Consultations Responses


EuroHealthNet responds to the European Commission's Green Paper on Ageing

EuroHealthNet has responded to the European Commissions Green Paper on Ageing. While welcoming the EU Institutions’ intention to mainstream ageing policies across all EU policies, we believe that EU actions should strengthen a greater focus on health inequalities and healthy life years, as key indicators of whether the policies, practice and investments being made to ‘foster solidarity and responsibility between generations’ are truly benefiting the health of people and generating more well-being across states, societies and communities.

We know three quarters of inequalities in health outcomes in older age are due to determining factors of the physical, social and economic environments in which people are born, grow, live, work and age. The exponential rise in the epidemic of the non-communicable diseases (NCDs), driven by common underlying risk factors is largely responsible for poor health in older age. These result in accumulative negative impacts throughout the life-course, starting in early years. This is due to structural determinants of health and health inequalities which underpin unequal distribution of good health at the population level and among different social groups. These are the true “causes of the causes”: this is where policy and practice needs to impact to be effective.

EuroHealthNet recommends:

  1. Changes in how we understand and act towards healthy and active ageing.
  2. Developing communities in ways that foster the abilities of people along the life-course.
  3. Bring forward attention to the inter-sectoral workforce for ageing populations
  4. Rebalance the unequal distribution of power, means and resources for healthy and active ageing
  5. Systematically include health and health equity in assessments of disparities in ageing.

Find EuroHealthNet's full response to the Agein Green Paper here.

EuroHealthNet responds to the 2030 Digital Targets

In March 2021, EuroHealthNet provided input on the European Commission's Coomunication on the Europe’s digital decade – 2030 digital targets. Following President von der Leyen’s proposal for a common digital plan towards 2030, this Communication sets out a vision of what a successful digital transformation will mean for Europeans by 2030.

The digital transformation of our societies is on its way and the years to come are crucial to define how this process will be steered. Health and social inequalities are prevalent in most European societies, and the digital transformation offers an opportunity to tackle them. On the other hand, should challenges and barriers to inclusion not be addressed today, the digitisation process could exacerbate pre-existing inequalities and their manifestations among various population groups.

In its response, EuroHealthNet sets out 7 recommendations to ensure that the strategy helps reduce rather dan increase inequalities. Find the response here

EuroHealthNet input to the roadmap on the provision of food information to consumers

EuroHealthNet welcomes the EC’s commitment to establishing harmonised mandatory front-of-pack (FOP) nutrition labelling and nutrient profiles in the context of the EU Farm to Fork Strategy. While recognising the complexity involved in of doing so, we strongly support both initiatives as part of a comprehensive, ambitious, and truly transformative transition to European food systems. EuroHealthNet counsels however against a disproportionate focus on ‘downstream’ behaviour-change and lifestyle-oriented measures alone without a genuine appreciation of the underlying causes of poor nutritional choices, the socio-economic determinants. Issues of social fairness and deprivation, affordability, health- and digital literacy will be key in this transition.

EuroHealthNet submitted insights on the following topics:

  • Policy options for front-of-pack labels
  • Off-line vs. digital nutritional labelling
  • Policy options for date marking
  • Social and fundamental rights impacts
  • Environmental impacts
  • Economic impacts
  • Evidence base and data collection

More information is available here

The full feedback can be found below. 

EuroHealthNet input to the EC Roadmap consultation on EU farm and food product promotion

EuroHealthNet welcomes the EC’s commitment to review the EU promotion policy for agricultural products. We strongly support a comprehensive, ambitious, and truly transformative transition to European food systems that put public and planetary health, sustainability, and social equity at the centre. EU’s policy for the promotion of agricultural products should be no exception.

Today's food systems are perpetuating and driving up health inequalities. To this end, a pivotal role for a modern, fit-for-purpose EU promotion policy for agricultural products will be in supporting food environments where “a healthy and sustainable choice is an easy choice” for all, and where the agricultural sector is sufficiently geared towards this transition in line with the EU Green Deal’s ambitions.

EuroHealthNet recommends the following:

  • re-focus the policy scope on promotion and information measures.
  • investigate using promotion funds to support ‘alternative’ modes of agricultural production.
  • review the conditionality and eligibility criteria.
  • consider excluding certain sectors from promotional funds.

The full feedback can be found below. 

EuroHealthNet input to the EC Roadmap consultation on the 8th progress report on economic, social and regional cohesion

EuroHealthNet believes that the 8th report on economic, social and territorial disparities should include a greater focus on health inequalities, as a key indicator of whether the investments being made to improve cohesion are truly benefiting the health of people and generating more well-being across societies. Since the publication of the 7th progress report on economic, social and regional cohesion, the situation across the EU and the world has dramatically changed. The COVID-19 syndemic, which can be seen as symptom of the chronic environmental crisis we face, has made all too clear the inter-relationship between health and the economy. However, this time also provides an opportunity to reassess our values and invest in initiatives that strengthen the EU’s social foundations, while re-orienting economic activities to respect planetary boundaries.

EuroHealthNet recommends the following to strengthen cohesion and to deliver on the EU’s priorities in relation to achieving a fair green and digital transition:

  • Systematically include health and health equity in assessments of regional disparities.
  • Assess the extent to which a wide range of sectors, including the health and social sectors, are collaborating to define and implement funding priorities.
  • Encourage EU Member States to develop pan-governmental strategies and set targets to reduce health inequalities.

More information is available here

The full feedback can be found below. 

EuroHealthNet contribution on EU Strategic Framework on Health and Safety at Work

EuroHealthNet welcomed the opportunity to give input for the future Strategic Framework on Health and Safety at Work 2021-2027. EuroHealthNet would like to highlight that it will be critical for the updated strategic framework to adequately address psycho-social factors of health and safety at work, including in increasingly digitalised workplaces, and their distributional impact on various 'vulnerable' population groups. Quantitative and qualitative evidence from longitudinal and systematic reviews confirms that physical and mental health are very closely inter-related. Most people spend a very large proportion of their lives at work, therefore workplaces are key settings to safeguard mental health and that doing so and investing in the workplace as health-enhancing settings can generate large returns on productivity, reduce health and social costs. Here, concepts and measures of the Wellbeing Economy should be looked into. The new EU OSH strategy will need to align with a number of other EU initiatives to amplify impacts, notably EU Pact for Skills, EU Digital Targets 2030, work on platform economy, but also with measures supporting the green transition.

A joint statement with the EU MH Alliance (The European Alliance for Mental Health – Employment & Work), is available here

The full feedback can be find in the link below. 

EuroHealthNet Input to the European Commission's Feedback to the European Health Data Space

EuroHealthNet welcomes the European Commission’s initiative to establish a European Health Data Space with the purpose of promoting access to health data for research and innovation on new preventive strategies, as well as on diagnosis and treatment of diseases to improve health outcomes, while ensuring that citizens have control over their own personal data.

The European Health Data Space (EHDS) aims for “making the most of the potential of digital health to provide high-quality healthcare and reduce inequalities”. Improved safe health data collection and use could certainly improve monitoring and prevention systems, as well as enhance the ability of people to better understand and engage in their own wellbeing via multiple applications and tools.

However, EuroHealthNet remarks that there are significant challenges to be addressed and safeguards to be ensured:

  • Standardisation of data is a key for the deployment of the EHDS and use of health data across the EU.
  • The development of sound digital infrastructures should ensure the collection of high-quality data that add value to health systems in a non-discriminatory way.
  • Data/Digital Health Literacy programmes should be an integral part of the EU actions on the EHDS.
  • The deployment of the EHDS should go hand in hand with training and capacity building programmes for professionals (including through up- and re-skilling) .

More information is available here

The full feedback can be found below. 


Consultation on EU pact for skills

EuroHealthNet responded to a consulation on the EU Pact for Skills and about different options to strengthen it.

Skills anticipation should also include equity and wellbeing needs, including health literacy and preparedness

Revision of Directive 2011/64/EU on the structure and rates of excise duty applied to manufactured tobacco: Inception Impact Assessment

EuroHealthNet has responsed to the Commission consultation on the Revision of Directive 2011/64/EU on the structure and rates of excise duty applied to manufactured tobacco: Inception Impact Assessment.

EuroHealthNet supports comprehensive and effective regulatory and taxation measures that reduce the consumption of manufactured tobacco and novel tobacco products as a matter of health equity in Europe.

EuroHealthNet recommends to:

  • Strongly support the further closure of the tax gap and increase of tobacco taxes, as well as the EU wide harmonisation of fiscal policy with regard to novel tobacco products, to bring their internal market treatment into line with that of conventional tobacco products;
  • Promote an effective and comprehensive regulation at the European level, including agreement on a common fiscal definition and the establishment of distinct category for e-cigarettes in EU excise legislation;
  • Adopt 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; invest in (digital) health literacy and health education;
  • Strengthen existing legislation to curb tobacco industry influence, especially in the (digital) advertising and marketing and digital tax sphere;
  • Cautiously endorse the use of e-cigarettes as one element of properly planned and supervised smoking cessation programmes, while further research into health effects of the novel tobacco products should continue.

Green paper on ageing consultation - Demographic change in Europe -

With demographic change causing Europe’s population to age, the European Commission plans to launch a green paper which will:

  • set out the key issues related to ageing
  • discuss possible ways to anticipate and respond to the socioeconomic impacts of Europe’s ageing population.

In giving feedback on the plans for the green paper, EuroHealtNet higlighted that:

  • health promotion and prevention should be central to European and national efforts to assess, prepare and act in a timely way to keep people healthy.
  • It is right to note regional inequalities in health outcomes and abilities to absorb the impact of demographic change.
  • We do not all age equally; people with lower levels of education and low-status jobs suffer more from the negative aspects of ageing more than others, and experience those aspects earlier. There are also gendered inequalities
  • There has so far been a lack of discussion on health as investment and the economic returns that can be achieved. improved implementation and enhancing enforcement of preventative measures across broader segments of the population “could extend the number of years in good health by a decade”.
  • Enabling healthy ageing begins in early years

We recommend to:

  • adopt a holistic, people-centered, and inter-sectoral community-based approach to healthy and active ageing across the life-course.
  • Recognise that human and financial investments in healthy and active ageing constitute a vital asset, not a burden to health and social costs in Europe.
  • Bring forward attention to the workforce for ageing populations especially in the long-term care, employment/productivity of older population with a particular focus on the psychosocial dimension of occupational health and safety strategies, closing the digital skills divide.
  • Prioritise preventative measures within primary health care, focus on chronic and non-communicable diseases, including mental health and cognitive functioning.
  • Recognise large inequalities in ageing not only between regions but importantly between people with different social and economic statuses. An assessment of the effects on equity and different groups of people should be central to all future actions and proposals


EuroHealthNet Contribution to the Action plan to implement the European Pillar of Social Rights

EuroHealthNet recognises the commitment to the action plan to fully implement the European Pillar of Social Rights (EPSR) and the progress that has been made. However, the political, societal, health and economic context has changed dramatically with the COVID-19 crisis. The EPSR will need to be strengthened to guide EC and Member States’ work, as has been demonstrated in the Joint Report by EuroHealthNet and the EU Joint Action for Health and Equity (JAHEE) on the 2020 European Semester for economic, social and sustainable governance, in which the EPSR plays an important role. 

Our report, in addition to other substantial evidence, has shown the need for a stronger Action Plan to be implemented from 2021. The current fragility of many social rights has been exposed by the pandemic of infectious and non-communicable diseases, in the context of persistent and growing social and health inequalities. EuroHealthNet has been involved in promoting and developing the EPSR since its initiation. But the new paradigm requires new efforts to recover from the economic and social consequences of COVID-19 impacts, towards greener, fairer and more equitable societies, taking into account the opportunities and challenges of the digital transformation. The Action Plan to implement the EPSR will be a vital vehicle to outline further policy initiatives that can support the implementation of its 20 principles.

Therefore, EuroHealthNet gave recommendations and evidence in the most relevant aspects from our perspective, guided by the questions posed in the public consultation.

The feedback in full can be found below. 

EuroHealthNet Contribution to the EU strategy on the rights of the child (2021- 2024)

EuroHealthNet welcomes the EU strategy on the rights of the child (2021-2024). In the response EuroHealthNet highlighted that not all children and adolescents have equal access to the opportunities to lead healthy, happy and prosperous lives. The situation has worsened during the pandemic, with highly likely adverse consequences to children and young people's psycho-social health and wellbeing. Importantly, those negative impacts have been unequally distributed across the populations in European countries. Such avoidable inequities are now likely to grow in the context of the COVID-19 crisis; a more substantial and ambitious focus and investments in children and their living conditions is urgently needed. The European Pillar of Social Rights (EPSR), its implementation Action Plan, and this Child Right’s Strategy are therefore key vehicles to ensuring the rights of the child to health, freedom from poverty and inequality. For that, data and surveillance systems need to be put in place, so as the governance mechanisms for collaboration, systematic impact assessment of policy and funds' on child rights and child protection outcomes across a comprehensive set of dimensions, including health promotion and disease prevention, health risk factors and health inequalities.

EuroHealthNet recommends the EU’s Strategy on the Rights of the Child to address the following issues:

  • A focus on reducing child poverty (25% of the EU’s children) and health inequalities
  • Ensuring environments that encourage and easily enable children and adolescents to adopt healthy
  • lifestyles and behaviours
  • Tackling persistent inequalities in childhood vaccination and immunisation
  • Improving the collection of disaggregated data on child health, well-being and social inclusion to help
  • monitor and assess progress towards reducing child health inequalities, child poverty and vulnerability

EuroHealthNet Contribution towards the Roadmap for the EU Strategic Framework on Health and Safety at Work (2021-2027)

EuroHealthNet, in the name of The EU Mental Health Alliance for Work and Employment, welcomes the European Commission’s proposal for the new EU Strategic Framework on Health and Safety at Work (OHS) (2021-2027) as a necessary step in improving the working conditions across the EU.

While we understand that this Roadmap is a first step of a broader consultation, we regret seeing no reference made to psychosocial factors behind work-related illnesses. Mental health of workers across different categories requires protection especially in realities of the changing world of work (e.g. platform workers, gig economy). Good mental health and wellbeing at work is fundamental to ensure quality of life for every worker – and their family – as well as positive economic outcomes for society as a whole.

The following recommendations were given to the new EU OSH Framework:

  1. Steer Member States to address mental health and psychosocial risks in their national OSH strategies, including adequate resource allocation for preventative actions with specific focus on the high risk groups
  2. Lay out an explicit role for the EU Steering Group on Health Promotion and Disease Prevention to offer additional support towards ensuring high protection of mental health due to the changing nature of work
  3. Embed the new EU OHS Framework into the rights-based approach (guided by the Action Plan for the implementation of the EPSR) to reforms of national occupational health policies with the support from the Recovery and Resilience plans
  4. Include occupational psychosocial health and safety indicators in the Social Scoreboard
  5. Promote a more integrated approach to address occupational mental health challenges through various sectors, services and settings, including community-based
  6. Encourage trade unions and employers to increase their efforts and understanding of mental health and workplace links to prevent and provide people with mental health problems with the right support to enter or remain in employment
  7. Support European companies addressing psychosocial risks in their operational guidelines
  8. Support addressing psychosocial risks in collective bargaining and in debates on ethics in digital transition and artificial intelligence
  9. Explore options to further elaborate on the introduction of relevant legal instruments (e.g. EU Directive) on addressing psychosocial risks at workplaces

Read the full response here.

EuroHealthNet contribution to the draft opinion on the Organisation of Resilient Health and Social Care following the COVID-19 Pandemic

EuroHealthNet notes the draft EXPH opinion on the Organisation of resilient health and social care following the COVID-19 pandemic in the context of the Terms of Reference (ToR) and presents its reaction to it. Overall, the Draft Opinion is a useful contribution to develop strategic approaches to (re-)organisation and strengthening of resilience of health and social care within the EU region. We expect it will support better positioning of the health promotion and disease prevention within those systems as well, following the COVID-19 syndemic.

We welcome this attempt from the Expert Panel to present a comprehensive framework that underpins the opinion, accompanied with potential indicators and buildings blocks. While social care is explicitly mentioned in the opinion, we would like to broaden its strategic focus onto education, social protection, employment or housing. These sectors can also play supportive and integrative roles in delivery of health and social care in modern public policy systems.

Several important points should be addressed and further strengthened in the Opinion. Recommendations given by EuroHealthNet include: 

  • Adaptive surge capacity and resilience of local health workforce 
  • Research and development for innovative medicines 
  • Tackling disinformation 
  • Linking databases across systems and sectors 
  • Investments in primary care and mental health and strengthen the integration of these systems 
  • Equity-driven decision-making 
  • Health promotion, lifestyle programs and inter-sectoral collaborative actions 
  • Training focusing on vulnerable groups 
  • Resilience test toolkit and implementation methodology 
  • Creation of learning communities 


The feedback in full can be found here.

EuroHealthNet Contribution to EU Strategy on the Rights of Persons with Disabilities 2021-2030

EuroHealthNet welcomes the European Commission’s plans to develop the EU Strategy on the Rights of Persons with Disabilities for 2021-2030, as a contributing enabling framework for public health actors to address disability-linked health and social inequalities. The strategy also offers opportunities to strengthen the imminent Action Plan for implementation of the European Pillar of Social Rights, the EU’s contribution to the UN Agenda 2030, the EU Green, Skills and Digital agendas.

Plans for the post-pandemic recovery and resilience of health and social care systems in Europe should fully include the rights of people with disabilities. This can be linked with the EU investments and technical support within the EU Recovery and Resilience Facility, the European Semester process, and plans for the European Health Union in the making. Furthermore, considering the recent speed of transition and transformation of the delivery of health and care towards one that’s increasingly digital and commercial, we urge stepping up investments in digital and health literacy, skills and competences needed for healthy lives.


The feedback in full can be found here.

EUROHEALTHNET PROVIDES FEEDBACK TO THE EC on The Child Guarantee Targeted Consultations Questionnaire

EuroHealthNet replied to a questionnaire on the Child Guarantee Targeted Consultations. Following up to its Communication “A Strong Social Europe for Just Transitions”, the Commission will adopt a proposal for a Council Recommendation on a Child Guarantee in 2021. This survey provided the opportunity for feedback on what actions should be taken at EU level through the Child Guarantee, to ensure that Member States provide access for children in need to the services that are essential for their development and well-being, in particular early childhood education and care (ECEC), health care, education, nutrition, housing and participation in cultural and leisure. 

Throughout its reply EuroHealthNet highlighted that it welcomes the EU's reinforced measures to improve basic services for children through the Child Guarantee, as the need for this is stronger than ever. Moreover, the suggestions submitted to the European Commission's open consultation on the Roadmap for Basic Services for Children in Need - European Child Guarantee were reiterated.

Specific elements that were highlighted included barriers that need to be overcome to ensure that children in need get adequate access to the above-mentioned services, such as access to public green spaces and active mobility options,  advertising and marketing of unhealthy diets as well as skills and competences in digital literacy including infrastructure and equipment. It was also suggested that action in the area of education should be improved by providing free/subsidised non-stigmatising meal schemes in educational settings health screenings including mental health, cognitive/linguistic and social wellbeing. In the area of health, action should be enlarged by including  mental health support services to children and their parents/caregivers. 


The feedback in full can be found here.


EuroHealthNet drew on its recent H2020 INHERIT initiative to provide feedback on the Zero Pollution action plan. We welcomed the Commission’s recognition of the inextricable links between a healthy planet and healthy people, and of the fact that “pollution often affects the most vulnerable people most seriously”, and agreed with the need for binding health and environmental standards, to ensure that the public and private sector implement EU rules on air, water and soil pollution. We were pleased to see the inclusion of the much-needed polluter pays principle, and noted that legislation should aim to ensure a just transition, in which those who are more vulnerable are not disproportionately harmed by new measures. Shifting to intersectoral governance will ensure that all potential impacts of legislative initiatives are considered; not just environmental but also health and social (equity) impacts. 

EuroHealthNet also noted that in order to successfully achieve the zero pollution ambitions, it is critical that citizens are enabled and encouraged to make sustainable changes through effective policies, which identify barriers and build a social and physical environment that facilitates these changes. We also know that people can be motivated to take action through concern for their health. Providing more information on how pollution is affecting health – including through citizen science approaches – can be a powerful lever for change. INHERIT research demonstrated that involving all communities in policies that affect them helps to ensure policies address real needs, is empowering and gives them a vested interest in their success. The feedback urges the Commission to encourage such approaches, in particular initiatives that involve citizens and communities who are most affected by pollution and the green transition, and whose voices are not always heard in public debates. 

Finally, EuroHealthNet also suggested a focus away from economic growth, and towards a regenerative and redistributive economy of “wellbeing”, which is good for people and good for the planet. We highlighted Kate Raworth’s Doughnut Economy as an essential model in this respect, which the Commission could use to further build on the Finnish Presidency’s Council Conclusions on the Economy of Wellbeing.

The feedback in full can be found here.

EC’s consultation on the Basic Services for Children in Need - European Child Guarantee (Roadmap)

EuroHealthNet welcomes the EU's reinforced measures to improve basic services for children through the Child Guarantee. The need for this is stronger than ever. A quarter of children in the EU are born and grow up at risk of poverty and social exclusion, with big implications for the life-course of these children and their ability to contribute to society.  The negative secondary effects of COVID-19 are affecting children and families that are already vulnerable, most. 

Specifically, but not exhaustively, we would like to suggest that a proposed Council Recommendation on a EU Child Guarantee address the following issues:

  • Improve links between the 2013 Council Recommendation for Investing in Children (wider policy framework) and the current proposal for EU Child Guarantee. 
  • Ensure that the recommendations in the progress report on the implementation of the 2017 Recommendation for Investing in children are being implemented. These called for e.g., the need to focus on children and families at high risk, which can be very hard to reach, and for a more comprehensive, multi-dimensional and coordinated approach to investing in children. 
  • Most EU states make healthcare services for children free of charge, but the definition of ‘free’ differs greatly with e.g., pre-payments constituting a real barrier for free care. Although unmet medical and dental needs among children are relatively low, current approaches to identify this may not reflect real need and regional and income-related differences are substantial. Poor children in Belgium are 5 times more likely not to access dental care they need than their wealthier peers. Access to mental health care for children in many EU states is suboptimal as well.
  • Like other medical interventions, access to health promoting and preventative measures like childhood vaccination and immunisation are subject to a social gradient. A recent drop in measles immunisation rates in rich-economies is most likely to have occurred amongst vulnerable families, as factors like income, maternal education, place of residence, the sex of the child, and poverty are all linked to access to levels of vaccination coverage (UNICEF data). Those further down the socio-economic gradient may also be less likely to access mental health services or positive parenting programmes, which studies have identified as effective to reduce inequalities in childhood (DRIVERS project).
  • Taking a multidimensional, coordinated approach to investing in children also means ensuring that children facing vulnerability can live, learn and play in environments that promote their health. It means that they can breathe clean air (indoors, outdoors), have access to green and safe public spaces that support physical and mental health and that these environments are not obesogenic. 
  • Cost can be a key factor inhibiting families on low incomes from enjoying healthy diets. Fiscal measures as well as targeted interventions are needed to ensure families have access to foods that promote rather than undermine health. Education settings should also be involved in ensuring this, as well as other approaches to improve the health and wellbeing of children in need, as health and educational attainment are inextricably linked. Such support must be provided in non-stigmatising ways. 
  • Efforts to address gaps in educational attainment must also focus on the digital divide. The pandemic has clearly reflected the inequitable access to devices and in skills.   
  • Finally, there is a real need to improve and harmonise the collection of disaggregated data on child health, wellbeing and social inclusion to help monitor, compare and assess progress towards reducing child health inequalities, child poverty and vulnerability. EU states should also identify and learn from the most effective, evidence-based approaches across the EU, to apply resources better.

Our response complements our input to a joint response by the EU Alliance for Investing in Children.

EuroHealthNet provides feedback to the EC on the Horizon Europe First Strategic Plan 2021-2024

EuroHealthNet continues to help shape the next EU Research & Innovation programme, Horizon Europe, through replying to a survey on the first Horizon Europe Strategic Plan. This plan will define the strategic orientations for the Commission’s research and innovation investments over the period 2021-2024 and aims to act as a compass to stay on course with its political priorities: a climate-neutral and green Europe, fit for the digital age, where the economy works for the people.

The survey provided the opportunity for feedback on the expected impacts to be targeted by research and innovation within Horizon Europe and the contribution of Research and Innovation (R&I) investments to the EU’s political priorities. Throughout its reply, EuroHealthNet highlighted the importance of jointly considering health, equity and the environment, building on its Horizon 2020 research initiative INHERIT, as well as of ensuring that health promotion and reducing inequalities are important elements of research priorities.

Specific elements that were highlighted include the fact that "behavioural transformations" need to be encouraged through wider enabling conditions for a fair transition, and with a solid understanding of the underlying socioeconomic determinants, and that research funding for health should not just support biomedical sciences, but also prioritise research that focuses on a psycho-social model of health, helping to generate specialist knowledge able to embrace the social determinants of health inequalities and place people at the centre.

The response in full can be found here.

EuroHealthNet provides feedback to the EC proposal on Empowering the consumer for the green transition

In its feedback, EuroHealthNet highlighted that the green transition is an area in which we need to strive for and can deliver a “triple-win”, promoting not just environmental sustainability but also health and health equity. It is crucial that all stakeholders are involved in this transition, including policymakers and the private sector, but also citizens, given that individual (un)sustainable behaviours impact not only the health of our planet, but also our own health. 

EuroHealthNet drew attention to the crucial role that policymakers should play to support people’s capability to make positive changes, by providing clear scientifically sound guidelines at EU level and mandatory standardised EU-wide labelling on food products, which highlights health, social and environmental sustainability aspects. Information must be easy to understand and apply by all; the more complex the information the harder it is for the general population to act on. Given that information and misinformation is increasingly transmitted digitally, this also calls for investments in improving digital literacy. Sustainable and healthy food, as well as other products and services, needs to be affordable, as cost is a key factor driving consumer behaviour, and this can increase health inequalities.

“Business as usual” is not an option, and EuroHealthNet highlighted the urgent need to enforce existing and amended legislations, rather than relying on self-regulation. Policymakers have a duty to facilitate the efforts of front-runner businesses, and to hold accountable those that harm the environment and public health.

Read the full response to the proposal here.

EuroHealthNet responds to consulation on the EU Strategy on the Rights of the Child (2021 - 24)

The EU strategy on children’s rights (2021 - 24) will provide the framework for EU action to better promote and protect children’s rights. It will contain a set of measures for the EU to implement, addressing among others (1) the rights of the most vulnerable children; (2) children’s rights in the digital age the prevention of and fight against violence; and (3) the promotion of child-friendly justice. It will also include recommendations for action by other EU institutions, EU countries and stakeholders.

Ensuring children's right to the highest attainable standard of health and to a adequate standard of living is not only in line with our European values, it is essential for strong societal foundations. There is a myriad of data on how the ‘First 1,000 days’ are a critical period for health and cognitive progress, while problems in early life are compounded across the life-course. The EU Strategy on the Rights of the Child is therefore integral to all of the EU’s political priorities of guidelines, and in line with efforts to meet the UN 2030 Agenda and the SDGs. EU-funded research projects coordinated by EuroHealthNet (GRADIENT, 2010-2013 & DRIVERS, 2011-2014) highlighted that for every step down the socio-economic ladder (social gradient), children and young people all across Europe experience a higher level of physical and mental health problems that will affect their future health and life opportunities. This reflects how not all children and adolescents have equal access to the opportunities to lead healthy, happy and prosperous lives. Such avoidable inequities are likely to grow in the context of the COVID-19 crisis; a more substantial and ambitious focus and investments in children and their living conditions is urgently needed. Our research projects showed that improving in particular mothers’ educational levels and employment status, as well as targeted programmes offering intensive support to develop parenting skills have led to the best outcomes for children.

Find our full response to the consultation here.

Find our video on the importance of the first 1000 days of life here

EuroHealthNet responds to consultation on the future of the European Research Area

The European Research Area (ERA) was set up to boost EU coordination and competitiveness in medical, environmental and other types of research. This initiative consists of a communication relaunching and revitalising the ERA in order to (1) make it future-proof; (2) make it better able to address the major challenges of the digital and green transition; and (3) increase Europe’s resilience following the Covid-19 crisis.

The ERA 2015-2020 Roadmap raised the importance of “jointly addressing grand challenges.” The gravity of these challenges, like climate change and the COVID-19 pandemic, the risk of digital divides and growing levels of socio-economic - and closely related - health inequalities have in recent years and months become all the more apparent. The EU must act as a role model globally of how democratic societies can work together to overcome these challenges and achieve ecological, social and economic transition; this hinges on bringing together Europe’s best researchers to design, develop and test new approaches. EuroHealthNet strongly supports efforts to bolster progress towards an ERA that helps meet those needs. COVID-19 has demonstrated all too clearly the central role that public health plays in our societies, and of how economic growth depends on good health and wellbeing. The ERA should therefore also include and coordinate research in the area of public health, prevention and health promotion as a crucial factor in and indicator of the effectiveness of measures to transition to more sustainable and inclusive societies.

Read our full response here.

EuroHealthNet responds to the draft WHO European Programme of Work 2020-2025

EuroHealthNet has responded to the draft WHO European Programme of Work 2020-2025 - United action for better health in Europe. EuroHealthNet welcomes the draft WHO European Programme of Work (EPW) 2020-2025, which identifies the main need, the main health sector situations and responses, and some channels which can be enhanced in the WHO context if taken up. It offers an accurate description of both the needs and challenges of advancing the joint commitment to work together to identify and tackle key barriers and seize new opportunities in health, adopt new ways of working, build on existing successful collaborations, and jointly align support around countries’ national health plans and strategies to help “unite for better health in Europe”. EuroHealthNet members (national public health agencies, regional health authorities and centres of excellence) should be at the heart of that and it needs to reach wider audiences.

In the response, EuroHealthNet has highlighted the need to strengthen health promotion, to invest in the social side of health crisis preparedness, and to work better together toward ambitious outcomes by 2025. Read our full response here

EuroHealthNet responds to consultation on the European Strategy for Data

EuroHealthNet has responded to a consultation for the EU Strategy for Data, which aims to create a single secure European data space. The strategy should make it easier for businesses and public authorities to access an access data to boost growth and create value, while reducing the EU economy’s footprint. Among other things, EuroHealthNet emphasised the need to improve digital literacy to help people manage their data, and for standardisation of data to avoid exacerbating inequalities and to avoid discrimination. It also highlighted the potential of data altruism to improve outreach to vulnerable and isolated communities, and advised against making datasets with sensitive health and social data freely available.

EuroHealthNet provides feedback on European Climate Pact

The European Climate Pact is one of the initiatives launched by the Commission in March 2020 as part of the European Green Deal. It aims to engage citizens and communities at local, regional and national level in the transition to climate-neutrality, including civil society, research organisations, educational institutions, the private sector, consumer groups and individuals. Concretely, the Climate Pact will seek to build on existing initiatives, and encourage societal engagement through three main activity strands: talking about climate change; triggering action; and working together.

EuroHealthNet provided input into the public consultation, helping to shape the final version of the Pact (which is non-legislative). This served for instance to highlight the kinds and sources of information which would be most useful to help trigger action and raise awareness on climate change. Currently, the Commission proposes to focus the Pact on three areas: energy efficiency, low-carbon mobility, and planting trees/green urban areas. Whilst underlining the importance of each of these activities, EuroHealthNet also drew attention to the fact that climate, health and inequalities are strongly interlinked. It indicated its willingness to provide targeted support to foster actions aimed at addressing climate change and environmental degradation, whilst improving health and reducing health inequalities, building on the learnings of the Horizon 2020 INHERIT initiative.

EuroHealthNet responds to EU Tobacco Products Directive Survey

This survey aimed to examine the practical application of Directive 2014/40/EU and its specific provisions, which strengthened existing rules on how tobacco products are manufactured, produced and presented in the EU, and introduced new rules for certain tobacco-related products. The study will assess the level of implementation of the TPD by exploring both achievements and hindering factors.

Despite progress made, the number of smokers in the EU is still high – 26% of the overall population and 29% of young Europeans aged 15-24 smoke. Rates of smoking among (young) females have not been falling urgently as needed, with an increase in occasional smoking and uptake of novel tobacco products consumption. As 56% of smokers start before the age of 18 and 93% before the age of 25, it is essential to prevent young people from taking up tobacco use. TPD has changed EU tobacco control to a significant extent, but there is room for improvement, notably in the area of plain packaging, novel tobacco products and e-cigarettes and their taxation, in particular for the new generation of smokers (young people, females). The EU has legal competences to ensure a high level of public health in the EU internal market, including placement, presentation, content and pricing of tobacco and novel products. Considering levels of cross border trade in tobacco and related products (and novel products most recently) and diverging national legislation (e.g. on smoke-free public spaces), EU-wide rules protecting consumers’ rights and health are increasingly necessary. Achieving TPD’s objective of ensuring a high level of protection of human health, especially for young people, has been undermined by inconsistencies across the applicable legislative acts exploited by tobacco and related industries, in particular by aggressive commercial tactics for new products and stagnation of price increases. Increases in e-cigarette use are widely predicted as availability and publicity multiply, especially in new users; it is necessary to adequately address novel products through regulation and taxation alongside conventional tobacco products. Given the frequent presentation of such products as a ‘healthier’ or ‘safer’ alternative to traditional tobacco products, we strongly urge caution in their active promotion. Until more evidence for the safety of e-cigarettes is presented through rigorous independent reviews, it is prudent to consider them as a potentially harmful and addictive products, to be regulated and taxed in an equivalent manner to conventional cigarettes. Reducing tobacco use among existing consumers and preventing take up by young people are important objectives towards a tobacco-free Europe. Tobacco cessation services which include qualified clinician-led, -monitored and -evaluated use of novel products have a limited place in such strategies, as do improved health literacy and health education as part of wider health promotion approaches. However, insufficiently regulated open markets in this respect are potentially harmful, not least in perpetuating sustainability of multinational.

Read our full response here

EuroHealthNet responds to consultation on Europe's Beating Cancer Plan

Every year, 3.5 million people in the EU are diagnosed with cancer, and 1.3 million die from it. Over 40% of cancer cases are preventable. Without reversing current trends, it could become the leading cause of death in the EU. European Commission has launched a public consultation on Europe’s Beating Cancer Plan, aimed to reduce the cancer burden for patients, their families and health systems. It will address cancer related inequalities between and within Member States with actions to support, coordinate and complement Member States’ efforts.

EuroHealthNet has contributed to the consultation by strongly focusing on health equity dimension of preventing cancers by addressing risk factors, early diagnosis and treatment, quality of life, and social reintegration post-disease. While welcoming the prevention pillar of the Plan, we cautioned against a downstream “lifestyle drift” for disease prevention approaches and shifting the burden on individuals, without integration of the “cause of the causes” - the structural and underlying causes of ill health and disease.

EuroHealthNet provides feedback on the European Climate Law

EuroHealthNet welcomes the European Green Deal and proposed European Climate Law in principle as crucial steps towards ensuring a transition to a more sustainable future. We particularly welcome the Commission’s emphasis on the need for the transition to be “just and socially fair”, and its acknowledgement of the impact of the climate crisis on wellbeing.

EuroHealthNet used the opportunity for feedback to highlight the strong links between the environment, health, and inequalities, and urged the Commission to take these links into account in all aspects of the proposed climate law, building environmental policy whilst looking through health and equity lenses. The INHERIT initiative, which EuroHealthNet coordinated, provides tools and recommendations on how to jointly consider opportunities for a “triple-win” between the environment, health and equity. Drawing on this, we recommend that the studies and assessments foreseen in the climate law take into account inequalities and the distributional impacts of policies or interventions on people across socio-economic gradients. Whilst recognising that EU Institutions have limited competencies to ensure Member States’ compliance with the law, we also wonder if stronger measures could not be included that lie within the scope of their powers to hold EU Member States accountable. Measures that encourage and enable Member States to monitor implementation as well as effects on health and distributional effects, and benchmarking of Member States performance will in this respect be crucial.

The COVID-19 pandemic has demonstrated the perils of not addressing the grave challenges we face in relation to the environment, health and social inequities, and of not addressing these issues in integrated ways. The need to mitigate the economic damage resulting from the pandemic provides an opportunity to do so now, in more systematic ways, and to build an economy fit for the 21st century.

EU Farm to Fork Strategy

EuroHealthNet welcomes the EC’s commitment to develop a Farm to Fork Strategy for sustainable food systems. We strongly support a comprehensive, ambitious and truly transformative transition to European food systems that put people and planetary health, sustainability and social equity at the centre. In a framework of the European Green Deal, this strategy offers an important opportunity to design and deliver a coherent response to current - and future, if business as usual prevails - health, social and environmental challenges related to unsustainable food production and consumption patterns.

Unhealthy diets – major contributor to a NCDs pandemic - are already responsible for over 950,000 deaths and 16 million DALYs lost in the EU (the 2017 Global Burden of Disease). Today's food systems are perpetuating and driving up health inequalities - which is conspicuously missing from this proposed strategic thinking. There is an abundance of evidence to show that sedentary and unhealthy lifestyles of people are heavily influenced by their social, economic, and environmental circumstances and cultural contexts. Therefore, a pivotal role for a modern, fit-for-purpose strategy will be in creating food environments where “a healthy choice is an easy choice” for all. EuroHealthNet counsels against disproportionate focus on ‘downstream’, ‘personalised’ lifestyle-oriented measures (information, education) without real appreciation of the underlying causes of ill-health and disease, the social determinants. They are part of a solution, but not enough to drive the transformative changes needed.

Please find our full response here.

Click here to read our Policy Precis on how Europe's food systems need to change to protect health, increase equality and protect the environment

EuroHealthNet gives feedback to the European Commission’s Roadmap “2020 Strategic Foresight Report"

EuroHealthNet provided feedback on the EC Strategic Foresight exercise, whcih aimed to identify strategic areas where “policy, research and technological developments are most likely to drive societal, economic and environmental change”. Being part of a larger ongoing exercise in the European Union, it’s aim was to help refocus the EU and support its Member States’ efforts towards “future-proofing our policies” to promote more effective response to emerging challenges and opportunities, better linking policies in different areas so they work towards common long-term objectives and re-engage with citizens on Europe’s future. EuroHealthNet welcomed the opportunity to provide input to the Commission’s strategic thinking by responding to the Roadmap on the subject. Anticipating a severe economic and social recession caused by the COVID-19 pandemic, EuroHealthNet advocated for prominent roles for health promotion, disease prevention and decreasing health inequalities in the EU's response.

Read our full response here.

Roadmap Consultation EU Cancer Plan

EuroHealthNet responded to the Roadmap on the EU Consultation on the EU Cancer Plan. We welcome the European Commission’s prioritisation of, and plans to implement, Europe’s Beating Cancer Plan. To be successful, however, ambitious commitment must be to urgently address the large scale of social and economic inequalities in cancer-related health outcomes and in population-wide opportunities for prevention.

Disadvantaged groups in all EU countries and in different regions in Europe are at a higher risk from most of the ‘common’ cancers due to a combination of higher exposure to risk factors, poorer access to cancer preventive measures and health services in general, and less capacity to deal with the social, employment, and financial consequences of the disease. Further disparities may occur in terms of informal care and peer-support required, return to work arrangements or need for long-term care.


Please find the full response to the consultation here.

Future mandates/questions for the Expert Panel on effective ways of investing in health

EuroHealthNet has responded to a consultation on the future work of the European expert panel on investing in health.

We asked them to consider:

  • How the sustainable development and green agenda can support health systems
  • How the EU can use its competencies environmental, digital, commercial and fiscal areas to improve health and health equity?
  • How the European Pillar of Social Rights can be used to improve health

Response to the draft WHO European Roadmap for implementation of health literacy initiatives through the life course

Overall EuroHealthNet welcomes the Roadmap for the implementation of health liteacy initiatives through the life course. It is a good summary for the specific purposes of the concept, which needs to be established by the Regional Committee of WHO and taken forward seriously. It identifies the main need, the main health sector situations and responses, and some channels which can be enhanced in the WHO context if taken up. It is good to see that strategic approaches are being developed. EuroHealthNet members should be at the heart of that and it needs to reach wider audience. While the initiatives are relevant and reasonable, several concerns about omissions have to be addressed. In terms of the third question about omissions, we have the following concerns.

Value-based healthcare and Task shifting in Healthcare: EuroHealthNet contribution following Expert panel on investing in health hearings

Task-shifting in healthcare systems:

EuroHealthNet welcomes the draft opinion prepared by the Expert Panel on this important issue. The actions recommended are reasonable, given the very limited evidence available which is “much less than desirable” so far. Therefore, EuroHealthNet calls for further evidence, including health equity impact assessments and learning from other sectors, to be gathered with urgency in relevant and comparable settings and models, including via EU research, health, ESIF and other programmes.

It is essential for us to see a strong focus on ensuring task shifting in healthcare strengthens, not undermines, principles of equity and quality. We agree that task shifting should not be viewed in isolation but in the wider context. This means not only within health systems as narrowly defined, but in terms of whole systems towards wellbeing, particularly as established in the integrated goals of UN Agenda 2030 and the SDGs, which we are surprised is beyond the scope of this draft opinion but should be included.

Health and well-being is a product of co-creation by various sectors and ownership levels. Therefore, shifts to new ways of working have multiple societal and governance impacts. Community workers are mentioned, but in terms of “requiring better integration into health and care systems”. In the real world, the opposite might offer better returns: health professions need to be better integrated within wider public health workforces and systems, including public, private and voluntary sectors.

While traditionally the emphasis has been on tasks related to delivery of medical care, it is also other tasks that can be shifted: responsibility for organisation or financing of specific types of care (including health promotion or social care ‘prescribing’), central government to regional authorities or municipalities, public and private insurance tasks. Beyond changing roles of health professionals, changing roles of patients and healthy populations should be considered.

The draft acknowledges that evidence is weak again on patient/carer/public “self-management of chronic conditions” We call on the Panel to consider learning from the CHRODIS Plus[1], Joint Action Health Equity Europe[2] and other relevant EU Joint Actions in these respects, where role shifts need to be integrated.

It is notable that health literacy and - increasingly more importantly – digital health literacy is barely mentioned, but that needs to be pivotal, both for the public, and for training of all relevant professionals.

Value-based Healthcare

The Opinion clearly states that the final goal of European healthcare systems should be achieving universal access, with particular attention to vulnerable (patient) groups. As such, EuroHealthNet certainly shares much of the vision and messages described in the document.

On the other hand, it is important to underline that the document focuses on access to treatments and medicines, and with little or no attention to public health or broader social policies.

This implies that the proposed definition of value-based healthcare is (mainly) meant to support the reform of the way healthcare systems provide care and treatment, and very little for improving prevention policies or policies aimed at improving the social determinants of health. The document could give more attention to social determinants of health, health promotion and prevention. Also, the scope should not be limited to just patients, but addressing more the whole population.




Feedback on the European Partnership for innovative health (Horizon Europe programme)

EuroHealthNet is a European Partnership that aims to improve health, equity and wellbeing through action on the social determinants of health and health inequalities, disease prevention and health promotion. It is therefore a reference to these aspects of public health that we miss in the “Description of the problem the initiative aims to tackle”.

This initiative aims to provide a collaborative platform for pre-competitive research and innovation where small and big companies can join forces with researchers, patients, healthcare professionals and regulators. This cooperation with partners specialised in e.g. pharmaceuticals, diagnostics, medical devices, imaging or from the biotech and digital industries will help speed up the development and uptake of innovation in public health.

While it is true that the EU must deal with an ageing population and an increasing burden of disease, it is also highly important that a problem of health inequalities within and between EU Member States is addressed and prevented. By considering equity and social fairness, innovative health interventions can make a significant contribution to addressing the challenges identified in the proposal. If left unchecked, the transformative potential of digitalisation or innovations in the field of health may remain inaccessible or too costly to benefit all population groups. Better digital health literacy, broader R&I understanding of the structural causes of disease and paths that lead to better health and wellbeing, the continuum of care and life-course approach may offer a much needed change of R&I narrative. Preventative, people-centered and integrated care, addressing key determinants of health, should always constitute an integral part of the European Partnership on Innovative Health.

Health inequalities reduce economic and social productivity and lead to higher healthcare and welfare costs, a point we recommend recognising in the “Expected economic and social impacts” in part C. Evidence shows that in the EU, inequalities in health are estimated to cost €980 billion per year, or 9.4% of European GDP. A 50% reduction of gaps in life expectancy would provide monetised benefits to countries ranging from 0.3% to 4.3% of GDP. Furthermore, for every 1 EUR spent on health promotion, on average, 14 EUR is returned to the economy. Action on health inequalities and the promotion of health-enhancing environments in which people are born, live, work and age represent a good return on investment, can unlock untapped sustainable growth potential, and have strong public support.

The Horizon Europe programme, a basis of the proposed European Partnership, acknowledges that the health challenges faced by the EU cannot be addressed by health systems alone and that they are fundamentally interlinked, global in nature and require multidisciplinary, cross-sectoral and transnational collaboration. Yet, a “health in all policies” principle (Art. 168 TFEU) is clearly lacking from the legal basis of the Partnership proposal, as well as from its expected contribution towards the implementation of the UN SDGs Agenda.

Finally, since the Partnership would include support to public-private collaborations, it should address issues of privatisation, ethics, and commodification of health research results, services and products – potentially undermining efforts towards the Health for All and contributing to widening health inequalities in the EU and globally. Establishing good governance and transparency, cohesion and coordination needs careful consideration. It is essential to ensure a balanced approach towards use of public funds to address issues that concern the public, respond to wider societal needs, and promote scientific collaboration beyond 'traditional' top-down disease-oriented R&I. True partnership for innovative health would mean being non-exclusive of cross-sector and smaller public health stakeholders both at EU and Member State level.

Evaluation of the support to promoting social inclusion, combatting poverty and any discrimination by the European Social Fund.

The European Social Fund (ESF) is the European Union’s main instrument available in EU countries for promoting social inclusion, combating poverty and any discrimination. This public consultation was an integral part of the evaluation of ESF support to promote social inclusion, combat poverty and any discrimination. It seeked feedback from all stakeholders of the ESF in the EU countries, as well as from the wider public.

In our response to this consultation, EuroHealthNet stressed that, although the European Social Fund has played an important role in fostering employability across the EU, persistent disparities within and between countries/regions and certain groups, as well as high and rising in-work poverty rates suggest that the EU policy actions on employment need to be reviewed. Single focus on fragmented labour market policies and skills development are not enough to stabilise work and life conditions for all. To build a productive and resilient society, capable to adapt and withstand economic fluctuations, the ESF should be rooted in holistic approaches that integrate employment with other social inclusion policies, ensuring that no vulnerable groups are left behind. (Un) employment initiatives that reach out towards health and social protection services with an aim to improve health and well-being of people, give them equal opportunities to contribute to a society life-long are good investments.


Response to orientations towards the first Strategic Plan for Horizon Europe

With a proposed budget of 100 billion Euro from 2021 to 2027, the Horizon Europe framework programme represents the largest collaborative research and innovation investment in the world and is open to participants worldwide. EuroHealthNet responded to a consultation for the Horizon Europe framework that focused on questions that had not been addressed in earlier consultations. 

An interconnected character of the Horizon Europe (HE) targeted impacts, bringing in more coherence to the overall impact of the programme is welcome. Overall, ‘European Green Deal’, ‘Economy that works for people’, and ‘Europe fit for the digital age’ priorities will be most likely reached through HE investments. From a public health perspective, environments in which we live are key determinants of health and wellbeing, subject to differential and often unfair distribution in populations. R&I should be able to ensure that the transition to greater sustainability is feasible for all and socially fair.


Response to the draft opinion on Options to Foster Health Promoting Health Systems by the EU Expert Panel on Effective Ways of Investing in Health (EXPH)

EuroHealthNet responded to the draft opinion on Options to Foster Health Promoting  Health Systems by the EU Expert Panel on Effective Ways of Investing in Health (EXPH). In EuroHealthNet's opinion, the Draft Opinion is a useful contribution to develop strategic approaches to implementing health promotion within the EU region and strengthening the integration of health promotion within health systems. Recognising that health promotion is an essential strategic approach for addressing health inequalities and wider systemic determinants of physical and mental health is a fundamental message that should underpin further action on transformation of health, care and wider public systems in Europe. 

However, we suggest that the Opinion should clarify the responsibilities and accountabilities of the EU and Member States, and to set out potential measures in terms of time frame. EurohealthNet also suggests that several important points should be addressed to strengthen the opinion:

  • The need for a clearer definition or clarification of what is meant by health promoting systems.
  • Include a stronger focus on digital transformation and digital health.
  • Consider the underpinning macro-economic perspective in achieving health promoting health systems.
  • The need for timely evidence and impact assessments as part of policymaking cycles across sectors.
  • Ensure capacity building in human resources, institutional structures and processes for health promotion.
  • Highlight the importance of sustained multi-level partnerships for health promotion.
  • Reinforce leadership and coordination at EU-levels.
  • A stronger emphasis on the reorientation of a medical model of health and addressing the 'lifestyle drift' of health promotion. 

EU Consultation on Horizon Europe Co-design 2021-2024

In EuroHealthNet's opinion, the expected results of the Horizon Europe programme will be truly beneficial and long-lasting only if equity and social fairness are addressed throughout. The programme concerns both the research and innovation area but also the European socioeconomic model at large. Horizon Europe should guarantee that the benefits of furthering evidence and innovation are inclusive and accessible, respond to public needs and advance societal wellbeing.

EC consultation on proposed Digital Europe programme

EuroHealthNet welcomes the initiative to establish the Digital Europe programme to support digital transformation in the EU. Digital technologies offer new opportunities to strengthen – in a balanced way - the public and private sector, and they are crucial to ensure sustainability, growth and equity in the EU. Digital innovation can bring new opportunities to transform health systems, including new approaches to health protection and promotion, treatments and care, accelerated scientific progress for early diagnosis, and prevention of diseases. Importantly, new digital technologies can contribute to reducing inequalities, by lowering costs, expanding coverage and improving access to and quality of public services, such as health, social protection and education.

Read our policy Précis on digital health literacy

Response to the draft Global Action Plan for Healthy Lives and Well-Being for All

EuroHealthNet welcomes the draft Global Action Plan for Healthy Lives and Well-Being for All, which, overall, is a good overview of strategic approaches to strengthening collaboration among multilateral health organisations to accelerate country progress on the health-related SDGs throughout several ‘accelerator’ areas identified. While EuroHealthNet supports strategic approaches and forward-thinking set out throughout the accelerator discussion documents, we believe that important equity-related issues should be addressed and further strengthened in the final Global Action Plan for Healthy Lives and Well-Being for All. In this responsse, we set out how the strategy can better address health inequalities. 

Response to the EC's Public Consultation on Gender Equality

EuroHealthNet responded to the European Commission's Public Consultation on Gender Equality. While progress has been made on gender equality over the last years, the existing gender gap in life expectancy between and within Member States demonstrates an urgent need to address the underlying structural and social factors of gender and health inequalities. Especially women with a low socio-economic status, from disadvantages/socially excluded backgrounds, victims of gender-based violence and migrants require more focused attention in the Commission's efforts to ensure gender equality. 

Response to the draft WHO Global Strategy on Digital Health 2020-2024

EuroHealthNet responded to the WHO Global Strategy on Digital Health 2020-2024.  Overall, it is a good overview of strategic approaches to digital health in-development. It offers an accurate description of both the needs and challenges of adopting digital technologies to improve health from inception to operation. In the context of rapidly-changing environments for health systems and delivery of care, this strategy can serve as a means of promoting equitable, affordable, and universal access to health, as well as fairer opportunities and wellbeing outcomes for all.

While EuroHealthNet supports such strategic approaches and forward-thinking, we believe that important equity-related issues should be addressed and further strengthened in the final Global Strategy on Digital Health 2020-2024. In our response. we set out how the final strategy can do so. 

EuroHealthNet's contribution to the Public Consultation on the Youth Employment Initiative

EuroHealthNet’s contribution focuses on the impact of youth unemployment and exclusion on health outcomes. It highlights the need to address significant societal and economic costs for EU governments through prioritizing long-term life-course investments, such as the EU Youth Employment Initiative. Health inequalities in youth erode the professional development of young generations and their ability to contribute to society, undermine economic growth and prosperity, and increase health, social care and wider public expenditures.

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. To read the response, click here.

On 30 April, the European Commission published a report in which the responses to the consultation were analysed. The report can be found here.

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"