24th Mar 2018


An open letter to ministers on the audiovisual directive

  • It is well-established that advertising causes both early onset and changes in consumption patterns, favouring the products advertised. (Photo: Mr Jan)

Dear Ministers,

The signatories to this letter would like to present suggestions to the ongoing negotiations on the Audiovisual Media Services Directive (AVMSD), relating to commercial communications.

Obesity and alcohol consumption are major causes of preventable ill-health and early death.

Currently, over half of EU citizens are overweight or obese and Europe's prevalence rate for children's (aged 5 to 17) obesity is greater than 30%. Becoming obese earlier in life clearly amplifies certain health risks.

Europe is also the heaviest drinking region in the world, with high alcohol use among adolescents. On average, four in five students (aged 15 to 16) report lifetime alcohol experience and every second student reported alcohol use in the last 30 days.

These consumption patterns amplify certain health risks which pose a burden on the sustainability of health systems.

It is well-established that advertising causes both early onset and changes in consumption patterns, favouring the products advertised.

Nevertheless, children and young people in Europe are still subjected to the aggressive marketing of alcohol and foods high in fat, sugar and salt (HFSS) on a frequent basis.

The ongoing revision of the Audiovisual Media Services Directive (AVMSD) presents a key opportunity to reduce exposure of Europe's children to commercial communications for products that can harm their health (health-harmful products) – it is an opportunity that should not be missed by EU governments.

We note that there are some positive aspects in the European Commission's proposal – for example, recognition of exposure as problematic. However, it relies on weak policy measures, such as self-regulation, and fails to provide effective protection of children from commercial communications.

The European Parliament's position, as adopted by its lead committee, weakens the commission's proposal, and we are greatly concerned that the EU institutions will fail to grasp this once-in-a-decade opportunity to protect children from commercial communications of health-harmful products.

Minimising exposure

We identified three improvements to the EU commission's proposal for AVMSD – to better achieve the objective of the AVMSD and to minimise children's exposure to HFSS food and alcohol marketing:

1. Minimise children's exposure to the marketing of health-harmful products:

Mandatory measures are needed to minimise the exposure of children to health-harmful marketing, regardless of whether the advertising is directly aimed at them or not.

Measures should cover television, on-demand services and online video-sharing platforms and include a mandatory provision for member states to determine and implement a watershed that adequately captures children's and adolescents' viewing times depending on the country.

Self-regulation and voluntary commitments without a regulatory framework have, to date, failed to achieve meaningful reductions in exposure. We strongly recommend that you keep a reference to the World Health Organization's (WHO's) nutrient profile model as a means of defining HFSS foods.

2. Exclude alcohol and HFSS food from product placement and sponsorship:

Product placement and sponsorship of alcoholic beverages and HFSS food are effective marketing techniques, and should be prohibited alongside tobacco and medicinal products – and not just from children's programmes or those with a significant children's audience.

3. Ensure that Member States can effectively limit broadcasts from other countries on public health grounds:

The efforts of front-runner governments to reduce the negative health effects of alcohol and HFSS food marketing must not be undermined by broadcasters established in other EU member states. The European Commission's proposal to this effect should be supported.

We hope to work constructively with you to develop a final text of the revised AVMSD that more effectively protects children and adolescents from commercial communications of health-harmful products.

Yours sincerely,

With kind regards,

Alcohol Policy Youth Network (APYN),

European Association for Study of the Liver (EASL),

European Centre for Monitoring Alcohol Marketing (EUCAM),

European Heart Network (EHN),

European Public Health Alliance (EPHA),

IOGT International,

International Association of Mutual Benefit Societies (AIM),

Standing Committee of European Doctors (CPME),

United European Gastroenterologist (UEG),

Alcohol Action Ireland (AAI),

British Medical Association (BMA),

Cancer Research UK,


Institute of Alcohol Studies (IAS),

Scottish Health Action on Alcohol Problems (SHAAP),


European Alcohol Policy Alliance (Eurocare).

This letter was written by 17 public health organisations, as listed above. An online copy of the letter can be found here.

Disclaimer: This article is sponsored by a third party. All opinions in this article reflect the views of the author and not of EUobserver.


Cost of obesity outweighs war and terrorism

Despite the expanding costs – and waistlines – caused by rising levels of European obesity, little is being done to remedy the epidemic.


Childhood obesity: Time to put words into action

MEPs from all parties have repeatedly voiced their concerns about the rising levels of childhood overweight and obesity. Yet, when the opportunity arises to put declarations into action, the response falls short.

An opportunity to help shape a better future for Europe

Political events of the last 18 months have prompted much soul searching and debate over the future of Europe. Romanian MEP, Laurentiu Rebega, believes that the European Conservatives and Reformists Group will best serve his constituents.

Behind the scenes of the Nordic model

The Nordic is comprised of 74 regions and, combined, is the 12th largest economy in the world. The State of the Nordic Region 2018 gives a unique look behind the scenes of the world's most integrated region.

Stakeholders' Views

This EUobserver section provides a platform for EU stakeholders to communicate positions, views and activities.

News in Brief

  1. EU wants 'Paris' climate strategy within 13 months
  2. Workload of EU court remains high
  3. Spain's supreme court charges Catalan separatist leaders
  4. EU calls for 'permanent' exemption from US tariffs
  5. Summit backs guidelines for future EU-UK talks
  6. Macron support drops as public sector workers go on strike
  7. EU leaders condemn Turkey for illegal actions in Aegean Sea
  8. Parliament must publish 'trilogue' documents, court says

Stakeholders' Highlights

  1. EUobserverStart a Career in EU Media. Apply Now to Become Our Next Sales Associate
  2. EUobserverHiring - Finance Officer With Accounting Degree or Experience - Apply Now!
  3. ECR GroupAn Opportunity to Help Shape a Better Future for Europe
  4. Counter BalanceControversial Turkish Azerbaijani Gas Pipeline Gets Major EU Loan
  5. World VisionSyria’s Children ‘At Risk of Never Fully Recovering', New Study Finds
  6. Macedonian Human Rights MovementMeets with US Congress Member to Denounce Anti-Macedonian Name Negotiations
  7. Martens CentreEuropean Defence Union: Time to Aim High?
  8. UNESDAWatch UNESDA’s President Toast Its 60th Anniversary Year
  9. AJC Transatlantic InstituteAJC Condemns MEP Ana Gomes’s Anti-Semitic Remark, Calls for Disciplinary Action
  10. EPSUEU Commissioners Deny 9.8 Million Workers Legal Minimum Standards on Information Rights
  11. ACCAAppropriate Risk Management is Crucial for Effective Strategic Leadership
  12. EPSUWill the Circular Economy be an Economy With no Workers?

Latest News

  1. Nordic states discuss targeted Russia sanctions
  2. Commission sticks to its line on Barroso case
  3. Germany and France promise new Russia sanctions
  4. EU rejects US trade 'gun to the head'
  5. Tariffs and Turkey will top This WEEK
  6. EU leaders roll over Brexit talks amid Trump and Russia fears
  7. Europe needs corporate tax reform - a digital tax isn't it
  8. EU data chiefs rally behind UK over Cambridge Analytica

Stakeholders' Highlights

  1. European Jewish CongressThe 2018 European Medal of Tolerance Goes to Prince Albert II of Monaco
  2. FiscalNoteGlobal Policy Trends: What to Watch in 2018
  3. Human Rights and Democracy NetworkPromoting Human Rights and Democracy in the Next Eu Multiannual Financial Framework
  4. Mission of China to the EUDigital Cooperation a Priority for China-EU Relations
  5. ECTACompetition must prevail in the quest for telecoms investment
  6. European Friends of ArmeniaTaking Stock of 30 Years of EU Policy on the Nagorno-Karabakh Conflict: How Can the EU Contribute to Peace?
  7. ILGA EuropeCongratulations Finland!
  8. UNICEFCyclone Season Looms Over 720,000 Rohingya Children in Myanmar & Bangladesh
  9. European Gaming & Betting AssociationEU Court: EU Commission Correct to Issue Guidelines for Online Gambling Services
  10. Mission of China to the EUChina Hopes for More Exchanges With Nordic, Baltic Countries
  11. Macedonian Human Rights MovementCondemns Facebook for Actively Promoting Anti-Macedonian Racism
  12. Nordic Council of MinistersGlobal Seed Vault: Gene Banks Gather to Celebrate 1 Million Seed Collections