Consultations Responses


Response to Consultation on European Child Guarantee for Vulnerable Children

EuroHealthNet has responded to a consultation from the European Commission on the EU Child Guarantee for Vulnerable Children. 

Response to consultation on the contributions of regions and cities to sustainable development

EuroHealthNet has responded to a consultation from the European Committee of the Regions and the OECD on the role of regions and cities in achieving the Sustainable Development Goals.

Impact Assessment Evaluation and Fitness Check Roadmap of the European Social Fund (2014-2020)

This evaluation will assess:

  • how the European Social Fund (ESF) promotes social inclusion (integrating disadvantaged people into society and ensuring fairer life opportunities for all) and combats poverty/discrimination;
  • structural reforms;
  • the visibility, usefulness, relevance, value for money and effectiveness of ESF measures.

As basis for Public Consultation planned for Q3 2019.

Submitted online on 16 January 2019. See our evaluation here.

Fitness Check Roadmap


The European Social Fund (ESF) is a major financial instrument to help pursue the Europe 2020 strategy’s objectives for smart, sustainable and inclusive growth, building up a more social Europe, guided by the European Pillar of Social Rights, and in line with the European Semester. Well-functioning health systems across Europe are central to meeting the headline targets of this strategic vision, particularly those relating to employment, education and social inclusion performance. For EuroHealthNet, ESF represents a valuable instrument to reduce health inequalities between and within EU Member States and further boost investments in structural determinants of health, health promotion and disease prevention measures.

Income and wealth inequality, and the associated levels of health inequalities are persistent and growing in many EU countries. Most EU Member States systematically allocate more than the required 20% of the ESF national resources to promote “social inclusion, combating poverty and any discrimination”(1), showing more ambitious investments are needed to address common social challenges. Evidence from EU funded initiatives that EuroHealthNet has been involved in (ESIF for Health(2), Equity Action(3)) and feedback from our members reflect how ESF can be used to make an impact on social inclusion and the reduction of poverty through action in the areas of health and wellbeing. They reflect that ESF is applied across the EU on a range of initiatives that e.g. improve the provision and quality of health and social care, incl. health promoting services, and strengthen capacities within these systems to provide accessible and quality services, particularly for socially vulnerable people. In many cases, these measures also boost cooperation between health and other key sectors.

Only a fraction of ESF funds are however currently being spent on such actions, and more can be done to maximise the impact of ESF in these areas, and to society at large. More can for example be done to raise awareness amongst professionals in other keys sectors like health about the funds, and to build capacities to enable them to engage, both strategically and practically. Furthermore, the administrative burden of obtaining and administering the funds should be reduced, including for smaller (civil society) organisations that are nevertheless crucial service providers and economic actors. In addition, projects cannot just of themselves deliver systemic change; they must be part of a broader strategy that aims to do this. The EU and its MS must in this respect acknowledge that social policy, health policy, environmental policy and economic outcomes are tightly inter-related, and encourage the implementation of strategies and programmes that deliver co-benefits across sectors. MS must therefore be encouraged to combine the use of EU funds for greater impact, and to invest as much in people (services, capacity building, learning exchange, awareness) as in hard infrastructure projects, as Slovenia and Latvia (4) have done by combining EDRF and ESF to achieve national strategic objectives.

Looking to the future EU budget and its ESF+, we call on these to emphasise the need to address inequalities in our societies, with a focus on fairness, vulnerability and early years. Performance indicators should, in addition, be applied that are aligned to the Social Scoreboard and were possible the SDG indicators, and other reputable measures of equity and wellbeing (5).



1. Regulation No. 1304/2013

2. Mc.Guinn J, Ganche M et al. ESIF for For Health. Investing for a healthy and inclusive EU. Milieu, 2018

3. Stegeman, I, Kuipers Y. Health Equity and Regional Development in the EU, Applying the EU Structural Funds, EuroHealthNet, 2013

4. EuroHealthNet Online Magazine, 2018 summer edition

5. A Healthy Budget? Analysis of the MFF 2021-27, EuroHealthNet


Why tobacco taxation matters for health equity

Tobacco consumption is the most significant cause of premature death in the EU and one that disproportionally affects our poorest and most disadvantaged citizens. Not only are rates of tobacco consumption higher amongst the lowest socio-economic groups, they suffer more from its effects.

EuroHealthNet has summarised it’s knowledge and position on tobacco taxation in a response to a European Commission’s consultation in August 2018. The full response can be found below.

Although the rate of tobacco use has declined, it has not declined enough nor equally amongst all groups. Much more remains to be done. Tobacco taxation is a very cost-effective public health prevention as revenues increase and smoking rates fall.

The use of novel tobacco products looks set to grow. National initiatives to research and regulate e-cigarettes and packaging are encouraging, but while the long – term effects of e-cigarette use remain unknown, caution should prevail. Clinician-led use of novel products can have a place in tobacco cessation services,  along with increased health literacy and health education as part of wider health promotion approach. However, unregulated and fully open markets can perpetuate the sale of harmful products, exploiting the vulnerability and inequalities experienced by certain groups

The EuroHealthNet partnership strongly supports the continued increase of excise duties and taxation on traditional tobacco products and the consistent excise treatment of e-cigarettes as an equivalent product to tobacco

In response to the consultation response, EuroHealthNet expresses:

  • Strong support for the further increase of tobacco taxes and the EU wide harmonisation of fiscal policy with regard to e-cigarettes, to bring their treatment into line with that of conventional tobacco products
  • Strong support for effective and comprehensive regulation at European level, including agreement on a common fiscal definition and the establishment of distinct category for e-cigarettes in EU excise legislation
  • Strong support for the adoption of an intelligent and contextual approach to regulation to mitigate the risk of e-cigarettes becoming a ‘gateway’ product to tobacco, particularly amongst those who are young and/or vulnerable
  • A cautious endorsement for the use of e-cigarettes as one element of properly planned and supervised smoking cessation programmes.

Consultation on the integration of the long - term unemployed into the labour market

In June 2018, EuroHealthNet replied to the European Commission's consultation on the integration of long - term unemployed into the labour market

EuroHealthNet urges EU institutions to address the imperative of addressing the health, social, economic and structural barriers linked to the (un-)employment, in particular of people with chronic diseases, to ensure that all people can meaningfully contribute to economies and societies . with special attention to quality work. It is also necessary to increasingly apply a structural approach recognising that EU goes beyond individual choice.

Response to inception impact assessment on the future Recommendation on Quality in Early Childhood Education and Care

EuroHealthNet submitted a response to the inception impact assessment on the future Recommendation on Quality in Early Childhood Education and Care, April 2018.

It also submitted a joint response as part of the alliance for investing in Children.

EuroHealthNet’s policy recommendations are:

  • The QECEC Recommendation should make a clear connection to health equity and wellbeing over the life course.
  • The QECEC Recommendation should promote the investment in early years to support good quality early years education and childcare provided in a proportionate way across the social gradient. Support for families should be improved by investing in pre- and post-natal interventions, encouraging parental leave, ensuring the income for a decent life, as well as through parenting programmes and children’s centres including outreach interventions to identify the most vulnerable and provide targeted support.
  • Use the European Regional Development Fund and European Social Fund to implement early child health and development interventions in areas of social deprivation.
  • Foster the implementation of the EC Recommendation on Investing in Children, which calls on MS to support parents into paid work and improve access to affordable early year’s childcare, education, and healthcare.
  • Connect the initiative to the EU Semester (Country Specific Recommendations, National Reform Programmes, and the Social Scoreboard – in the latter is it necessary to broaden the use of indicators to “children at the risk of poverty and social exclusion”).
  • Connect the initiative to the European Pillar of Social Rights (Principle 11: Childcare and Support to Children; the Social Scoreboard; the Work-Life Balance Directive).

Consultation on the next Multiannual Financial Framework (MFF)

EuroHealthNet has submitted three specific responses to the EU Public Consultation on the future EU revenue and expenditure priorities for 2021-27, known as the post 2020 MFF.

The three submitted questionnaire responses provide answers on EU funds in the area of:

  • Health, Research & Innovation in the Single Market;
  • Cohesion
  • Values & mobility

A short summary document of the responses and the three submmitted contributions can be downloaded by clicking on the links below.

Consultatons on vaccinations

In February 2018 EuroHealthNet responded to stakeholder and public consultations on vaccination.

The document below summarises EuroHealthNet’s response to the European Commission’s consultations on possible activities to be included in a proposal for a Council Recommendation on Strengthened Cooperation against Vaccine Preventable Diseases, which will be adopted mid-2018.

It addresses three aspects:

  1. Tackling vaccine hesitancy at national and EU level;
  2. Sustainable vaccine policies in the EU;
  3. EU coordination, including the promotion of stakeholder dialogue, and contribution to global health.

From a health equity perspective EuroHealthNet considers that priority should be given to addressing the needs and fulfilling the right to health of the underserved. This requires better commitment, investment and outreach programmes to tackle the under coverage of marginalised, migrant, or socially disadvantaged children and families. It is important to invest in health promotion and education programmes, and fight vaccine hesitancy by providing transparent and evidence-based information to the public in targeted and tailored ways.


Consultation on health and care in the digital single market

EuroHealthNet responded to the public consultation on transformation of health and care in the
digital single market

Communication on Digital transformation of health and care in the context of the Digital Single Market

EuroHealthNet welcomes the consultation towards a Roadmap for the EC Communication on this subject. The collaboration between DGs CONNECT and SANTE is particularly important; however this should be extended to ensure cohesion with other relevant DGs and EU
instruments such as the EU Semester processes and the potential EU Pillar of Social Rights. Mention of the need to address health inequalities is welcome; however this is potentially both a key positive and negative factor and should be more prominent. Since the 2009 Communication Solidarity in Health it is increasingly recognised that health inequalities cost EU governments significantly: they reduce people’s ability to contribute to society, undermine economic growth and prosperity, and increase health, social care and wider public expenditures.

Digital technologies do offer new opportunities to transform health care systems, including new approaches to personalised prevention, treatments and care, independent living, integrated health and social care, accelerated scientific progress for early diagnosis and prevention of diseases. However, there are significant risks and obstacles of inequitable implementation including safety, access, effectiveness and authority.

Consultation on EU urban agenda

EuroHealthNet responded to the consultation on the EU urban agena in relation to air quality, inclusion of migrants & refugees, and urban poverty.

Modernising and Simplifying the Common Agricultural Policy (CAP)

EuroHealthNet responded to the EU survey Modernising and Simplifying the Common Agricultural Policy (CAP)

mid-term evaluation of the European Union Programme for Employment and Social Innovation (EaSI)

EuroHealthNet responded to the mid-term evaluation of the European Union Programme for Employment and Social Innovation (EaSI)

Public Consultation for the Evaluation of the EU Agencies: EUROFOUND, CEDEFOP, ETF and EUOSHA

EuroHealthNet responded to the Public Consultation for the Evaluation of the EU Agencies: EUROFOUND, CEDEFOP, ETF and EUOSHA

Public Consultation on the European Solidarity Corps

EuroHealthNet responded to the Public Consultation on the European Solidarity Corps

Tobacco Excise

EuroHealthNet responded to the Public consultation  on Excise duties applied to manufactured tobacco

Evaluation of the long-term unemployed recommendation

This feedback builds upon the impact long term unemployment (LTU) has on health inequalities (HI). HI cost EU governments significantly: they reduce people’s ability to contribute to society, undermine economic growth and prosperity, and increase health, social care and wider public expenditures.

The link between unemployment and ill health is well established. Unemployment has a higher negative on health for people from low socio-economic groups. Unsurprisingly, LTU sees effects on ill health compounded: people experience negative pressures on their physical
and mental health.

Mid-term evaluation of the Third Health Programme

EuroHealthNet contributed to the consultation on the Mid-term evaluation of the Third Health Programme (2014-2020)

Consultation on Digital Health Societies

Digital health is a potential set of tools and instruments within processes to tackle inequities. Digital health offers the advantage of increasing access to disadvantaged populations. However this is not only about access to services, but also an opportunity for empowerment, balancing collective rights (to organise systems for States, Authorities and providers) with individual rights (rights to care, treatment, protection and prevention as set out in the EU Treaty, Charter of Fundamental Rights and potential EU Pillar of Social Rights).

In that context digitalisation of health and care systems could be a key trigger for removing health inequalities, as foreseen in the 2009 EU Communication Solidarity in Health; in the UN Agenda 2030 and Sustainable Development Goals (SDGs) and in the evidence and recommendations of the WHO Commission for Social Determinants of Health (SDH).

EuroHealthNet, the European Partnership for sustainable health promotion, wellbeing and social equity, has identified technological changes as one of the ten greatest priorities to be embraced and applied by public health and health promotion sectors towards 2030 objectives. EuroHealthNet is working with its national and regional members, EU Institutions and WHO Europe on sustainable health systems, health information systems, data use, health determinants and health literacy.


Consultation on Evaluation of the Youth policy cooperation in the EU

EuroHealthNet responded to the public consultation on evaluation of the Youth policy cooperation in the EU

Possible action to address the challenges of work-life balance faced by working parents and caregivers

EuroHealthNet responded to the EU survey on possible action to address the challenges of work-life balance faced by working parents and caregivers

Consultation on the Energy Union

EuroHealthNet responded to the public consultation on the development of a comprehensive, integrated Research, Innovation, and Competitiveness Strategy for the Energy Union.

On the proposal by the European Commission to establish a potential European Pillar of Social Rights (EPSR)

EuroHealthNet has conditionally welcomed the European Commission (EC) initiative to establish a “European Pillar of Social Rights”. Announcing its overall position after a substantial consultation with members and partners in EU Member States, EuroHealthNet sees the Pillar as an opportunity to clarify unclear objectives and provisions in the EU Treaties and body of laws concerning equality, wellbeing and social determinants of health. EuroHeathNet has made concrete proposals for the implementation of the initiative.

EuroHealthNet warns against risks of increasing inequalities if Eurozone states are treated differently from others, but insists “There can be no EU without a social EU”. Its members feel that many health and social responsibilities should remain with States and sub-national authorities, but there is scope for improvements in existing legislation, plus some important new initiatives.

In particular, EuroHealthNet calls for numerous actions and investment directly related to social and economic factors causing ill-health, plus several innovative ideas for content of the potential Pillar:

  • An EC Vice President with responsibility to ensure implementation of social measures;
  • A new Directive on Social Sustainability using models in development in Sweden and elsewhere;
  • Improved measures to support States address health and social issues in the EU Semester;
  • Alignment of goals and targets with the global 2030 Sustainable Development commitments

Better Research for Better Health: EuroHealthNet's comments and recommendations

EuroHealthNet has been invited to respond in writing to a consultation on the European Commission's Scientific Panel for Health (SPH) Vision paper Better research for better health. The paper presents key recommendations for health and biomedical research under the Horizon 2020 Framework Programme.

While acknowledging that the paper presents some interesting points, EuroHealthNet fears that the paper’s approach is almost exclusively from a biomedical point of view, and calls for a more holistic approach.

Through the consultation’s response, EuroHealthNet highlights how to achieve health and well-being for all the issue should be seen from a wider perspective that considers social and environmental determinants as having as much impact on health as biological and genetic factors.

To access the response from EuroHealthNet, click here.


Consultation Response to the public consultation on long-term unemployment

While responding to this consultation, EuroHealthNet highlighted some of the most relevant evidence-based practices and findings of its FP7 DRIVERS project. Involving prominent research centres and public health, civil society and business organisations, DRIVERS’ goal was to find solutions to improve health equity through policy and practice in (among other areas of focus) fair employment, income and social protection.

This consultation response is an evidenced-based contribution resulting from EuroHealthNet’s FP7-funded DRIVERS project focused on links and best ways to tackle equity through policy in, amongst others, employment and working conditions.

To access the response from EuroHealthNet, click here.


EuroHealthNet's response to public consultation on the Europe 2020 strategy

The Europe 2020 strategy was launched in March 2010 as the EU's strategy for promoting smart, sustainable and inclusive growth. It aims to achieve a knowledge-based, competitive European economy while preserving the EU's social market economy model and improving resource efficiency. It was thus conceived as a partnership between the EU and its Member States driven by the promotion of growth and jobs.

After four years, the Commission has proposed, and the European Council of 20-21 March 2014 has agreed, to initiate a review of the Europe 2020 strategy. On 5 March 2014, the Commission adopted a Communication "Taking stock of the Europe 2020 strategy for smart, sustainable and inclusive growth". drawing preliminary lessons on the first years of implementation of the strategy. Building on these first outcomes and in a context of a gradual recovery of the European economies, it is time to reflect on the design of the strategy for the coming years.

Through these questions, EuroHealthNet, its members and its partners suggest how health and systems can become part of the solution for Europe's ills rather than bes seen as part of the problem. 

Read EuroHealthNet's response to the public consultation on the Europe 2020 stragey here

EuroHealthNet response to the European Commission’s public consultation on the Green paper on mobile Health (mHealth)

Mobile Health (mHealth) is a relevant topic for EuroHealthNet as it bears great potential for novel means of health promotion, disease prevention and healthcare. The use of mobile and wireless technologies can support achievement of various health objectives.

However, EuroHealthNet wants to highlight that there are various aspects that have to be taken into consideration when designing and implementing mHealth solutions. One is that there are different levels of knowledge, skills and capabilities within the social groups, which play an important role in understanding new technologies and the messages it delivers. If they are ignored then mHealth promotion activities and mHealth treatment and monitoring will widen inequalities and create an even bigger health gap between advantaged and disadvantaged groups in society. It is therefore crucial to ensure that the design and application of mHealth is tailored accordingly to the needs and skills of different (social) groups, and that the merits of health technology benefit the whole society.

EuroHealthNet responds to the consultation by focusing and commenting particularly on the questions that are most relevant to health promotion and disease prevention from the social and health equity perspective.


EuroHealthNet's response to the European Commission’s Green Paper on Restructuring and anticipation of change: What lessons from recent experience?

EuroHealthnet - Demography Report 2010: Older, more numerous and diverse Europeans


EuroHealthNet's response to the public consultation on the eHealth Action Plan (eHAP) 2012-2020

EuroHealthNet’s comments on the EU Public Health Programme post-2013,

EuroHealthNet replies to the Commission Green Paper on a common strategic framework for EU research and innovation funding

EuroHealthNet's Summary - Synthesis report on the public consultation on the European Innovation Partnership on Active and Healthy Ageing

EuroHealthNet’s response to the consultation on the conclusions of the Fifth Report on Economic and Social Cohesion-January 2011

European Public Health and Agriculture Consortium’s (EPHAC) response to “The reform of the CAP towards 2020- Impact Assessment"


EuroHealthNet response to the European Commission’s Green Paper towards adequate, sustainable and safe European pension systems

EuroHealthNet response to the European Commission consultation on the EU2020 strategy

EuroHealthNet response to the European Commission pre-consultation on the future of the Common Agricultural Policy


EuroHealthNet response to the European Commission communication on health inequalities

EuroHealthNet response to the European Commission consultation on the role of the EU in Global Health


EuroHealthNet Response to "Modernising social protection for greater social justice and economic cohesion: taking forward the active inclusion of people furthest from the labour market."


EuroHealthNet contribution to EC Social Reality Stocktaking Consultation


EuroHealthNet Response to "Towards a reform of the common market organisation for the fresh and processed fruit and vegetable sectors"


EuroHealthNet Response to the Commission Proposal for a joint Programme in the Field of Health and Consumer Protection (2007-2013)

EuroHealthNet response to EC Communication "Community Strategic Guidelines for Cohesion Policy"

EuroHealthNet response to EC Communication "Community Strategic Guidelines for Cohesion Policy"

EuroHealthNet Response to the Communication from the Commission on "Confronting demographic change: a new solidarity between the generations"