CHAPTER 4: THE CASE FOR CONTINUED EU ACTION
Added value to national action
on alcohol-related harm
86. Many of the policy options discussed in this
report remain partly or wholly within Member State competence.
We received a large amount of evidence emphasising the differences
in drinking cultures, patterns and levels of harm across EU Member
States, along with the great importance of local action in reducing
alcohol-related harm. The question therefore arose, whether it
would not be best to leave action on alcohol-related harm entirely
to the Member States.
87. In the 2006-12 Strategy, the Commission described
the reasons for action at EU level as well as what it perceived
to be its own role. It described its main role as raising awareness
on major public health concerns at EU and Member State levels,
and cooperating with Member States in addressing these; initiating
action at EU level when this relates to its field of competence;
and supporting and coordinating national actions. Such actions
are intended to "complement Member State efforts, to add
value to their actions and, in particular, to deal with issues
that Member States cannot effectively handle on their own."
88. The evaluation of the Strategy carried out
in 2012 intended to set out its added value, and according to
several of our witnesses succeeded in doing so.[90]
Speaking generally, Mr Carlin quoted the WHO to say that
"national and local efforts produce better results when they
are supported by regional and global action within agreed policy
frames."[91]
89. We asked our witnesses to explain what role
they thought the EU should and could play to assist national action
on alcohol-related harm. Only Janice Atkinson MEP submitted
that there should be no EU action on alcohol-related harm at all.[92]
All others were more positive, and their comments regarding the
success of the Strategy demonstrated that the EU's role in focusing
the discussion, enabling the exchange of best practice and facilitating
cross-border research were regarded as key in this respect. Mr Carlin
linked this issue to the matter of competence discussed above,
saying "That is the concept of subsidiarity and we absolutely
agree that every Member State should remain free to develop and
implement its own health policies, but the EU policy complements
national actions."[93]
90. The Sheffield University Alcohol Research
Group (ScHARR) said that "the EU can play an important role
by assessing whether Member States' alcohol policies are likely
to achieve (a) their stated aims and (b) the aims of the EU Alcohol
Strategy."[94] Referring
to the interaction between alcohol policy at the national, regional
and EU level, spiritsEUROPE believed that "the Commission
should have a coordinating role in ensuring the coherence of messages
from Member States, ensuring that there is no gap between the
policies and orientations chosen in various international foragiven
the autonomy Members States have in setting their respective national
alcohol policies."[95]
91. Some witnesses stressed that EU action should
be clearly limited, not only by the EU's competence, but also
to areas of added value, leaving all else to the Member States.
A number of potential areas for action were identified as particularly
suited to EU action, as they could not be sufficiently addressed
by unilateral Member State action. These were primarily cross-border
issues related to the trade of alcohol within the EU, including
taxation and labelling, which we consider in Chapters 6 and 7.[96]
92. On the other hand, some alcohol-related policy
areas were explicitly excluded as unsuited to EU action, notably
licensing arrangements and alcohol-related crime. Mr Greaves
noted that such crime cost the UK around £11 billion each
year, but he still cautioned that "It is just a question
of the added value of EU co-operation, of which we remain to be
convinced."[97]
93. Mr Greaves also said that the previous
Strategy's focus on alcohol-related health and other linked harms
largely reflected the competence of the EU to take action to complement
national policies directed towards improving public health. The
EU's competence in relation to criminal matters did not explicitly
cover alcohol-related crime. Before considering inclusion of alcohol-related
crime in the Strategy, Ministers would need to be assured that
any such action respected the limits of the EU's competence and
the principle of subsidiarity. Aside from illicit alcohol, alcohol-related
crime was not necessarily cross-border by nature: "There
are not very new or fast-moving issues to be dealt with in this
issue, as there are perhaps in drugs or other areas, and patterns
of harm and the domestic responses around licensing regulations
and criminal justice systems are very different by member state.
Therefore, we remain to be convinced there is a compelling case
for further co-operation in this area, but this is something that
Home Office Ministers would be consulted on and consider on a
case-by-case basis."[98]
94. Action is worth formulating at EU level
only to the extent that it supplements and supports what Member
States can do independently.
Added value to international
action on alcohol-related harm
95. The WHO has supported EU Member States in
reducing alcohol-related harm through its European Regional Office
since the 1970s. The WHO European Action Plan on reducing the
harmful use of alcohol was first implemented in 1992 and last
updated in 2012. In 1995, the WHO European Charter on Alcohol
was adopted at the European Conference on Health, Society and
Alcohol, "in furtherance" of the European action plan.[99]
Since 2002, the WHO has collected data through the European Alcohol
Information System, as part of the Global Information System on
Alcohol and Health.[100]
96. The WHO European action plan is closely linked
to the WHO's Global Strategy to reduce the harmful use of alcohol
2010,[101] and utilises
the 10 areas for national action identified by the Global Strategy. Box
7: Ten action areas of the WHO European Action Plan 2012-20
· Leadership, awareness and commitment
· Health services' response
· Community and workplace action
· Drink-driving policies and countermeasures
· Availability of alcohol
· Marketing of alcoholic beverages
· Pricing policies
· Reducing the negative consequences of drinking and alcohol intoxication
· Reducing the public health impact of illicit alcohol and informally produced alcohol
· Monitoring and surveillance
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97. Of the ten action areas, the WHO has identified
measures relating to availability, marketing and pricing as 'best
buys': interventions which are cheap, feasible and most cost-effective
in reducing alcohol-related harm.[102]
We received a large amount of evidence on the value of policies
restricting alcohol advertising and regulating the price of alcoholic
beverages, with much less being said about labelling or about
policies restricting availability. This is probably due to the
fact that setting licensing requirements and age limits for purchasing
alcohol are solely within the competence of Member States. We
discuss interventions on pricing, advertising and labelling in
Chapters 6 and 7.
98. In the light of the WHO's extensive work
on reducing alcohol-related harm in Europe, we asked whether there
was any need for additional EU action in this area, and if so,
what shape such action should take in order to constitute real
added value.
99. Dr M¾ller noted that the WHO's
remit was limited to health matters and that it therefore interacted
only with national health ministries. He said "We can work
with other sectors, but it has to pass through the ministry of
health. I think the European Commission has better links to the
different ministries that have impacts on alcohol policies. Therefore,
the EU can be used to focus on more cross-border issues, which
we are not able to do in the same way."[103]
100. Ms Brown agreed: "There are also
very important things which the EU can do within its mandate that
the WHO cannot do. The European Union is a trading region and
there are many elements where collective action is going to be
stronger than Member States or nation states trying to implement
policies on their own." In this regard she mentioned pricing,
marketing and labelling of alcoholic beverages as "areas
where the European Union could enact its mandate in order to ensure
that the policies are implemented across the region and are not
undermined by cross-border issues that could be introduced by
individual Member States."[104]
101. These statements illustrate the difference
between alcohol health policy and alcohol policy more widely.
We found our witnesses' arguments that the EU should reach beyond
the WHO's health mandate by taking a "health in all policies"
approach particularly convincing. The merits of such an approach
will be discussed further in Chapter 5.
102. We also considered how the EU and WHO alcohol
strategies should interact in order to be most effective, and
how this interaction had worked thus far. Dr M¾ller
stated that cooperation between CNAPA, the European Commission
and the WHO European Regional Office had been successful, in particular
in the area of developing indicators. He was particularly positive
about EU funding, which had enabled the WHO to proceed with research
projects it would otherwise not have had the means to pursue.[105]
103. Other witnesses stressed that there should
not be any duplication between the WHO and EU Strategies.[106]
Ms Ellison agreed, stating that while an EU Alcohol Strategy
should be aligned with the objectives and indicators of the WHO
action plan, the Government "definitely [did] not want to
see the two strategies duplicating each other", and was in
favour of a new strategy "addressing areas within its current
rules and areas of competence while taking account of the WHO
view."[107] The
Institute of Alcohol Studies added that "a new EU Alcohol
Strategy should complement existing WHO strategies by including
targets and indicators that have been endorsed by Member States."[108]
104. Although the recommendations made to
Member States by the WHO Global Strategy and European Action Plan
are not legally binding, EU action should not conflict with these
recommendations.
105. EU action on alcohol should continue
to facilitate cooperation between the WHO European Regional Office
and the Commission in the field of alcohol-related harm, in order
to add to the evidence base and avoid duplication, in particular
in the development and application of indicators.
Future work at EU level
106. For the reasons outlined above, all but
one of our witnesses were in favour of some form of continued
EU action on alcohol, and the majority supported action continuing
along the same or at least similar lines to those of the 2006-12
Strategy. Only one industry body indicated that a strategy might
not necessarily be the most effective form of action against alcohol-related
harm in Europe.[109]
All others were adamant that there should continue to be
an EU Alcohol Strategy, though they differed greatly in their
opinions on what such a strategy should look like.
107. Industry representatives all favoured, rather
than an entirely new strategy, a "continuation" of the
2006-12 Strategy,[110]
which would "build on the previous Strategy rather than seeking
to create something entirely different."[111]
Sue Eustace, Director of Public Affairs at the Advertising Association,
described the Strategy as "still fit for purpose",[112]
and Mr Beale felt that "We do not need to reinvent the
wheel".[113] This
view was also supported by the British Beer and Pub Association,
The Brewers of Europe, the Scotch Whisky Association and spiritsEUROPE.[114]
108. Industry witnesses such as Simon Spillane,
Senior Adviser to The Brewers of Europe, also felt that the five
priority areas of the Strategy were still relevant, and should
remain the focus of EU action on alcohol-related harm: "These
are areas that are still valid priorities and, to be honest, they
will not ever go away entirely."[115]
Eurocare agreed that the priorities remained valid, but felt strongly
that they should be added to in the light of developments since
2006.[116] Lundbeck
Ltd highlighted alcohol-related harm in the workplace as an area
which needed increased attention,[117]
while Eurocare advocated that this be separated from alcohol-related
harm among adults more generally.
109. We agree that the five themes remain relevant
generally to addressing alcohol-related harm in EU Member States.
However, given their varying success rates and developments since
2006, it is time to reconsider how suited they are to EU action,
including coordination activities. If areas are to be described
as 'priorities', they should be more specific and the responsibilities
for taking action under them should be clearly allocated. Where
the EU can act, it should take action based on the available evidence.
Member States need some flexibility, but not so much that any
standards imposed by the EU have no real effect.
110. Our evidence has shown significant shortcomings
in how the Strategy operated and still operates, in particular
regarding CNAPA, the EAHF and research. Priority 5, relating to
the establishment of a common evidence base, should be restated
as a main priority and indeed a prerequisite for success in the
remaining priority areas. These are specific issues which need
to be addressed in a way that the previous Strategy did not, so
while its underlying principles and priorities may still be valid,
simply 'continuing' is not an option.
111. There is much to be said for EU action
which deals with matters within EU competence and addresses the
weaknesses which our evidence has revealed. However, we see no
point in the Member States agreeing on a new EU Strategy which
is simply a continuation of the previous one.
112. Any future EU action on alcohol abuse
should state realistic, clearly defined and measurable objectives,
and include an evaluation mechanism to assess its progress and
added value.
113. In the following chapters we consider those
matters where it is in our view appropriate and potentially beneficial
for the EU to take action. We look first at the possible policy
approaches, and then at two of the WHO 'best buy' policies: pricing
and marketing.
90 For example Q141 (Ruxandra Draghia-Akli). Back
91
Q107 (Eric Carlin) Back
92
Written evidence from Janice Atkinson MEP, UKIP (EAS0003) Back
93
Q107 Back
94
Written evidence from the University of Sheffield Alcohol Research
Group (EAS0014) Back
95
Written evidence from spiritsEUROPE (EAS0025) Back
96
For example Q6 (Peter Anderson). Back
97
Q181 Back
98
Q181 Back
99
WHO, European Charter on Alcohol (14 December 1995): http://www.euro.who.int/__data/assets/pdf_file/
0008/79406/EUR_ICP_ALDT_94_03_CN01.pdf
[accessed 24 February 2015] Back
100
WHO, 'Global Health Observatory Data Repository (European Region)':
http://apps.who.int/gho/data/
?showonly=GISAH&theme=main-euro
[accessed 24 February 2015] Back
101
WHO, Global Strategy to reduce the harmful use of alcohol (2010):
http://www.who.int/
substance_abuse/alcstratenglishfinal.pdf
[accessed 24 February 2015] Back
102
For example WHO, From Burden to "Best Buys": Reducing
the Economic Impact of Non-Communicable Diseases in Low- and Middle-Income
Countries (2011), p 7: http://www3.weforum.org/docs/
WEF_WHO_HE_ReducingNonCommunicableDiseases_2011.pdf
[accessed 24 February 2015]; see also Q7 (Peter Anderson) Back
103
Q77 Back
104
Q37 (Katherine Brown) Back
105
Q77 Back
106
Written evidence from the British Beer and Pub Association (EAS0013)
and the Department of Health (EAS0019) Back
107
Q231 (Jane Ellison MP) Back
108
Written evidence from the Institute of Alcohol Studies (EAS0002) Back
109
Written evidence from WSTA (EAS0016) Back
110
Q201 (Henry Ashworth) Back
111
Written evidence from BBPA (EAS0013) Back
112
Q201 Back
113
Q186 Back
114
Written evidence from BBPA (EAS0013) and SWA (EAS0020); Q118
(Paul Skehan); Q119 (Simon Spillane) Back
115
Q119 Back
116
Written evidence from Eurocare (EAS0006) Back
117
Written evidence from Lundbeck Ltd (EAS0011) Back
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