Aligning Visions for Public Health: EPHA’s Review of the European Commission’s Health Union Communication

On May 22, the European Commission adopted a Communication on the European Health Union. This document, presented by the Commissioner for Health (DG SANTE), Stella Kyriakides, highlights the significant strides made in EU health policy over the last five years; a period marked by unprecedented challenges and critical advancements. The Communication was unveiled at an event where Commissioner Kyriakides set the stage for future developments under her successor. 

 With over 30 years of relentless activity, the European Public Health Alliance (EPHA), along with its members and allies, plays a crucial role in shaping health policies and enhancing public health across Europe. EPHA actively engages in policy discussions, advocates for robust public health agendas, and ensures that health strategies throughout Europe are not only implemented but are also effective, sustainable, comprehensive, and inclusive.  

 In this context, it is crucial for us to analyse and review how well our mission and advocacy align with the Commission’s Communication. Our aim is to identify synergies and gaps in our shared vision, laid out in our manifesto, assessing what has been achieved so far and how we can further advance public health in Europe. Herein, we investigate how the five key priorities described in our manifesto are addressed by the Communication, evaluating the progress made and underlining areas for potential improvement. 

EPHA’s Priority 1: Keeping health as a top priority on the EU political agenda.

Pro: The Communication states the importance of health as a political priority and advocates for a joint action approach. 

Con: The Communication doesn’t mention specific structural changes to strengthen the health union. 

The EPHA manifesto emphasises the importance of keeping health as a top priority on the EU political agenda, breaking policy silos and increasing action on health across all policy areas. While both the EPHA manifesto and the European Commission’s Communication recognise the catalysing role the COVID-19 pandemic has had on EU health policy, they also express the need for the EU to maintain its trajectory and keep health as a political priority. Indeed, the Communication states that ‘health policy can no longer be limited to its pre-pandemic boundaries’ and that ‘joint action at European level is crucial to Europe’s societal wellbeing, our strategic autonomy, and our geopolitical stability.’ This integrated approach, demonstrated successfully during the COVID-19 pandemic, underscores the need for continued collaboration to empower health policy in Europe. This is especially relevant in the current context of permacrisis. 

To crystallise this priority, the EPHA manifesto suggests changes in the structure of European institutions. Notably, these include the appointment of a dedicated European Commission Vice-President on health and social rights and wellbeing, who would contribute to the implementation of a Health-in-all-Policies approach.  

The Communication concludes with a hopeful message on how it envisages the European Health Union to evolve and continue to enhance the health and wellbeing in the EU and beyond. We encourage the next mandate to take concrete action to realise this vision. 

EPHA’s Priority 2: Providing the means for an ambitious EU health policy

Pro: The Communication does mention a record high budget and robust support for the health workforce. 

Con: The Communication falls short in ensuring improved accountability and structured financial management. 

In alignment with the goals outlined in the EPHA manifesto, the Communication underscores the necessity of not only securing a sustainable budget, which has reached historic levels under this Commission, but also robustly supporting the health workforce across the EU. This is addressed through the introduction of an ambitious Action Plan that includes multi-level action focusing on improving working conditions, training, and skills for health professionals. These efforts are vital to guarantee that health systems are equipped to face current and future challenges efficiently. 

 Moreover, as part of its broader strategy to improve health workforce capabilities, the Commission has launched several initiatives under the Pact for Skills. Notably, this includes forming a skills partnership for the health ecosystem and the European Health Industry, aiming to bridge gaps in skills and facilitate continuous professional development in alignment with evolving healthcare needs. These efforts demonstrate a comprehensive approach to addressing the multifaceted challenges of the health sector, ensuring that the workforce is prepared, supported, and skilled in line with the latest advancements and demands of healthcare services. 

 Despite these positive steps, there is a need for improved accountability, and a more structured approach to financial management. The Communication stresses the significance of this substantial budget in strengthening health security and developing resilient health systems, which are vital during ongoing and future health crises. To fully leverage this historic economical resources, clear, transparent reporting and management of these funds are essential. Such accountability is crucial to uphold public trust and to demonstrate the effective and efficient use of health funds. However, the decision to reallocate 20% of this ambitious budget (€1 Billion out of a €5.3 Billion budget) in 2024 raises concerns about the commitment to these goals. 

EPHA’s Priority 3: Ensuring equal access to health and care

Pro: The Communication does highlight several successful initiatives to promote equal access to health services.

Con: The Communication lacks an explicit focus on intersectionality and the needs of the most vulnerable and marginalised populations, which would enhance reach, fairness and equity in health policies. 

The EPHA manifesto firmly advocates for addressing the stark disparities in health access and outcomes across Europe, emphasising the EU’s commitment to being ‘a Union of Equality.’ This commitment is vital, especially in ensuring equitable health outcomes for marginalised groups. The European Commission’s Communication on the European Health Union highlights various initiatives that align with this vision, yet challenges remain in fully realising this pledge. 

These challenges include combating intersectional health inequities, poverty, social exclusion, discrimination, and racism. Several strategies and initiatives have been designed to include measures to mitigate health inequity, such as in the Pharmaceutical Strategy and the Communication on Mental Health. These initiatives guarantee equal access to medicines and support reintegration into society after recovering from mental health issues. However, while these measures are praiseworthy, the depth of their impact on truly levelling the health access field needs continual assessment and proactive adjustments. Furthermore, they must include a wider societal and cross-sectoral approach to address the social and fundamental determinants of health and hook into the EU’s social agenda and other policy areas. Over the past years, EPHA proposed ways to improve this approach to foster greater inclusion and improve equity, especially in the narrative surrounding mental health issues and the EU’s approach to non-discrimination. 

Additionally, the manifesto stresses the importance of enabling equitable access to healthcare resources across the EU. The Commission’s response, particularly through the creation of the European Health Data Space (EHDS), aims to enhance access to and the sharing of health data, which is a step towards equitable health resource distribution. Another example provided in the Communication is the announcement of an upcoming evaluation of the EU medical device legislation, focusing on availability, sustainability, and competitiveness. Nevertheless, to fully align with EPHA’s vision, developed through relentless collaboration with its members, there must be an explicit focus on how these measures address the needs of the underrepresented groups and the so-called “digital inverse care law”. This entails, for example, addressing the digital determinants of health, that include digital health literacy, and safeguarding the ethical and safe use of health data. Ultimately, the manifesto calls for enhancing representation in health policy dialogues, rigorously evaluating the impact of health strategies on marginalised and vulnerable communities and ensuring that digital health advancements are accessible and beneficial to all, irrespective of socio-economic status. As the Communication optimistically states, the European Health Union aims to evolve and expand. It is hoped that this evolution will closely reflect the principles of equity and justice as core pillars of the EU’s health strategy, and will be mainstreamed across other strategies and policy areas, turning the promise of a Union of Equality into a living reality where nobody is left behind. 

EPHA’s Priority 4: Enhancing civil society participation in health policymaking

Pro: The Communication does highlight the importance of collaborating with civil society.  

Con: The Communication lacks a structural and sustainable framework for consistent and meaningful civil society involvement in co-creation processes. 

The EPHA manifesto underlines the critical role of civil society in enhancing the transparency and democracy of European policymaking. As watchdogs, CSOs monitor accountability and support the most marginalised and vulnerable, making these organisations not just supplementary but essential in delivering services and safeguarding the rights of those hardest hit by health and social emergencies. 

Notably, the Communication remarks the importance of collaborating with civil society only once, as part of the EU’s response to the COVID-19 pandemic through the Health Emergency Preparedness and Response Authority (HERA). While this acknowledgment is commendable and reflects a move towards more collaborative health governance, it falls short of having a truly transformative impact. There is a tangible need for a structural and sustainable framework that involves civil society consistently and meaningfully, integrating its contributions into the co-creation processes. 

Although the Communication does not explicitly mention it, the robust support for civil society through maintained Operating Grants, Framework Partnership Agreements and increased funding within the current Multiannual Financial Framework is noteworthy. However, this support alone is not enough. Recognising the indispensable role of civil society, it is imperative that the EU commits to safeguarding inclusive and transparent policymaking processes. This commitment must extend beyond token participation, empowering civil society with a genuine seat at the table.  

To institutionalise this approach, the development of a Civil Society Strategy is crucial. This strategy should ensure adequate and sustainable funding for CSOs across all sectors, allowing them to design and execute long-term plans without the ongoing uncertainty of funding. Moreover, the strategy should protect them from private interests, thus reducing the need to explore alternative funding sources. It is our hope that these key points will be considered by the next Commissioner of Health, thereby fostering a more inclusive and effective European health policy framework. 

EPHA’s Priority 5: Securing a healthy planet for healthy people

Pro: The Communication highlights health issues related to industries profiting from known NCD risk factors, actions against AMR, and climate commitments.  

Con: The Communication lacks all the promised and long-awaited stringent regulations on such industries, falling short of fully securing a healthy planet for healthy people. 

The EPHA manifesto underscores the necessity for the EU to secure its capacity for resilience and robustness amidst several converging crises, ranging from aging population and geopolitical conflicts to climate change and socio-economic instability. To navigate these complex challenges, a comprehensive and multidisciplinary approach is key, one that creates a robust healthy environment. 

  • Prioritising Health Over Commercial Interests 

The Communication addresses health issues related to tobacco and alcohol. It mentions an ongoing comprehensive evaluation of the legal framework for tobacco control aimed at supporting Member States in achieving a Tobacco-Free Generation. Additionally, the Commission remains committed to reducing “harmful alcohol consumption” as part of the prevention pillar of the Europe’s Beating Cancer Plan (EBCP). While these statements highlight a recognition of the need to control substances that significantly impact public health, the Communication does not directly address the stringent regulation of industries such as tobacco, alcohol, and ultra-processed foods to the extent advocated by health organisations, which prioritise health over commercial interests. This Commission has made important promises in the EBCP, including enhancing health literacy through clear labelling systems, and regulating the availability, taxation, and marketing of products known for their detrimental effects on health. These efforts aim to address the commercial determinants of health comprehensively. 

Initially, these promises were warmly welcomed by civil society, yet several and sometimes unannounced changes to the EBCP’s implementation roadmaps have tempered this optimism. Key deadlines were missed, and previously stated goals have been removed. Notably, these issues are not explicitly addressed in the ‘Looking Ahead’ section of the Communication. Our hope lies with the next Commission not exacerbating the delay in implementing of these crucial and long-awaited policies. These measures are essential, and while there are praiseworthy national successes, such as laws on alcohol labelling and health warnings in Ireland or the ban of appealing flavours in E-cigarettes in Slovenia, a coordinated European approach is necessary given the global scale of commercial interests that profit from known NCD risk factors.  

  • Enhancing Food Systems and Environments 

The Communication fails to mention any specification on food systems in general, and food environments in particular. Instead, it focuses broadly on health policy and its interconnectedness with environmental and economic stability, mentioning the Green Deal. However, the lack of detailed plans or the specific inclusion of actions regarding sustainable food systems and environments is considered a missed opportunity and an area left for future expansion, if picked up by the next Commission.  

EPHA, together with a plethora of its members and allies been relentlessly asking for explicit commitments or updates on these aspects, as well as the compliance of the Farm to Fork Strategy, which addressed the revision of the Food Information to Consumers Regulation, and the Sustainable Food Systems Framework. Neither of these cornerstones have been published.  To align more closely with the goals of transforming European food systems into more sustainable and health-focused entities, the future Commission’s workplan would need to incorporate specific policies on food environments (such as the regulation of the marketing of unhealthy food products, and public procurement), regulatory frameworks, and budget allocations directly addressing these areas.  

  • Leading the Global Fight Against AMR 

The EU’s actions against antimicrobial resistance (AMR) are prominently highlighted in the Communication through various health programs and the European One Health Action Plan. These efforts show significant alignment with global health security agendas. However, implementation on the ground often lags in terms of resource allocation and practical, cross-sectoral prevention strategies, which are critical for addressing the growing burden of AMR both within the EU and globally. 

Additionally, while the Communication includes the One Health approach, there is a need for a stronger focus on animal health within this framework. The Joint Action on Antimicrobial Resistance and Healthcare-Associated Infections (EU-JAMRAI) explicitly integrates animal health, but further emphasis is needed. Ensuring comprehensive integration of animal health measures, supported by the full implementation of the Farm to Fork strategy, is essential for a holistic approach to combating AMR across human, animal, and environmental health sectors. 

  • Addressing Climate Change and Health 

The EU’s commitment to addressing climate change is robust, as outlined in the European Green Deal and the European Climate Law, aiming for a 55% reduction in emissions by 2030 and for climate neutrality by 2050. While the Commission’s strategies align closely with environmental and global health goals, focusing on reducing pollution in all forms and transitioning to renewable energy, its climate targets fail to convey the urgency of the climate crisis 

The Communication acknowledges some of the positive steps made by the EU in recognising the need to address climate-related health impacts. A welcome development for EPHA and its members that does not feature in the Communication is the incorporation of human health as a major risk area in the first European Climate Risk Assessment launched in March 2024. Nonetheless, there remains a significant need for the EU to not only prepare and react to the health impacts of a changing planet, but also to mitigate them by concretely engaging, across all policy areas, with the climate-health nexus and related equity considerations.  

A success story is the integration of health and equity considerations in air pollution policies, as exemplified by the ongoing revision of the Ambient Air Quality Directive. We continue to recommend that the integration of this approach across all policies remains central in the future of the European Health Union, in line with the Health in All Policies Framework (HiAP). Regrettably, during the current mandate, this approach has been insufficient in critical policy areas, such as the new Industrial Emissions Directive and the Euro 7 Emissions Standards, which fail to deliver health and environmental co-benefits that would have been achieved through an adequate reduction of emissions and pollution. 

Moving forward with the European Health Union and EU climate action, it is necessary to avert the largely preventable health impacts linked to climate change. Agile mechanisms should be set up to ensure the integration of climate, health and social justice objectives across key sectors regulated at EU level, from energy to transport, agriculture and healthcare. 


In concluding this analysis of the European Commission’s Communication, it is evident that the Commissioner’s message is overwhelmingly positive, highlighting key achievements such as the largest health budget in the Union’s history and the most ambitious plans and actions to tackle NCDs, including cancer and mental health issues; other significant developments include leading health innovations on global scale through the introduction of the Digital Health Act, and a proactive and unified response to the global COVID-19 pandemic. Nonetheless, there are critical gaps that need addressing, especially in terms of integrating comprehensive health strategies that tackle broader commercial, social, digital, and environmental determinants of health. Moreover, recent announcements have tempered this confidence. Earlier this year, a decision was made to redirect 1 billion euros, a 20% cut, from the 5.4 billion euro EU4Health budget. Adding fuel to the fire, this month, the Director General of DG SANTE, Sandra Gallina, raised concerns about the future continuity of the EU4Health programme, remarking on the shift from a “constant source of public money” to a phase where “the seed is sown in the member states” and the focus must now shift to “sustainable financing”. 

These voids did not seem to affect the optimism that shines through in the ‘looking ahead’ section of the Communication, which outlines several priorities that the Commissioner hopes will be embraced by her successor for the new mandate. These priorities include Antimicrobial Resistance, Climate Change-Induced Health Threats, Medicine Shortages, Strengthening Medical Research and Health System Resilience, Healthy Aging in an Aging Europe, Cardiovascular Diseases, and Health Protection in the Digital Transformation. We are encouraged by the multifaceted approach these measures propose to foster a more just and healthier Europe. We urge the next Commission to implement ambitious plans addressing commercial, social and environmental determinants of health. As we look forward to the new workplan, we remain committed to collaborating with our members to actively support these efforts, refine our advocacy strategy and to comprehensively address these persisting public health challenges.  

A lot has been accomplished by this Commission, and we are grateful for its efforts in including civil society in consultations and starting to adopt co-creation processes. However, there remains room for improvement to fully integrate the broad, preventive, and equity-focused health strategies advocated by EPHA. The elections are approaching, and we will soon witness the formation of the new Parliament and the appointment of the new Commissioner for Health. EPHA has conducted a thorough manifesto analysis of how the main European political families have incorporated health into their respective work programs for the next mandate. The upcoming election presents a significant opportunity to recognise those political forces that have explicitly committed to creating a healthier society. Let’s work together to push for a more comprehensive and inclusive approach to health across Europe.  

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