House of Lords - A new EU Alcohol Strategy?

A new EU Alcohol Strategy? - European Union Committee Contents

CHAPTER 8: BODIES TO SUPPORT ACTION AT EU LEVEL

196. Witnesses across all sectors were positive about the exchange of expertise and best practice in reducing alcohol-related harm across EU borders, which was regarded as one of the main benefits of the Strategy. Two bodies set up under the Strategy, the Committee on National Alcohol Policy and Action (CNAPA) and the European Alcohol and Health Forum (EAHF), were repeatedly cited as having contributed to this achievement. At the same time, public health interest groups and government representatives were particularly vocal about the shortcomings of these bodies.

197. Alongside some specific issues, there are two overarching problems which affect all bodies set up under the Strategy to some degree: unclear and informal mandates and remits; and unclear and informal relationships between them.

The Committee on National Alcohol Policy and Action (CNAPA)

198. The 2012 review of the Strategy used six evaluation questions to assess CNAPA as an instrument for coordinating national alcohol policies. It found that CNAPA had "supported information exchange and convergence of Member State policies, including through cross-policy discussions", and made two main suggestions for the improvement of CNAPA's work: greater political visibility and strengthened consistency and continuity.[190]

199. CNAPA was not mentioned in the text of the Strategy, which was silent on its role or objectives. Instead, some information on CNAPA's mandate can be found in the Annex to the 2007 Charter establishing the EAHF, which states that "The main objective of this group will be to further coordinate government-driven policies aimed at reducing alcohol-related harm at national and local level, building upon the examples of good practice identified in the Commission's Strategy." The Charter also describes CNAPA's tasks as reviewing national and regional alcohol policy development, "with a view to disseminating best practice across the EU".[191]

200. CNAPA can make an important contribution to EU action on alcohol-related harm by enabling Member State representatives to exchange best practice and coordinate national policies. Examples of CNAPA's work include RARHA and the Joint Action on Youth and Heavy Episodic Drinking, as well as its role in carrying out a scoping exercise following the expiry of the Strategy. However, our evidence has also shown some limitations to its practical value.

201. The Advertising Association felt that "the role of CNAPA as speaking for all Member States is unclear. We understand that some Member States send representatives to CNAPA who do not speak for government departments."[192] Mr Carlin agreed, adding: "I think Member States need to prioritise and nominate officials to CNAPA who are equipped to speak on behalf of their governments and to act to ensure that they gain cross-government support for the policy positions that they take."[193]

202. Some witnesses agreed with the findings of the 2012 evaluation. Lundbeck Ltd suggested that "CNAPA would benefit from more political visibility. For example, beyond the exchange of best practices, CNAPA could open a structured dialogue with the forthcoming EU Trio Presidencies and with the [European Parliament] Health Coordinators to present CNAPA's recommendations on how to take EU policy action on alcohol to the next level."[194] Ms Willmott suggested that CNAPA's role could also be strengthened by establishing it as a full working party under the Council structures.[195]

203. A number of public health NGOs felt that CNAPA's role should also be enhanced in practice.[196] The Alcohol Health Alliance UK wrote: "As CNAPA is the body representing Member States, it is essential that its role be strengthened to reflect its position as the driving force for the design and implementation of a new EU Alcohol Strategy."[197]

204. The current confusion over CNAPA's exact powers, as well as its relationship to the EAHF, Member States and the Commission, may hamper its effectiveness. While this confusion may in part be due to its lack of formal status, it is likely to have been compounded by the Commission's attitude towards its role within the Strategy, which we discuss below.

205. We recommend that the Commission review the structure and functioning of CNAPA in order to ensure that it is fully capable of carrying out its coordination function. In particular, it should encourage Member States to nominate officials who are in a position to represent their governments' views.

The European Alcohol and Health Forum (EAHF)

206. The EAHF was established in 2007, following its inclusion in the Strategy under the heading 'coordination of actions at EU level'. The text of the Strategy stated that "The overall objective of this Forum will be to support, provide input for and monitor the implementation of the Strategy". In practice it has mainly done so by enabling industry and NGO partners to enter into voluntary commitments intended to reduce alcohol-related harm.

207. The 2012 evaluation of the Strategy noted that several sectors and Member States are under-represented in the EAHF. This was supported by a 2013 report on commitments made by members of the EAHF, which found that all but one of the member organisations at the time were from the EU15 countries,[198] with 10 out of 34 Member-State level members being based in the United Kingdom.[199]

208. The evaluation also recommended that the Forum should re-focus its work on fewer well-defined action areas and implement outcome and impact indicators, as well as strengthening its relationship with CNAPA, which we discuss below. Again, our witnesses—many of whom are themselves members of the EAHF—broadly agreed with these findings and felt that, in general, the Forum was a valuable body worth keeping. However, when we began taking oral evidence, it quickly became apparent how greatly the opinions of the industry on the one hand, and the public health lobby on the other hand, differed as to the value of the key feature of the EAHF: the involvement of the alcohol industry.

INDUSTRY INVOLVEMENT

209. Unsurprisingly, representatives of the alcohol industry were positive about the structure of the EAHF, which exemplified the "inclusive multi-stakeholder approach"[200] taken by the Strategy. Mr Beale even considered the Forum to be the Strategy's "key advantage and benefit".[201] The Advertising Association was also particularly enthusiastic, describing the EAHF as "an extremely important mechanism for dialogue between industry, the NGO community and the European Commission … It, or an equivalent channel for this dialogue, must be retained in any future Strategy."[202]

210. Notwithstanding the importance of such a dialogue, spiritsEUROPE was disappointed that the policy debate on alcohol at EU level had become "too polarised and inefficient".[203] The background to this statement is what the Advertising Association described as "repeated complaints from the NGO community about the extent of industry's representation in the EAHF", which were "consistent with public health lobbyists' general suspicion of co- and self-regulation."[204]

211. Witnesses from the public health sector were indeed a great deal less positive about the manner in which the EAHF had been conducting its work and the value of its output. It is also true that many of their concerns related to the extent of industry representation in the EAHF, although it seemed to us that in most cases these were grounded in their first-hand experience as EAHF members.

212. In fact, many public health witnesses appreciated that there was some benefit to involving the alcohol industry at some stage of the EU policy cycle. Eurocare, a member of the EAHF, saw "value in maintaining a mechanism whereby NGOs and public health bodies can discuss with the European Commission how economic operators can contribute to actions that will reduce alcohol harm."[205] Towards the end of an oral evidence session in which all three public health witnesses had been particularly critical of the alcohol industry, Dr Gillan conceded that "of course you have to talk to the industry—of course they are a stakeholder. No one is suggesting that we ignore them completely. However, we have to be clear about where the industry's expertise lies … For example, the industry has a clear role in server training, labelling—there are a number of things that are to do with its role as producers, marketers and sellers of alcohol, and that is what the role should be confined to."[206]

213. Similarly, Prof Sheron confirmed that he was in fact in favour of speaking to representatives of the industry, although he continued: "I have met many members of the drinks industry who were quite committed to doing the best they can to reduce alcohol-related harm, but I have not met a single one who would put the health of the population above the health of their company."[207]

214. The concerns of the public health witnesses related not so much to the fact of industry involvement in the EAHF as to its extent, and the effects which this had on the Forum's priorities. ScHARR told us:

208

215. Public health NGOs, including Eurocare and SHAAP, also had some specific concerns about industry involvement with regard to the interpretation of the Forum's mandate: "Despite the EAHF having no official role in policy development, views of Forum members were sought throughout the development of the EU Alcohol Action Plan, and objections from economic operators to scientific reports produced on behalf of the Forum have been upheld." Eurocare therefore wished to emphasise that, despite their seeing value in the EAHF, "alcohol industry activities should be restricted to their core roles as developers, producers, distributors, marketers and sellers of alcoholic beverages and that they should have no role in the formulation of alcohol policies, which must be protected from distortion by commercial or vested interests."[209]

216. Of all our witnesses, Government representatives seemed to present the most balanced and realistic picture of industry involvement in alcohol policy. In reference to the UK Responsibility Deal, which we discussed in Chapter 7, Lindsay Wilkinson, Deputy Director of Drug and Alcohol Policy at the Department of Health, said: "Alcohol manufactures and retailers can reach their customers in a way that other people cannot … We have a long history of working with the alcohol industry, and we find that it does some things that we are not able to do through any other means."[210] She was, though, also careful to point out that "Ultimately policy formulation is a matter for Member States and governments. There is no reason why the industry cannot say what it believes we should do, but that does not mean that it is part of the decision-making about what happens."[211]

217. It seems that this crucial distinction has been lost in the workings of the EAHF, thanks in particular to its unclear mandate and its involvement in policy setting. This has blurred the line between policy debate and policy formulation, which we regard as unacceptable in the light of the significant industry presence in the Forum.

SUGGESTIONS FOR IMPROVEMENT

218. In recognition of the Forum's general usefulness, and in order to improve its functioning, several witnesses felt that the Forum should become a more focused body, with fewer priorities and clearer indicators to measure the success of commitments. Eurocare and SHAAP suggested the implementation of a work plan by the Commission, aligned to a set of core objectives agreed by CNAPA and drawn up in consultation with Forum members.[212] This would provide a practical framework within which commitments could be made in the EAHF.

219. ScHARR suggested an alternative structure for the EAHF which would separate discussions on alcohol health policy from discussions on policy areas touching upon alcohol-related harm more widely:

213

220. In the light of the evidence described above, we question whether the Strategy's "multi-stakeholder approach", so lauded by the alcohol industry, has actually been a success. It seems that the enthusiasm about its functioning is rather one-sided, while a successful model for cooperation, and in particular dialogue, would require satisfaction by all partners. We believe that there is merit in involving the industry at some stage of the policy cycle. But steps must be taken to address the shortcomings we have identified, in order to make the most of that involvement and foster true cooperation, in place of the "polarised and inefficient" debate that has arisen from the current arrangements.

221. Most witnesses were willing to accept industry involvement at some stage and in some way. It therefore seems to us that it is not the involvement of the alcohol industry per se, but rather the nature of that involvement, combined with the unclear mandate of the Forum itself, which is undermining the EAHF. The EAHF is a valuable policy tool and should be retained, but it should be made clear that it is a tool for the formulation of voluntary commitments to support European alcohol policies, not for setting policy objectives, which should be the role of the Commission and Member States.

222. We recommend that the Commission restate the remit of the EAHF and review its structure and functioning. The terms of reference of the Forum should clearly state the roles and responsibilities of all participating stakeholders, including the alcohol industry.

The Science Group

223. The mandate of the Science Group is found in Annex 3 of the Charter establishing the EAHF: "The main tasks of the Group are to stimulate cross-EU networking of scientific activities around the issues before the Forum and, on request, to: provide scientific guidance … offer guidance on monitoring/ evaluation … provide in-depth analyses of key issues."[214]These tasks include issuing Scientific Opinions when requested by the EAHF. In the six years of the 2006-12 Strategy, only two such Opinions were produced.

224. Prof Anderson—himself an expert member of the Science Group—attributed this low output to uncertainty about the responsibility and funding of the Group: "The problem with the Science Group as it was formulated was that it was never given a very clear mandate and it was not sure what it was supposed to be doing. There was no money whatever to support its work, so the two reports that it did were done completely voluntarily."[215] As a result, the Group's meetings became irregular and rare, with attendance gradually decreasing until the Group became practically defunct.

225. Prof Anderson also had concerns about the selection of the Group's members, stating that they "were not necessarily the ones you might want to discuss policy issues: there were a mixture of people, who were chosen more to represent different interest groups and to get people there."[216] Mr Spillane noted that "After four years of the Science Group, every meeting struggled to have a quorum and, in the end, it was driven largely by scientists linked to organisations that were able to fund their science. Consequently, you ended up with probably the most polarised people sitting in these groups."[217]

226. In March 2014, a group of NGOs called for the Science Group to be strengthened through, among other measures, a new call for experts, additional financial means and improved interaction with the EAHF and CNAPA. The NGOs emphasised the Science Group's key tasks in "moving discussions forward that are blocked due to a lack of conclusive scientific evidence" within the EAHF and CNAPA, as well as "bringing together top scientists in alcohol research".[218]

227. Some witnesses also suggested tasks which a strengthened and well-resourced Science Group could carry out in order to contribute more fully to the Strategy. These included: "setting the scene in each EAHF session on the health consequences of harmful use of alcohol and on new evidence published of interest to the EAHF; identifying research gaps and priorities for EU funding based on discussions with the healthcare members of the EAHF."[219] Written evidence from public health NGOs added that the Group could "ensure that EU alcohol policies are underpinned by an up to date evidence base of effectiveness moving forward, and that the evidence advising such policies is independently verified and free from commercial vested interests."[220] We welcome these constructive suggestions.

228. We agree that an independent Science Group could make a significant contribution to EU action on alcohol-related harm. It would address several of the concerns identified in this report, including the tension between public health and industry representatives in the EAHF, agenda-setting for EU-funded research, and the development of a common evidence base through standardised data collection. If it is to satisfactorily fulfil all these tasks however, it will need to be re-established as an independent body with adequate resources.

229. We recommend the re-establishment of the Science Group, which should be independent from the EAHF and include experts from all Member States. The Science Group should receive adequate support as well as sufficient financial resources from the Commission.

The relationship between supporting bodies

230. The 2012 evaluation of the Strategy explicitly pointed out deficits in the interaction between the bodies intended to assist in its implementation. These findings were endorsed and confirmed by several of our witnesses.[221] When we asked them for their opinions on the structures in place more generally, the unclear and at times troubled relationships amongst the bodies, as well as between them and the Commission, emerged as a concern shared by all sectors.

THE EAHF AND THE SCIENCE GROUP

231. The creation of the Science Group from within the EAHF caused some concern among witnesses from the public health sector. Most of these concerns related to the level of industry influence in the Forum, which we have already described. Prof Meier stated that "there is a very substantial industry representation, so any reports that the Science Group sends to the Forum get filtered through an industry interpretation process."[222]

232. We also received written evidence from several public health NGOs saying that "the Science Group … would be better placed if it reported directly to CNAPA. This would enable policy discussions on the evidence to support interventions to reduce alcohol harm to be free from commercial conflicts of interest … The Science Group of the EAHF should therefore be re-established as an independent expert group, free from membership from economic operators."[223] We agree that, if the Science Group is to act as a broker for discussions on scientific evidence, including within CNAPA, it should have a status separate from the EAHF.

233. Ms Skar and Prof Anderson both emphasised the need for a body similar to the Science Group, regardless of the form it would finally take. Prof Anderson said: "What the Commission needs is a scientific expert body on which it can call and get scientific advice. Looking to the future, I would find a way of reformulating the work of the science group; rather than being the science group for the forum, it should be like an expert or an evidence-based group for the Commission itself."[224] Ms Skar added that "we do believe it is good to have a Science Group, whether it is EMCDDA or the Joint Research Centre or whether we let the Commission use their own. It is not so important how it is organised, but we should have some body that is relatively independent."[225]

CNAPA AND THE EAHF

234. There was feeling among industry EAHF members that "it would be good to see the CNAPA and the European Alcohol and Health Forum working more closely together."[226] The WSTA and SWA were particularly concerned about the lack of coordination between the two bodies, highlighting that there "is currently little or no interaction between the Forum and CNAPA; some Member States do attend the Forum meeting but attendance is low and variable."[227] SpiritsEUROPE added: "More information, communication, and interaction between the Forum members and CNAPA would be welcomed: there is no indication as to the level of awareness of CNAPA members about the discussions, conclusions and, even more broadly, the commitments made in the EAHF over the past seven years."[228]

235. Mr Acton confirmed this, albeit from CNAPA's perspective: "For most of [the EAHF's] existence, there has been almost semi-exclusion of the Member State role. Although we have been notified of Forum meetings, sometimes we do not get the papers, so we cannot decide how important it is to attend. There is no formal process for seeking Member States' opinions on Forum commitments."[229]

236. At the moment, the only document setting out how CNAPA and the EAHF are to interact is the 2007 Charter establishing the EAHF, which states, in a rather scant section entitled 'relations with other structures': "The plenary meetings of the Forum are open to members of [CNAPA and the Committee on data collection and indicators]. Where the work of the Forum is relevant to their agenda, the Committees may invite members of the Forum to contribute to their discussion, alongside other sources of input."

237. Based on the experience of our witnesses from both the EAHF and CNAPA, it seems that the level of interaction between the two bodies is insufficient and should be reviewed. The WSTA and SWA commented: "It would be useful to have formal exchanges between the two bodies. Forum commitments should be on the agenda of each CNAPA meeting, and reciprocally, CNAPA members should present Member States' national developments at Forum meetings." Lundbeck Ltd suggested that the interaction between CNAPA and the EAHF could be improved by "the presence of representatives from the EU Trio Presidencies and CNAPA members at the EAHF meetings—who could report back to CNAPA members on points of relevance".[230]

CNAPA AND THE COMMISSION

238. Mr Carlin argued that CNAPA would benefit from a clear delineation of its responsibilities, as opposed to those of the Commission. Specifically, he suggested that:

231

239. Eurocare argued that "to date CNAPA's view has not been awarded sufficient attention, with several calls for a renewed EU Strategy since 2010 failing to result in action from the European Commission … It is essential that the views and priorities of CNAPA are given active consideration in developing and implementing European alcohol policy."[232] We agree, and believe the Commission should be more supportive of CNAPA's role.

Conclusions

240. The bodies created under the EU Alcohol Strategy 2006-12 have the potential to facilitate the exchange of expertise and best practices across the EU, and therefore to make an important contribution to EU alcohol policy. None of our witnesses, many of whom had first-hand experience and were critical of their functioning, suggested that any of the bodies should be abolished.

241. Despite the contributions made by these bodies, our evidence revealed significant problems with how they operate in practice. Problems common to all bodies are a lack of clear mandates and unclear relationships between them. Putting the existing structures on a more formal footing may go some way to addressing these concerns, including those surrounding the relationships between bodies. In particular, a clear remit for each body, including more limited priorities, could avoid the duplication of tasks and thus waste of resources.

242. In the light of the evident tensions between bodies, as well as between CNAPA and the Commission, further steps are needed to encourage more active cooperation. We consider that the nature and extent of relationships between the bodies should be included in any document formalising the status of CNAPA and an independent Science Group. Links between CNAPA and the EAHF should be strengthened through regular exchanges and mutual representation at meetings, while the administrative links between the EAHF and the Science Group should be severed to ensure the latter's independence.

243. EU action on alcohol should continue to be supported by bodies facilitating the exchange of expertise and best practices, which is seen by many as the key benefit of the EU Alcohol Strategy 2006-12.

244. We recommend that the roles and mandates of CNAPA, the EAHF and the Science Group should be formalised and reviewed periodically. In each case the role should include a clear work plan in line with the stated objective of any future EU action on alcohol abuse, as well as an explanation of the relationships between bodies and the Commission, which should be agreed by the Council.

190 COWI-Milieu, Assessment of the added value of the EU strategy to support Member States in reducing alcohol-related harm (December 2012): http://ec.europa.eu/health/alcohol/docs/ report_assessment_eu_alcohol_strategy_2012_en.pdf [accessed 24 February 2015] Back

191 EAHF, Charter establishing the European Alcohol and Health Forum (June 2014): http://ec.europa.eu/health/ph_determinants/life_style/alcohol/documents/Alcohol_charter2007.pdf [accessed 24 February 2015] Back

192 Written evidence from the Advertising Association (EAS0015) Back

193 Q116 Back

194 Written evidence from Lundbeck Ltd (EAS0011) Back

195 Q158 Back

196 Written evidence from Alcohol Health Alliance UK (EAS0012), Balance (EAS0017), Eurocare (EAS0006) and the Institute for Alcohol Studies (EAS0002) Back

197 Written evidence from Alcohol Health Alliance UK (EAS0012) Back

198 The 15 Member States of the European Union prior to the 2004 enlargement. Back

199 COWI-Milieu, Summary report on commitments made by members of the European Alcohol and Health Forum (October 2013): http://ec.europa.eu/health/alcohol/docs/eahf_commitments_2013_en.pdf [accessed 24 February 2015] Back

200 For example written evidence from SABMiller (EAS0009)and the Advertising Association (EAS0015) Back

201 Q142 Back