Høringssvar til EU-kommisjonen om irske helseadvarsler

Vi i IOGT i Norge mener helseadvarsler gir nødvendig informasjon til forbrukere om risikoen ved alkoholbruk, og er informasjon som bør være på alle alkoholprodukter - på lik linje med andre produkter som kan innebære helserisiko. Vi ser frem til at slik informasjon også kommer på produktene solgt i Norge!

IOGT Norway’s contribution to the TRIS notification 2022/441/IRL of Draft Regulations under Section 12 of the Public Health Alcohol Act, 2018

IOGT Norway would like to provide our comments to the TRIS notification 2022/441/IRL of Draft Regulations Under Section 12 of the Public Health (Alcohol) Act 2018. 

IOGT Norway is an NGO committed to better prevention and rehabilitation from alcohol and drug in Norway. We are funded through member contribution and project grants from public funding, e.g Norwegian directorate for health.  

The population in general, and particularly consumers, have the right to know about the potential harm from consuming alcohol to be able to take an informed choice. This is not the case today, as the knowledge about the health risk from consuming alcohol is very low – both in Europe seen in total, and also the case in Ireland and for Norway, where we are based.  

Alcohol causes seven types of cancer (mouth, upper throat, larynx, oesophageal, breast, bowel, and liver) and there’s no safe lower limit. The European Code against Cancer therefore states that “If you drink alcohol of any type, limit your intake. Not drinking alcohol is better for cancer prevention.” 

We would like to express our support to the initiative from the Irish government, as this would be a policy that would contribute to providing better information to consumers and population in general. Similar initiative has been presented from the Norwegian government in their national alcohol strategy from 2020, and the Irish initiative would therefore fit well into other European initiatives on the same issue.  

The science is clear regarding alcohol as a class 1A carcinogen (highest classification of causality of cancer), also recognized by the World Health Organization. Well-designed health warnings on products have the potential to support a reduction in alcohol consumption and related harms such as future cancers. The Court of Justice of the European Union (‘CJEU’) has repeatedly confirmed that combating alcohol-related harm is an important and valid public health goal and health warnings on alcohol packaging as proposed in The Public Health Alcohol Act, 2018 is in our opinion clearly in accordance with EU Law and the alcohol industry`s tactic to make uncertainty whether the measure is legal or not cannot be heard. The motivation for introducing this measure is to protect human health.  

Conclusion 

IOGT Norway welcomes both the Irish initiative and the Commission’s commitments to propose effective legislation on alcohol labelling and warnings. We urge the Commission to support EU and EFTA Member States in their fight against the devastating effects of alcohol.