject to alcohol advertising during sports events. They’re referring to the fact that during interruptions of sports broadcasts, there are ads for beer or spirits, which are not only targeted towards adults, but are also accompanied with warning messages about the hazardous nature of these products. In essence, the researchers claim that any ad that could be seen by a child should not contain any risky products, which would, with the fringe exceptions of places such as 18+ cinema screenings, hit every single ad. Adding to that: from my own experience, I can say that sports events like football or motorsport would be something that as a child I would watch with my dad… who would drink a beer during the event. We should not over-inflate our perception of what advertising is really able to do.

In a piece for Comment Central in September, I had laid out why the ASA’s restrictions on certain advertising was equally patronising.

It is also thoroughly contradictory that the Lancet would argue against advertising for harm-reducing products such as e-cigarettes, notably since its own research in other areas of the world (such as New Zealand) shows that vaping has displaced youth cigarette smoking.

Overall, consumers shouldn’t be patronised by blanked advertising bans. There is a case to be made that children should be protected, and many services (such as the video-streaming platform YouTube) already offer browser-based parental controls. However, it is parents that need to play the biggest role in the education of children. Confronting and discussing advertising and the availability of potentially harmful products is a role of parents that they cannot fully or even confidently outsource to the State.

Following the advice of the Lancet would lead us down the path of overprotecting children, all while reducing the consumer choice and information of adult consumers.

Originally published here.

[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 consistent	Strongly consistent	Moderately consistent	Not consistent	No 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 consistent	Strongly consistent	Moderately consistent	Not consistent	No 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.

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

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 ?

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 ?

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 ?

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 ?

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

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

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?

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?

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

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

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

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) ?

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 ?

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 ?

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 ?

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

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 ?

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

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