EuroHealthNet responds to consultation on EU rules on audiovisual media services
EU rules on audiovisual media services are one of the cornerstones of EU media policy and regulation. These rules promote the competitiveness of European media companies and the cross-border circulation of media content, protect viewers and enhance cultural diversity and media pluralism, among other things. The European Commission has opened a consultation to evaluate the impact and added value of the current rules and present proposals for their review, where appropriate.
EuroHealthNet welcomes the Commission’s evaluation/review of the audiovisual media services, including its focus on the rapidly evolving digital media environment, the rise of influencer-led marketing & uneven protection of minors across platforms and Member States.
Children & adolescents spend substantial time in digital spaces, and marketing in these spaces shapes preferences & behaviours that track into adulthood, including regarding their diet and the use of alcohol, nicotine products, and addictive substances. These harms do not ease in adolescence, where exposure and susceptibility remain high – so protection must cover all under-18s. Stronger EU action would particularly benefit children in disadvantaged situations, who are often more exposed & have fewer protective resources, risking widening of existing health inequalities.
Current protection is insufficient, and EuroHealthNet urges moving decisively beyond it and creating enforceable AVMSD minimum standards, as follows:
- Introducing mandatory, enforceable duties for services/platforms and the marketing chain (brands, agencies, platforms, influencers) and supervision/sanctions (e.g. blocking sites & services that don’t comply with EU rules).
- Protecting all under-18s (explicitly adolescents).
- Extending beyond food/drink to harmful/age-inappropriate marketing of products (alcohol, nicotine/ENDS, gambling) and (age/sex/SES) vulnerability-exploitative practices.
- For foods/drinks, embedding the WHO/Europe nutrient profile model in the binding law.
- Reducing exposure to mixed-audience content and modern formats beyond children’s programmes, including influencer ads/’kidfluencing’, placement and sponsorship, promotions, advergames, dark patterns, and other persuasive techniques that appeal to minors.
- Ensuring coherence with the EU digital acquis (DSA) and emerging agenda (Digital Fairness & AI Acts) to reduce fragmentation and enable cross-border enforcement.
- Aligning legal duties with the EU approach to mental health, the new EU Cardiovascular Health Plan, the forthcoming EU Anti-poverty, the new EPSR Action Plan, Intergenerational Fairness strategies, & ensure appropriate funding in the next MFF 2027-2034.
Clearer AVMSD rules would better uphold children’s rights & reduce preventable harms linked to commercial determinants of health (NCD risk, childhood obesity, mental health impacts, addictive products/services). We urge the implementation of the recommendations of JA Best-ReMap & ongoing work by JA PreventNCD.
