Eurocare: Submission to Europe’s Beating Cancer Plan
February 2020
Eurocare welcomes the European Commission’s initiative on Europe’s Beating Cancer Plan and is hoping it will result in tangible results in terms of decreasing cancer prevalence.
Given Eurocare’s profile, comments will be given to areas in which it possesses expertise, mainly the prevention pillar of the plan. Furthermore, comments are given in relation to EU’s level of action. From the proposed actions European Commission is best positioned to suggest the adequate level of implementation taking into account subsidiarity and proportionality.
As a general comment Eurocare would like to support the European Commission’s remarks regarding too little resources being allocated for prevention efforts (an average of 3% of health budgets). As stated in the document, avoiding known risks and adopting healthy lifestyles can greatly lower people’s risk of getting cancer.
Eurocare agrees that prevention is the easiest and most effective way of reducing cancer in the EU.
As pointed out in the document the Europe Against Cancer plan in the past resulted in EU legislation on tobacco.
Eurocare would strongly advocate that given the burden alcohol places on people’s health and its role as a risk factor for cancer, EU should be ambitious in its actions and introduce alcohol specific legislation. While over the years EU has achieved significant progress on tobacco, it has not placed similar emphasis on alcohol.
There are several areas where divergences exist in Member States not only with regards to the level of knowledge regarding harms caused by alcohol (such as contributory factor for cancer) but also in terms of policies (i.e. commercial communication policies, especially with regards to digital advertising)
EU should show leadership that would consequently also empower Member States to address alcohol related harm and its contribution towards cancer development.
Eurocare acknowledges and understands cultural differences in attitudes towards alcohol consumption in the EU. However, when it comes to cancer prevention cultural viewpoints cannot get in a way of such basic actions as informing people about alcohol being a risk factor for cancer and introduction of measures that would help to reduce its burden.
Eurocare would also like to suggest that Mission on Cancer should consider alcohol specific research in relation to cancer, to better understand the role of alcohol. Available research would benefit from analysis for compounding factors among others.
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Comments in relation to Prevention pillar
Eurocare welcomes the suggestion of the objective ‘prevent the preventable’ and specific mention of alcohol consumption in that setting.
Digital tools are a welcomed development of the recent years but Eurocare would like to point out that prevention efforts can be complemented by digital tools and not primarily dependent on them. Access to digital tools relies heavily on the individual actively engaging with them, making a choice to be informed. This can result in increased disparities among EU’s citizens in terms of knowledge regarding alcohol and cancer.
To date few countries held public awareness raising campaigns about alcohol and cancer, they were rarely state funded; mainly lead by dedicated organisations such as Belgian #TournéeMinérale initiative organised by Cancer organisations (Stichtingtegen Kanker and Fondation contre le Cancer) or Christmas videos by Danish Cancer Society (Kræftens Bekæmpelse). Since 2011 Eurocare together with ECL has hosted www.alcoholandcancer.eu website however due to lack of appropriate funding the website has been stagnant and is in an urgent need of improvement.
Eurocare would suggest allocation of resources into awareness raising efforts to increase citizen’s knowledge about alcohol as a risk factor for cancer. Healthy lifestyle changes can only come to fruition if the public is aware of the risks and has an environment encouraging a lifestyle change.
Eurocare is pleased to see the role of taxation highlighted as potential instrument to reduce alcohol related harm.
Eurocare would like to highlight that although taxation is a Member State competence, there are steps which EU can undertake to show its leadership and set standards. For instance, minimum rates for alcoholic beverages (Directive 92/84/EEC) have not been changed since 1992, with zero rate for wine. Although Member States are free to apply excise duty rates above these minimum, a zero rate for wine does not set a good example.
The document suggests a set of legislative and soft measures, however with regards to alcohol, Eurocare would strongly suggest considering several legislative measures and widening the scope of potential actions beyond taxation, under the umbrella of a comprehensive alcohol directive.
Suggested objectives for alcohol prevention
Firstly, we would strongly recommend for Europe’s Beating Caner plan to include specific measures related to prevention of alcohol-related cancers such as:
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Allocation of funding for campaigns (either national or European) to increase awareness about the connection between alcohol and cancer.
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Gathering information regarding citizens’ knowledge about alcohol and cancer (the latest Eurobarometer asking that question is a decade old).
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Gather information regarding prevalence of alcohol-related cancers in the EU-27, and good practice examples from Member States on methods to increase awareness and reduce prevalence (this could be part of State of Health of the EU review series).
The EU should seek legislative means to enhance the current alcohol policy landscape, this could be achieved through harmonisation of currently diverging policies among Member States in areas such as:
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Commercial communications, especially regarding the digital environment
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Labelling of health-related messages on containers of alcoholic beverages, (among others) informing consumers about the connection between alcohol and cancer.
Eurocare would suggest that Europe’s Beating Cancer plan in area of prevention should built on the work and evidence generated by the WHO. Appendix 3 of the Global Action Plan for the Prevention and Control of NCDs 2013–2020 consists of list of options for policymakers to address main risk factors including alcohol, the so called - best buys. In area of alcohol prevention, they are:
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Increase excise taxes on alcoholic beverages
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Enact and enforce bans or comprehensive restrictions on exposure to alcohol advertising (across multiple types of media)
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Enact and enforce restrictions on the physical availability of retailed alcohol (via reduced hours of sale)
Considering the EU’s competences Europe’s Beating Cancer plan could contribute to achievement of ‘best buys’ by Member States by:
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Putting forward a proposal addressing the EU excise duty arrangements for travellers’ purchases of alcohol and tobacco
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Putting forward a proposal allowing Member States to levy excise duties based on alcohol content on all categories of alcoholic beverages (not just beer and spirits)
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Ensuring Member States retain the power to enforce national marketing restrictions, also online, on products with links to cancers, such as alcohol and tobacco.
Alcohol and Cancer
Europe is the heaviest drinking region in the world with 9.8 litres of pure alcohol per person (15 + years), well-above the global average of 6.4 litres. Drinking alcohol is associated with a risk of developing more than 200 different types of diseases . Every day in EU+ countries around 800 people die from alcohol attributable causes (291.000 per year).
The main cause of death due to alcohol in 2016 was cancer (29% of alcohol-attributable deaths) .
Volume 96 of the IARC Monographs found there to be ‘sufficient evidence for the carcinogenicity of alcoholic beverages in humans. The occurrence of malignant tumours of the oral cavity, pharynx, larynx, oesophagus and liver is causally related to the consumption of alcoholic beverages.’ Since 1987, connections between alcohol intake and cancer of the breast, colorectum and liver have also been identified. Indeed, the 2010 monograph identified a relative increased risk for breast cancer for which ‘regular consumption of even 18g of alcohol per day the relative risk is significantly increased. ’18g per day is equivalent to just under 2 regular glasses of wine, 1.3 pints of beer or nearly 6cl of whiskey. Likewise, the monographs confirm an increased relative risk in colorectal cancer for regular drinkers of 50g of alcohol per day.
Need for increased awareness
Experts have known since 1987 that alcohol can cause cancer, but the connection between the two is often unknown, or ignored. Research in Europe has shown that 1 in 10 Europeans do not know about the connection, and that 1 in 5 do not believe that there is a connection between cancer and the drinks .
Low levels of public awareness can be found across Europe, latest survey in France has shown that only 23% of respondents identify it as the second risk factor for cancer after smoking .
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The European Union has recognised the need to promote information regarding preventative measures targeted at individuals and public at large. Since 1987 it leads the initiative of European Code Against Cancer, the current fourth edition has a revised message in terms of alcohol consumption:
If you drink alcohol of any type, limit your intake.
Not drinking alcohol is better for cancer prevention.
As stated on the European Code Against Cancer website :
There is no doubt that drinking alcohol can cause at least seven types of cancer: those of the mouth, gullet (oesophagus), throat (pharynx and larynx), liver, large bowel (colon and rectum), and breast.
Consumption of any amount of alcohol increases your cancer risk. The more alcohol you drink, the higher the risk of developing cancer. Reducing your consumption or – even better – avoiding alcohol completely will help reduce your cancer risk.
However, awareness among the public is still low regarding the link between alcohol and cancer. Intensified efforts and resources are needed to ensure that EU’s citizens are fully aware of the risk that alcohol consumption can carry with regards to cancer development.
1. WHO (2018), Global status report on alcohol and health
2. WHO Europe (2019), Status report on alcohol consumption, harm and policy responses in 30 European countries 2019; results of joint WHO-EU project MOPAC
3. Ibid.
4. EU citizen's attitudes towards alcohol, Eurobarometer EUROBAROMETER 72.3. Special Eurobarometer 331
5. Résultats d’un sondage réalisé par Opinion Way pour la Ligue contre le cancer
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