EN   EN 
 
 
 EUROPEAN  
COMMISSION   
Brussels, 24.7.2020  
SWD(2020) 150 final  
 
COMMISSION STAFF WORKING DOCUMENT  
EVALUATION         
         
of the         
         
EU Drugs Strategy 2013 -2020 and EU Action Plan on Drugs 2017 -2020         
  
{SWD(2020)  151 final}   
 
1 
 Table of contents  
1. INTRODUCTION  ................................ ................................ ................................ ....... 4 
1.1 Context, purpose and scope of the evaluation  ................................ ..........................  4 
2. BACKGROUND TO THE IN TERVENTION  ................................ ...........................  5 
2.1 Description of the intervention and its objectives  ................................ ....................  5 
2.2 Intervention logic  ................................ ................................ ................................ ...... 6 
2.3 Baseline and points of comparison  ................................ ................................ ...........  7 
3. IMPLEMENTATION STATE  OF PLAY  ................................ ................................ .. 9 
4. METHOD  ................................ ................................ ................................ ..................  12 
4.1 Short description of  methodology ................................ ................................ ...........  12 
4.2 Limitations and robustness of findings  ................................ ................................ ... 13 
4.3. Deviations from the evaluation roadmap  ................................ ...............................  14 
5. ANALYSIS AND ANSWERS  TO THE EVALUATION QUESTIONS  ................  14 
5.1 Relevance  ................................ ................................ ................................ ................  15 
5.2 Coherence  ................................ ................................ ................................ ...............  17 
5.3 Effectiveness  ................................ ................................ ................................ ..........  20 
5.4 Efficiency  ................................ ................................ ................................ ................  32 
5.5 EU Added Value  ................................ ................................ ................................ ..... 35 
6. CONCLUSIONS  ................................ ................................ ................................ ....... 38 
ANNEX I: INTERVENTIO N LOGIC TABLE  ................................ ................................  41 
ANNEX II: PROCEDURAL  INFORMATION  ................................ ................................  42 
ANNEX III: SYNOPSIS REPORT OF THE STAKEH OLDER 
CONSULTATION  ................................ ................................ ................................ .... 44 
ANNEX IV: METHODS AN D ANALYTICAL TOOLS  ................................ ................  54 
ANNEX V: EVALUATION CRITERIA AND QUESTIO NS ................................ .........  55 
 
2 
  
Glossary  
Term or acronym  Meaning or definition  
CADAP  Central Asia Drug Action Programme  
CELAC  Community of Latin American and Caribbean States  
CEPOL  European Union Agency for Law Enforcement Training  
CND  United Nations Commission on Narcotic Drugs  
CSFD  Civil Society Forum on Drugs  
COSI  Standing Committee on Operational Coopera tion on Internal 
Security at the Council of the EU  
COPOLAD  Cooperation Programme between Latin America, the Caribbean 
and the E uropean Union on Drugs Policies  
ECDC  European Centre for Disease Prevention and Control  
EWS  Early Warning System on new psychoactive substances  
EEAS  Europea n External Action Service  
EMA  European Medicines Agency  
EMCDDA  European Monitoring Centre for Drugs and Drug Addiction  
EMPACT  EU policy cycle for organised and serious international crime - 
EMPACT  
EU-ACT  EU-Action against Dru gs and Organised Crime  
Europol  European Union Agency for Law Enforcement Cooperation  
HDG  Horizontal Working Party on Drugs  at the Council of the EU  
ICT Information and communications technology  
JIT Joint Investigation Team  
LSD  Lysergic acid diethylamide.  
MAOC -N The Maritime Analysis and Operations Centre -Narcotics  
MDMA  3,4-Methylenedioxymethamphetamine  (commonly known as 
ecstasy)  
NPS New psychoactive substances  
OCG  Organised Crime Groups  
 
3 SIENA  Secure Information Exchange Network Application  
UNAIDS  The Joint United Nations Programme on HIV and AIDS  
UNGASS 2016  United Nations General Assembly Special Session on the World 
Drug Problem (2016)  
WHO  World Health Organi zation  
 
4 1. INTRODUCTION  
1.1 Context, p urpose and scope  of the evaluation  
The EU Drugs Strategy 2013 -20201 (hereafter referred to as the Strategy) and its second 
EU Action Plan on Drugs 2017 -20202 (hereafter referred to as the Action Plan , and 
together with the Strategy sometimes referred to as the instruments ) set out the political 
framework and priorities for EU drugs policy. The Strategy provided a balanced , 
integrated,  evidence -based framework for tackling drugs inside and outside the EU, and 
was based on a five pillar structure consisting of  two main policy areas  – reduction of 
drug demand and  reduction of drug supply  – and three cross -cutting themes:  
coordination ; international cooperation ; and research, information, monitoring and 
evaluation. The Action Plan, which followed its predecessor the EU Action Plan on 
Drugs 2013 -20163, aimed to facilitate the implementation of the priorities laid out in the 
Strategy .  
The Strategy asked the Commission to “initiate an external midterm assessment of the 
Strategy by 2016, in view of preparing a second Action Plan for the period 2017 -20.” In 
this context, the European Agenda on Security4 also provided  for the Commission to 
assess progress in implementing the 2013 -2016 Action Plan and decide on that basis 
whether to propose a new Action Plan for the remaining years covered by the Strategy . 
This midterm assessment , along with a final evaluation of the first Action Plan , was 
concluded in March 2017  with the adoption of the second Action Plan.5 No updates were 
made to the EU Drugs Strategy , as this was outside the scope of the exercise .  
The midterm assessment found  that stakeholders favoured updating the 2013 -2016 
Action Plan in order to ensure the continued translation of the Strategy into concrete 
objectives and actions, and to respond  to new developments and emerging issues.6 The 
midterm assessment confirmed  that there is room for improvement in implementation 
and access to risk and harm reduction measures across various Member States , flagging 
concerns about the extent and quality of these measures.  Another conclusion was that 
new psychoactive substances (NPS) posed significant risks to health, and should continue 
to be monitored,  and aimed for the reduction of their supply, demand , and associated 
harms in the context of the Action Plan.   
The Strategy also mentions : “upon conclusion of the Drugs Strategy and its Action Plans 
by 2020, the Commission will initiate an overall external evaluation of their 
                                                           
1 OJ C 402, 29.12.2012, p. 1.  
2 OJ C 215, 05.07.2017, p. 21.  
3 OJ C 351, 30.11.2013, p. 1.  
4 COM(2015) 185.  
5 COM(2017) 195.  
6 For example, use of new communication technologies in illicit drug production and trafficking, and the 
role of internet in drug prevention. The omission of a discussion on ongoing trends in cannabis policy 
was noted by a wide range of stakeholders and represented one of the most frequent items raised when 
exploring whether there are any issues not covered by the Strategy.  
 
5 implementation .” With the support of an external contractor7, the Commission conducted 
the evaluation  of the Strategy an d the Action Plan between June 2019 and April 2020 . 
The overall  objective of the evaluation was to assess the implementation of the Strategy  
and the  Action Plan in terms of outputs, r esults and impact s. Based on the Commission’s 
Better Regulation Guidelines, i t look ed at the relevance , coherence , effectiveness, 
efficiency, and the achieved EU added value of the actions undertaken as part of the 
Action Plan, and on the basis of the Strategy. The evaluation also looked at  where the 
European Union and  its Member States could do more together to better address the 
current and future challenges of the drug situation, but also where national or even sub -
national measures would be better suited.  The outcome of the midterm assessment was 
taken into account in this evaluation, as well as the outcome of the evaluation of the 
European Monitoring Centre for Drugs and Drug Addiction (EMCDDA)8 conducted in 
2018 -2019 . The evaluation was also in part informed by an external study of the 
Strategy’s and Action Plan’s  implementation.9 
The evaluation considered the implementation of the Strategy and Action Plan from 
January 2013 to October 2019. A wide range of stakeholders were consulted as part of 
the evaluation. These included:  Member States competent authorities at the national, 
regional and local levels; civil society organisations including those that are members of 
the Civil Society Forum on Drugs10; academia  and researchers ; practitioners involved in 
the drugs or health policy fields; chemical and medical industry  representatives;  the 
general public ; and , the relevant Directorate s-Gene ral within the Commission, EU 
agencies and the European Ext ernal Action Service (EEAS) . International organisations 
and relevant stakeholders from third countries were also consulted when looking at the 
international cooperation pillar.   
This staff working document describes the evaluation, how it was carried out, the 
outcomes  and conclusions that were  drawn . It is accompanied by five annexes  that 
contain the intervention logic, procedural information  for the evaluation , a summary of 
the consultations, an overview of the methodology, and a detailed description of the 
evaluation criteria.   
2. BACKGROUND TO THE INT ERVENTION  
2.1 Description of the intervention and its objectives  
The Strategy was adopted by the Council in December 2012, and it maintained the same 
general structure as its predecessor strategy, although it was adjusted to reflect the key 
                                                           
7 A consortium composed of ICF Consulting Services Limited together wit h the Institute for the Study of 
Lifestyles and Substance Addiction, and the Center for the Study of Democracy.  
8 COM(2019) 228; SWD(2019) 174.  
9 ICF (2020). Evaluation study of the EU Drugs Strategy 2013 -2020 and EU Action Plan on Drugs 2017 -
2020.  
10 The C ivil Society Forum on Drugs is a  specific consultative body  created and chaired by the European 
Commission. Learn more: https://ec.europa.eu/home -affairs/wha t-we-do/networks/civil -society -forum -
drugs_en   
 
6 findings and recommendations of the evaluation of the previous instrument .11 For 
example, it noted for the first time the need to promote access to harm reduction 
interventions and the issue of NPS.  
In the European Agenda for Security, adopted in April 2015, the market for illicit drugs 
was recognized as a significant challenge under the serious and organised cross -border 
crime priority . It highlighted important areas that are covered by the Strategy and Action 
Plan, covering both drug demand and drug supply.  
The Strategy ha s five objectives  (later referred to as general objectives) , each linked to its 
five pillars , as follows:  
1) Policy field: drug demand reduction  – to contribute to a measurable reduction 
of the demand for drugs, of drug dependence and of drug -related health and social 
risks and harms;  
2) Policy field: drug supply reduction  – to contribute to a disruption of the illicit 
drugs market and a measurable reduction of the availability of illicit drugs;  
3) Cross -cutting theme: coordination  – to encourage coordination through active 
discourse and analysis of developments and c hallenges in the field of drugs at EU 
and international level;  
4) Cross -cutting theme: international cooperation  – to further strengthen 
dialogue and cooperation between the EU and third countries and international 
organisations on drug issues;  
5) Cross -cutting theme: information, research, monitoring and evaluation  – to 
contribute to a better dissemination of monitoring, research and evaluati on results 
and a better understanding of all aspects of the drugs phenomenon and of the 
impact of interventions in order t o provide sound and comprehensive evidence -
base for policies and actions.  
2.2 Intervention logic  
The intervention logic provides an overview of how the EU Drugs Strategy, implemented  
through the two Action Plans , was expected to work  (see Annex I  Interven tion logic 
table ). 
The intervention logic presents the chain of expected effects associated with the Strategy  
when it was first adopted , starting with the needs  that the intervention sought to address, 
namely, for the EU to prioritise and coordinate actions to counteract the supply and 
demand of illicit drugs.  
In response, the Strategy was built on five pillars, each supported by five corresponding 
general object ives (listed above) , which frame the intervention logic. These five general 
objectives were translated in the Action Plan  into 15 more tangible specific objectives , 
each pillar of the Strategy corresponding to three such specific objectives.  
The inputs  to support the implementation of the Strategy and the Action Plan included 
support through EU programmes and instruments as well as resource allocation at the 
national level by the Member States. The general and specific objectives were to be 
                                                           
11 For the evaluation of the previous instrument, see RAND (2012). Assessment of the implementation of 
the EU Drugs Strategy 2005 -2012 and its Action Plans. Technical Report.  
 
7 achieved thr ough a number of actions  that, as stated in the Action Plan, were to be 
“evidence -based, scientifically sound, realistic, time -bound, available and measurable 
with a clear EU relevance and added -value ”12. Under each general objective, the a ctions 
covered a wide -range of support areas . For example, a ctions under the general objective 
of drug demand reduction included activities from  prevention, early detection and 
intervention, treatment , to reintegration and recovery. With regards to drug supply 
reduction, t he Action Plan encompassed  judicial and law enforcement cooperation, 
confiscation of criminal assets and border management.  Key actors and bodies  
responsib le for carrying out the actions were also identified . Of these , the EMCDDA and 
Europol were named to have  central roles together with Member States and the 
Commission .  
Through the actions listed, the Strategy was meant to yield corresponding outputs . The 
intervention logic makes clear that where these outputs were met, the Strategy should 
have generated outcomes  that address the specific objectives . The various outcomes 
identified in the intervention logic , grouped together per each general objective, should 
lead to the impacts , which mirror  the five objectives of the Strategy. Although not 
included in th e intervention logic, the Action Plan also set out a number of over -arching 
indicators based on existing reporting mechanisms, which were meant to track outcomes 
and impacts.  
The intervention logic also identifies that the generation of impacts may be aff ected to 
some extent by other factors, namely, other policies  (international, EU and MS) as well 
as for example, political, social, economic and technological factors .  
Assuming these outcomes  were met and impacts  were achieved, the Strategy  should 
ultimat ely lead to the overarching impacts  highlighted in the intervention logic , thereby 
responding to the needs and general objectives.  
However, the overarching impacts extend beyond what could be measured in the 
evaluation. These correspond to the desired achi evements mentioned in the Strategy: “ a 
high level of human health protection, social stability and security ”13. They are present  in 
the intervention logic  because of their importance in bringing together the five strata of 
the intervention logic.    
2.3 Baseline  and points of comparison   
The baseline was mainly established on the basis of  EU figures aggregated from reported 
Member States data. These figures cover to the extent possible the period in which the 
Strategy was introduced (2013), but should be viewed with caution. They are not 
necessarily representative of the entire EU at a set point in time. Specifically, figures may 
not include data from all EU Member States, and may not reflect the exact baseline year. 
Member States do not always consistentl y report, and data is not gathered annually 
across the different areas covered by the Strategy. The figures used , mostly draw on desk 
research such as the final assessment of the Strategy’s predecessor (the EU Drugs 
Strategy 2005 -2012) and statistics gathered by the EMCDDA, as compiled in the external 
                                                           
12 OJ C 215, 05.07.2017, p. 21.  
13 OJ C 402, 29.12.2012, p. 1.  
 
8 study supporting this evaluation . These data were combined with ot her sources of 
information,  allowing for a general overview of the state of the drug demand, drug 
supply, coordination, international cooperation, and information, research, monitoring 
and evaluation (the five pillars of the Strategy) in the EU in 2013. In dicators were 
selected on the basis of the Action Plan to reflect to the best extent possible the 
underlying issues related to the objectives of the Strategy (the impacts of the intervention 
logic).  These fives strands are briefly introduced:  
Drug demand r eduction:  Among the age group in which illicit drug use is concentrated 
– 15-34 age group (EU 28) – on average14, as reported in 201315: 10.3% used cannabis, 
1.1% used cocaine, 0.8% used amphetamines, and 0.9% used MDMA16 (commonly 
known as ecstasy), over the last year17. In terms of the prevalence of high -risk drug users, 
on average, 3 per thousand population (aged 15 -64) were injecting drug users, and 3.1 
were high -risk opioid users. When looking how this translated into treatment demand, on 
average, 22 per 100,000 population (aged 15 -64) entered specialised treatment centres for 
cannabis use, 38 for opioid use, 5 for cocaine use, and 2 for amphetamine use. Regarding 
drug-related diseases, on average, 2.13 per million popu lation of HIV notifications were 
attributed to injecting drug use. On average, there were 11.9 reported drug -related deaths 
per million population (aged 15 -64).18  
Drug supply reduction:  The estimated retail market size of illicit drugs in the EU in 
2013 wa s estimated to be at least  EUR 24 billion.19 The supply of illicit drugs in the EU 
was characterised at the time by the shift from plant -based drugs to the production of 
synthetic and semi -synthetic drugs, which was beginning to take root in some EU 
Member States. The shift to synthetic drugs was closely linked to the availability of drug 
precursors , which are used to produce drugs, including synthetic drugs. There were five 
prominent drug markets in the EU: cannabis (which in spite of the shift mentioned above 
remained the largest market), heroin, cocaine, amphetamines, and MDMA. Herbal 
cannabis had the highest average number of seizures per 1 00,000 inhabitants (59 
seizures), as well as the highest average quantity seized in kg per 100,000 inhabitants (11 
kg). Cocaine was the most expensive drug at the time at EUR 57 per gram, followed by 
EUR 38 per gram for heroin, and EUR 7 per MDMA tablet.20 
                                                           
14 In this section, when references are made to average values, the type of average referred to is the median 
– the ‘middle’ value in a list of numbers – and not the more commonly used mean. This is the case 
unless stated otherwise . 
15 Supplied with data from earlier years where recent data for Member States was absent.  
16 3,4-Methyl enedioxy methamphetamine.  
17 Last year prevalence of drug use is often referred to as recent use. It indicates the percentage of the 
population that reported having used drugs (or a given substance) in the last year.  
18 See Baseline Situation and Annex 9  in ICF (2020),  Evaluation study of the EU Drugs Strategy 2013 -
2020 and EU Action Plan on Drugs 2017 -2020.  
19 EMCDDA and Europol (2016). EU Drug Markets Report. For more, see: 
https://www.emcdda.europa.eu/publications/joint -publications/eu -drug-markets -report -2019_en   
20 See Baseline Situation and Ann ex 9 in ICF (2020),  Evaluation study of the EU Drugs Strategy 2013 -
2020 and EU Action Plan on Drugs 2017 -2020. 
 
9 Coordination:  By 2013, p olicies in the area of illicit drugs actively engaged 
stakeholders at EU and national levels and to some extent , civil society. The Horizontal 
Working Party on Drugs at the Council of the EU (HDG), though playing a central role 
in the drugs policy discourse at EU level, had very limited to no coordination and formal 
exchanges with  other relevant Council bodies.  Finding a common EU position at the time 
was still hampered by divergent positions within the EU (and HDG). At the national 
level, most Member States had adopted the EU model of a drugs strategy; 12 out of 24 
Member States used the 2009 -2012 Action Plan a s a guide for developing national 
strategies; 23 out of 24 Member States indicated the involvement of civil society in 
national drugs policy. In terms of coordination among law enforcement actors, less than 
half of national intelligence on drugs was cross -checked with Europol’s databases.21  
International cooperation:  In 2013, Europe was an important destination for controlled 
substances but played a limited role as a transit point. Some production of controlled 
substances took place internally – for local c onsumption (e.g. cannabis), but also for 
export (e.g. synthetic drugs). Some candidate countries and potential candidates for 
future membership of the European Union used the Strategy’s predecessor as guidance 
for their own national policies and partook in  capacity building and data collection 
programmes, mainly with relevant EU agencies such as the EMCDDA, Europol and 
Eurojust. The Strategy’s predecessor was at this time often recognized by third countries 
as a standard  in drugs policy. A range of EU cooperation programmes with third 
countries or regions were underway focusing mostly on Latin America and the 
Caribbean , and Asia . The EU had influence within the United Nations Commission on 
Narcotic Drugs (CND), but limited visibility with t he World Health Organi zation (WHO) 
and the Joint United Nations Programme on HIV and AIDS (UNAIDS).22 
Information, Research, Monitoring and Evaluation:  Funding at EU level for drugs 
related research was allocated within four EU funding mechanisms in 2013 : the Drug 
Prevention and Information Programme, the Prevention of and Fight against Crime 
programme, the Second Health Programme, and the Seventh Financial Programme. In 
2013, this pillar was considered to be one of the strongest in terms of achieved results . 
The EMCDDA played a central role under this pillar. In 2013, the EU Early Warning 
System, operated by the EMCDDA and Europol, monitored 350 NPS, of which 81 were 
notified for the first time. Moreover, that year there were eighteen publications and three 
joint publications related to the European drug situation on the EMCDDA website. At the 
Member State level, nineteen evaluations of national drug strategies had been undertaken 
by 2013.23 
3. IMPLEMENTATION STATE OF PLAY 
The Strategy was implemented through two  Action Plans for the periods 2013 -2016 and 
2017 -2020. Both Action Plans were aligned to the five pillars  of the Strategy, under 
which  fifteen specific objectives  were laid out , three per each pillar . Each specific 
                                                           
21 See Baseline Situation and Annex 9  in ICF (2020),  Evaluation study of the EU Drugs Strategy 2013 -
2020 and EU Action Plan on Drugs 2017 -2020. 
22 Ibid.   
23 Ibid.   
 
10 objective was further divided into concrete actions, which were assigned  responsible 
parties and timeline for implementation24, as well as indicators and data collection 
mechanisms to sup port monitoring and evaluation. To facilitate the measurement of the 
overall effectiveness of the Action Plan s, fifteen over-arching indicators  were set out, 
along with additional indicators  that dr ew on programme, evaluative and other data 
sources.  These  were referenced, as appropriate, across the Action Plans. Utilisation of the 
indicators has been  dependent on data collection processes in each Member State or at 
EU level.  
Difference s between the two Action Plans include d the number and the topic s covered by 
the actions. The first Action Plan included a total of 54 actions, and the second Action 
Plan included a total of 55 actions. In the latter, n ew actions were included on 
strengthening monitoring of NPS, tracking cannabis policy and legislative developments , 
and identifying best practices with regard to the internet ’s role in drug prevention. Other 
additions include d focus on analysis of possible links between drug production and 
trafficking and other crimes, most notably terrorism financing, migrant smugglin g and 
trafficking in human beings.  This midterm assessment  of the Strategy along with the  final 
evaluation of the first Action Plan  found that the Action Plan covering 2013 -2016 had 
been implemented to different degrees across  all five pillars  (see Figure 1). Based on the 
Traffic Light Assessment25 that also takes into consideration the assigned timeline of 
each action within the timeframe covered by the instrument, t he majority of the actions 
were considered  implemented . 53% of actions were  assessed as completed or on track, 
whilst for 47% of actions some progress had  been made but implementation was behind 
plan. Overall, c onsiderable progress ha d been made across  the 15 specific objectives of 
the Action Plan.26 
Figure 1: Action Plan 2013 -2016 – status  of actions implemented per pillar27 
                                                           
24 The timeline  for implementation was mainly defined for each action  as ongoing, or as a year or range of 
years within the foreseen timeframe of the instrument.  
25 EY and RAND Europe  (2016). Mid -Term Assessment of the EU Drugs Strategy 2013 –2020 and Final 
Evaluation of the Action Plan on Drugs 2013 –2016. Final Report. Annex A -Traffic Light Assessment.  
26 COM(2017) 195.  
27 Ibid.  
 
11  
The current evaluation concluded  that the Action Plan covering 2017 -2020 ha s also been 
implemented to varying degrees across the five pillars, but implementation of demand 
reduction and supply reduction has seen the most delays since the previous Action Plan 
(see Figure 2). Most of the actions under demand and supply reduction were either found 
to lack progress (red) or to still require further progress  (yellow) . Overall, considerable 
progress ha s been ma de across the other three pillars, however, among these, the pillar on 
information, research, monitoring and evaluation was assessed to be still in progress to a 
large r degree.28 
Figure 2: Action Plan 2017 -2020 – status  of actions implemented per pillar29 
 
                                                           
28 See Annex 5 Traffic Light Assessment  in ICF (2020),  Evaluation study of the EU Drugs Strategy 2013 -
2020 and EU Act ion Plan on Drugs 2017 -2020. 
29 See Summary of traffic light assessment  in ICF (2020),  Evaluation study of the EU Drugs Strategy 2013 -
2020 and EU Action Plan on Drugs 2017 -2020.  
012345678910
Demand
reductionSupply
reductionCoordination International
cooperationInformation,
research,
monitoring and
evaluationNumber of Actions  
Green: on target Amber: in progress Red: no progress
 
12 In the area of drug demand reduction, specific objective (1)  to prevent drug use and delay  
the onset of drug use was found to be on target, while (2) to enhance  the effectiveness of 
drug treatment and rehabilitation, and (3) to  embed coordinated, best prac tice and quality 
approaches in drug demand reduction were found to be still in progress .  
In the area of drug supply reduction, the specific objective (4)  to enhance effective law 
enforcement coordination and cooperation was assessed on target, while  (5) to enhanc e 
effective judicial cooperation and legislation was behind schedule, and (6) to respond  
effectively to current and emerging trends in illicit drug activity was assessed as still in 
progress.  
In the area of coordination, all three  specific objecti ves (7-8-9) to ensur e effective 
coordination at EU and at national -level of drug -related policies , and to ensure  the 
participation of civil society in the formulation of drugs policy were assessed to be on 
target . 
In the field of international cooperation , the specific objective (10) to integrate  the 
Strategy into the EU's overall foreign policy framework was assessed as lagging behind, 
while the specific objectives (11) to  improv e the cohesiveness of the EU’s approach and 
visibility in the United Nations (UN) and (12) to support  the process for acceding  and 
candidate  countries  and potential candidates countries’ to adapt to and al ign with the EU 
acquis on drugs were assessed as on track.  
In the field of information, research, monitoring and evaluation, further progress was 
needed regarding specific objective (13) to ensure adequate investment in research, data 
collection, monitoring, evaluation and information exchange . Progress on (14) to 
maintain  networkin g and cooperation and develop  capacity within and across the EU’s 
knowledge infrastructure for information, research, monitoring and evaluation of drugs, 
particularly on illicit drugs , was good  and marked on target . Finally, on (1 5) to enhance 
the dissemination of monitoring, research and evaluation results at EU and national level , 
the evaluation found that further progress is still needed .  
 
4. METHOD  
4.1 Short description of methodology  
The evaluation aimed to analyse the implementation of the Strategy and its second 
Action Plan in terms of outputs, results and impacts according to the specific criteria set 
out in the Commission’s Better Regulation Guidelines ( relevance, coherence , 
effectiveness, efficiency  and EU added val ue). The evaluation has covered EU -2830 and 
applicable international aspects from January 2013 to October 2019.  
A wide range of stakeholders were consulted as part of the evaluation. A mixed -method 
approach consisting of three distinct phases (inception, da ta collection and field work, 
and analysis, triangulation and reporting) was developed in order to carry out the external 
study , which fed into this evaluation . Within each phase, a range of methodological tools 
and techniques were used. These included:  
                                                           
30 For the period covered by the evaluation,  the UK was an EU Member State.  
 
13  112 interviews covering all relevant  stakeholders  (Member States relevant 
authorities, EU -level stakeholders, civil society organisation, c hemical and 
pharmaceutical industry representatives, and international organisations  and UN 
agencies ); 
 An online surv ey targeted to four different stakeholder groups (the EMCDDA 
Reitox network of National Focal Points31, regional and local authorities in the 
field of drugs, EU Delegations and project beneficiaries of EU funds);  
 A workshop with the Civil Society Forum on Drugs, which also covered civil 
society organisations that represent people affected by and recovering from drugs, 
and their families;  
 A meeting organised by the external consultant with selected academics and 
experts  in the field  to discuss key findings and possible conclusions  before the 
finalization of the external study ;  
 2 thematic case studies on the  EU Early Warning System on new psychoactive 
substances and the use of benchmarks in policy documents;  
 8 Member States case studies chosen based on set criteria to achieve a balance of 
countries including , for example, based on geographical location , covered 
demand and supply side -indicators, innovative interventions and best practices, 
and balance between demand -supply policies at national level;  
 20 country fiches of the Member States not covered by the ca se studies;  
 The public consultation was conducted by the European Commission in all EU 
languages between 1 2 November 201 9 and 4 February 20 20, the results of which 
were made available to the contrac tor carrying out the external study.  
A more elaborate description of the methodologies applied a nd the stakeholder 
consultation activities  are provided in Annexes II I and I V. 
4.2 Limitations and robustness of findings  
Certain limitations were either identified at the outset of the evaluation or became 
apparent once the evaluation was underway. An overview of th ese limitations and a 
description of how they were addressed follows:  
 Figures  for the  baseline assessment are not consistent across Member Stat es. The 
figures  are not necessarily representative of the entire EU at a set point in time. 
Specifically, some fi gures may not include data from all EU Member States, and 
may not reflect the exact baseline year  (2013) . Member States do not always 
consisten tly report, and data is not gathered annually across the different areas 
covered by the Strategy.  Furthermore, the Strategy covers a broad range of 
aspects, not all of which were possible to be covered in the Baseline. However, 
various data sources were co mbined  to mitigate  this challenge, including desk 
research and interviews with Member States authorities.  
 There is a usual one to two years data collection delay  in the drugs policy field . In 
some instances, data available was more than two years old, or no d ata was 
                                                           
31 Members of the Reitox network are designated national institutions or agencies responsible for data 
collection and reporting on drugs and drug addiction. These institutions are called ‘national focal 
points ’ or ‘national drug observatories’; For more, see : 
http://www.emcdda.europa.eu/about/partners/reitox .  
 
14 available whatsoever. T he most recent available data covers the period of the 
Strategy until 2017 and in some cases, until 2018. Overall, the most impactful 
drawbacks have been  to the analysis on effectiveness and efficiency  due to 
limited avai lability  of statistical data for most of the 15 over -arching indicators 
and the lack of national quantitative data available for the period 2017 -2019. The 
information gaps due to lack of statistical data were filled largely throu gh 
qualitative inputs from stakeholders consulted.  
 Information on the implementation of the Strategy through the Action Plans was 
meant to be drawn from a wide range of sources such as Member States reporting, 
EU agencies and Commission reporting, EEAS (including EU delegations 
reporting ), the Horizontal Working Party on Drugs  at the  Council (HDG)  and 
Presidency reporting , and others. Due to the differences in (and sometimes lack 
of) data monitoring and collection, time lags  in reporting , the limited 
comparability of some of the national data available  and the sensitive nature of 
topics covered  by the Action Plan, in particular regarding  both drug demand and 
drug supply , information on implementation was fragmented  and not always up to 
date. This  was addressed through  the extensiv e stakeholder consulta tion activities 
and an EMCDDA briefing note covering an overview of implemen tation data, 
submitted to the external consultant .  
 The over-arching indicators related to  the drug supply strand are relatively limited 
in number . They are also limited in  overall usefulness  regarding the extent to 
which these reflect the baseline situation and the analysis of effectiveness.  The 
evaluation fill ed some of these information gaps largely through qualitative inputs 
from stakeholders consulted.  
Despite these limitations that stemmed from the wide range of areas covered, and the 
underl ying sensitive nature of both drug demand and drug supply  measures , the design of 
the analytical framework was such that the data collected was adequate in terms of 
quality and breadth of representation from different categories of stakeholders. At the end 
of the evaluation exercise, t his allowed for methodologically robust conclusions.  
4.3. Deviations from the evaluation roadmap  
While the Evaluation Roadmap that was pu blished in November 201 8 indicated that the 
evaluation should have been completed in the first quarter of 2020, the actual completion 
date was in the second quarter of 2020. This was due to the fact that the public 
consultation was launched later than initially anticipated. In o rder to allow enough time 
to process and analyse the outcomes, the Commission opted to extend the evaluation 
timeframe into the second quarter.  
 
5. ANALYSIS AND ANSWERS TO THE EVALUATION QU ESTIONS  
By comparing the baseline situation (described in Section 2. 3) with the implementation 
state of play (described in Section 3), it is possible to study to what extent the actions  and 
outputs  that can be observed (see the intervention logic in Section 2. 2) correspond to the 
expectati ons concerning what the Strategy  should have achieve d through the Action 
Plans , i.e. the five objectives of the Strategy  (see the description of the intervention in 
Section 2.1) . The sections that follow describe the results of this analysis in relation to  
 
15 the five evaluation criteria, namely relevance, coherence , effectiveness, efficiency  and 
EU added value. For clarity and simplicity, the evaluation questions in this section were 
grouped together in a single, more general question covering each criteria (for an 
overview of all the evaluation questions related to each criteria, see Annex IV.)  
5.1 Relevance  
Evaluation Q uestion:  To what extent are the Strategy and Action Plan relevant in view 
of current and future needs/challenges?  
Key findings  
 Owing to the ir broad scope, the Strategy and the Action Plan appear  to be overall 
relevant to the needs of different stakeholders at EU and national level.   
 However, t he Strategy appears to have partial relevance in view of recent 
technological, soci etal, policy/political and environmental developments, and the 
challenges they entail. Increased poly -criminality of organized crime groups, role of 
the EU as a producer and exporter, increased levels of violence and corruption that 
enable the drug trade, tech nologic enablers such as darknet marketplaces for 
buying/selling drugs, new patterns of drug consumption between young people and 
the aging population, as well as gender differences, and environmental effects were 
amongst the areas considered not sufficien tly covered.   
 The balanced approach between drug demand  and drug supply continues to be 
relevant  in view of the security and health needs related to the drugs phenomenon , as 
well as the general objectives of the Strategy.  
 The areas covered by the five pil lars of the Strategy and the actions in the Action 
Plans remain  generally relevant , but due to lack of prioriti sation, they are subject to 
different levels of visibility and means of implementation.  
 The Strategy could overall be made more concrete , focused , and set clear priorities 
to increase its relevance  in view of persistent and upcoming  trends and threats . In 
this context, a shorter life span than 8 years would also be more relevant to 
addressing pressing needs.  At the same time, the Action Plan  could also be more 
operational .  
The external study found that the wide scope of drug policy intersecting  major policy 
areas such as health and security, and the international and cross -border extent of drug 
related OCGs, demonstrate the continued need for the EU to be involved in the strategic 
development of drugs policy. This confirm s the continued relevanc e of the Strategy and 
Action Plan . 
According to the external study , stakeholders considered the Strategy and Action Plan to 
be as relevant as at the time of their adoption. The Strategy responded to the need for 
continued evidence -based strategic drug  policy development at EU level, and for a 
balanced approach between drug demand  and supply reduction that also address ed 
relevant  cross -cutting themes .  
 
16 However, while the Strategy and Action Plan  were  broad in scope and allowed for 
flexibility to accommo date different needs  of Member States , they  contained  no 
indication of priorities. The more critical priorities since 2013 , such as the emergence of 
NPS, could have been made clearer in operational terms. Also, from a practical 
perspecti ve, prioritisation of act ions was seen as necessary in view of t he limited 
resources available and in some cases the reduction of resources . The Strategy could 
overall be made more concrete, focused and set clear priorities according to current and 
emerging needs, but a lso be more proactive, meaning the Action Plan  could be more 
operational and relevant if it  would  address targeted up -to-date pressing needs. In this 
context, a  few stakeholders at EU and national level commented on the duration of the 
Strategy. Some considere d the lifespan of 8 years too long, especially given the dynamic 
nature of the policy area. A shorter duration was determined to be more relevant because 
it would have allow ed the Strategy to better take into account the fast evolving  drugs 
phenomenon .  
The assessment shows that even though overall , the Strategy and the Action Plan  have 
remained relevant to the needs and challenges  originally listed in the Strategy, some 
specific areas, gaps and challenges have been identified that have not been sufficien tly 
covered.  This finding accounts for and reflects the technological, societal, policy/political 
and environmental developments that have taken place since the Strategy was adopted in 
2012. A number of new and emerging relevant areas that are currently in sufficiently 
covered  or not covered at all , includ e:  
 Demand reduction: gender -approach and the specific circumstances and problems 
faced by female drug users; vulnerable and other population groups  of users with 
specific needs such as the ageing segment of the population that are long -term 
substance users , and those with co -morbidity, psychiatric needs and dual 
pathologies (drug use and mental issues) ; novel ways of drug consumption ; drug 
impaired driving and its effects on overall road safety; th e effective ness of 
relevant e lectronic and mobile health apps; associated health risks of specific 
drugs as these differ significantly across different types .  
 Supply reduction: EU as a producer and exporter  linked to the diversion of drug 
precursors  or us e of ‘designer -precursors’32 to make drugs, especially synthetic 
drugs ; environmental concerns  and high clean -up costs  related to  toxic waste 
from drug production illegally dumped;  increased poly -criminality of OCGs  and 
their adaptive and innovative modus operandi ; the use of new technologies  for 
drug related criminal entrepreneurship of OCG s, including  the use of darknet 
marketplaces  for drugs , encryption technologies and cryptocurrencies for 
facilitating anony mity, and the ‘uberisation’ of the cocaine mar ket whereby 
through the common use of smart phones sellers compete by offering additional 
services such as fast and flexible delivery options ; use of postal and express 
services for the delivery of drugs or drug precursors.  Stakeholders also singled 
out that a more explicit link should be addressed between drug use and violence , 
as well as the violence  and corruption used by  drug related OCGs.  
                                                           
32 Designer -precursors are close chemical relatives of a scheduled drug precursor that are purpose -made to 
circumvent controls by the aut horities and usually do not have any known legitimate use.  
 
17  Horizontal strands  and other priorities : predictive monitoring of the drug 
situation, including new tools,  artificial intelligence  and social media analysis for 
monitoring and predictive forecasting of trends, especially when it comes to NPS ; 
a balanced approach between drug demand and supply reduction measures to the 
issue of drugs in prisons; prevention efforts covering demand reduction as well as 
supply reduction such as crime prevention.  
A number of different stakeholder types are involved in the area of drugs and/or are 
affected by it, including, inter alia,  stakeholders at interna tional, EU, national, regional 
and local policy level, practitioners, civil society, industry, academia and of course 
people who use  drugs. Overall, owing to the broad scope and coverage of the Strategy 
and the Action Plan, the majority of stakeholder types consider that their specific needs 
have been reflected  in a general sense . A few areas emerged as not highlighted 
sufficiently in the Strategy, which can be linked to prioritization.  For example, civil 
society stakeholders emphasised the importance o f strengthening the harm reduction 
approach, and highlight ed human rights of drug users.  
 
5.2 Coherence  
Evaluation Q uestion: To what extent are the Strategy and Action Plan coherent with 
and complementary to other relevant policy interventions at Member State, EU, and 
international level?  
Key findings:  
 The Strategy is largely  consistent with other relevant EU sectoral policies and 
legislati ve developments , with no conflicting objectives . However, there is room 
for better exploitation of the synergies that  exist between the Strategy and other 
sectoral initiatives and cross -sectoral initiatives at EU level.  
 Further  synergies and coordination between drugs and drug precursors 
legislation33 would be beneficial , especially in terms of tackling the issue of 
‘designer -precursors ’. There are complementarities with EU health policy, but 
additional  aspects could be aligned  such as prevalence of drug use amongst the 
aging population . Stronger links with organised crime, cybersecurity, migra nt 
smuggling , terrorism a nd other relevant security policy topics would establish 
higher alignment with up to date  security developments. Lastly, the EU has been 
successfully integrating a strong drugs dimension in its approach to enlargement 
and in the instruments used for prepar ing candidate and potential candidate 
countries.  
 Overall, the general objectives of the Strategy and actions  in the Action Plan are 
coherent with the mandates  and activities of  relevant EU agencies  especially 
EMCDDA and Europol, as well as Eurojust, CEPOL , EMA, and ECDC.  
 The Strategy and the Action Plan appear to be coherent with national drugs 
                                                           
33 Regulations No 1258/2013 and No 1259/2013.   
 
18 policies. Overall, approximately half of  Member States seem to have been  more 
likely to closely align  to the Strategy and Action Plan, both structura lly and 
themati cally, whil e the other  half of  Member States have been  more likely to 
depart from th e structural paradigm of the Strategy and Action Plan.  
 The Strategy is perceived to be  a comprehensive guiding document for national 
stakeholder s across the EU, and in case of overlaps, Member States draw  from it 
what is resourceful  and applicable  for their national context.  
 At Member State level , most synergies were found in terms of EU coordination 
with stakeholders highlighting scope for improv ement in the area  of international 
cooperation, especially regarding dialogues with third countries.  
 At the international level, the Strategy and Action Plan have been  coherent with 
the United Nations framework and current strategic developments.  
 Overall, the Strategy is c oherent with the drug-related developments at global 
level . The EU and its Member States provide support and technical assistance to a 
wide range of drug -related initiatives in Latin America, the Caribbean and West 
Africa along the cocaine trafficking route, and in Afghanistan and Western 
Balkans  along the heroin  route.  
Overall, the Strategy and Action Plan appear to be  coherent with other EU policy and 
legislative developments in the field of drugs, although more synergies could  have  been 
created with precursor legislation,34 health policy, as well as stronger l inks with emerging 
security priorities .  
Since  2013, the EU has adopted legislative actions in the area of drugs, focussing on 
NPS.  These legislative developments appear to be coherent with the Strategy 
emphasising the need for timely action  on emerging  trends in the  area of drug  supply. In 
this context, EMCDDA actions in rapidly assessing the risks of NPS and maintaining a 
rapid information system with regard to their use and new methods of using for known 
existing psychoactive substances are coherent with the corresponding emphasis of the 
Strategy and Action Plans. The EMCDDA and Europol have been monitoring approx. 
788 NPS in 201935 through the Early Warning System (EWS) on NPS , providing a 
permanent function to facilitate the sharing of NPS related information among Member 
States.  
As for drug precursor legislation, the evaluation assessed  that this area, which relates 
both to internal and external trade, appears to be coherent with the Strategy to so me 
extent.  However, it stressed the importance to better integrate precursor issues in the 
Strategy, especially in terms of coordination and consiste ncy between the involved 
actors.  Particular attention should be paid to ‘designer -precursors’ as these chem icals are 
                                                           
34 Ibid.   
35 ICF (2020).  Evaluation study of the EU Drugs Strategy 2013 -2020 and EU Action Plan on Drugs 2017 -
2020.  
 
19 currently predominantly used in the illicit synthetic drug production in the EU and pose 
particular challenges for the law enforcement authorities.   
While the Strategy shares the same general objective of fostering good health with the 
EU Health Strategy, there is no real overlap between the two. The evaluation found that 
the coherence between the two could be further strengthened. For example, the Str ategy 
does not take into account a number of key aspects of the EU Health Strategy, such as: 
the challenges posed by the ageing population in Europe, the role of new technologies in 
delivering preventative interventions or treatment services, addictive beh aviours and 
general substance abuse issues . 
Although the Strategy is coherent with  the EU’s Internal Security Strategy and the 
European Agenda on Security, specifically in terms of the emphasis on disrupting drug 
related OCGs, the evaluation also determine d that further alignment could be achieved 
with relevant emerging challenges  in other security p riorities, such as cybersecurity, 
migrant  smuggling  and terrorism , and the fight against money laundering  and corruption, 
which enable OCGs .  
Overall, the EU has been successfully integrating a strong drugs dimension in its 
approach to enlargement and in the instruments used for preparing candidate and 
potential candidate countries. The drug -related acquis is reflected and addressed 
explicitly w ithin chapter 24 of the accession negotiations  and in the Stabilisation and 
Association Agreements with the Western Balkans . The Strategy and Action Plan 
support candidate and acc eding countries by providing guidance for aligning with the EU 
acquis.  
The evaluation also revealed other key  EU priorities that should have an increased level 
of coherence  with the Strategy. These include: EU education and training policy  as well 
as youth policy,  early intervention and treatment , and  potentially in terms of  prevention  
of drugs, where educational institutions could play a pivotal role in reaching and 
communicating to young people ; and finally, environment al policy  regarding  illicit 
dumping of chemicals resulting from drug production in the environment .  
Overall, the general objectives of the Strategy and actions in the Action Plan are coherent 
with the mandates and activities of relevant EU agencies especially EMCDDA and 
Europol, as well as Eurojust, CEPOL, EMA, and ECDC.  In particular, the joint activities 
betwee n the agencies have contributed to maintaining a high degree of coherence across 
the EU’s drug -related knowledge infrastructure in relation to the Strategy and Action 
Plan.  
The external study was useful in depicting how different Member States follow six 
patterns in terms of coherence with the Strategy and Action Plan. These patterns show 
that at national level,  the instruments are overall highly aligned with Member States 
strategies, action plans and other relevant drug policy documents. It appears that a ll 
Member States  strategies explicitly endorse the balanced approach to drug policy, 
emphasising the importance of both drug demand and supply reduction. Overall, 
approximately half of  Member States seem to have been more likely to closely align to 
the Str ategy and Action Plan, both structurally and thematically, while the other half of  
Member States have been more likely to depart from the structural paradigm of the 
Strategy and Action Plan.  Additionally, some Member States also included security and 
judic ial reform as additional priorities in their drug strategies and a few focused on 
addiction  more broadly . A third of Member States did not address one or more of the 
 
20 Strategy’s cross -cutting themes, such as coordination, international cooperation and 
monitoring and evaluation.  
While the Strategy has acted as  a guiding framework for national strategies, in some 
Member States with autonomous authorities, regions and pro vinces , the evaluation had 
difficulties in articulating the level of complementarity.  
At the international level, t he general objectives set out in the Strategy are highly 
coherent with the drug policies, conventions and declarations of the United Nations  (UN) 
and its bodies. To an important extent, this is because the EU engaged in related 
negotiations . This finding is based on compariso n with the three UN Conventions36, the 
Political Declaration of 200937, the 2030 Agenda for Sustainable Development  of 201 538, 
the UNGASS outcome document of 2 01639, the M inisterial Declaration of 201940 and the 
UNAIDS 2016 -21 Strategy41. The Strategy and UN drug related activities complement 
and reinforce each other and are mostly coherent.  
Drug -related priorities have  been incorporated into EU external policies, strategies and 
actions relating to third countries and regions. Efforts to promote supply reduction are 
often aligned with priorities that address organised crime or trans -national crime . This 
also points to th e possible need for further alignment and link within security priorities.  
Overall, the tasks of the Strategy and the Action Plan ha ve been allocated at the 
appropriate governance level, with improvements after the adoption of the second Action 
Plan. A ho rizontal need identified by the  evaluation was to involve civil society in the 
governance and coordination mechanisms of the Strategy and the Action Plan. With the 
adoption of the second Action Plan, this has been translated into  an increase d presence of 
civil society in the drug  policy  area at EU level . 
 
5.3 Effectiveness  
Evaluation Question:  To what extent have the Strategy and Action Plan been effective 
in delivering intended results?  
Key findings : 
 The Strategy has been partially effective in achieving the drug demand 
                                                           
36 https://www.unodc.org/unodc/en/commissions/CND/conventions.html  
37 https://www.unodc.org/unodc/en/commissions/CND/Political_Declarations/Political -Declarations_2009 -
Declaration.html  
38 https://sustainabledevelopment.un.org/sdgs   
39 https://www.unodc.org/documents/postungass2016/outcome/V1603301 -E.pdf  
40 https://www.unod c.org/documents/commissions/CND/2019/Ministerial_Declaration.pdf   
41 https://www.unaids.org/en/resources/documents/2015/UNAIDS_PCB37_15 -18 
 
21 reduction  general objective. While progress was overall made in terms of some 
areas covered under drug demand (e.g. the variety of general and specific 
prevention and treatment interven tions implemented across many Member 
States) , the Strategy did not seem  to succeed in reducing drug demand across the 
EU in comparison to 2013. Prevalence of drug use has increased across most 
types of drugs across most Member States  since the baseline year. The overall 
increase was particularly pronounced amongst young peopl e. Finally, drug -
related deaths across the EU have also increased.  
 Similarly, the Strategy has been only partially effective in achieving the drug 
supply reducti on general objective. While progress was recorded for example in 
terms of effective law enforcement coordination and cooperation within the EU, 
and while seizures of drugs have overall increased, the estimated availability of 
drugs in the EU has nonetheles s increased since 2013 across most types of drugs 
(in some instances doubled ). Purity of most illicit substances has also largely 
increased since the baseline year . Also, the large -scale operations conducted seem 
to have been largely insuffici ent to disrup t the illicit drug  markets.  
 In terms of the  coordination  general objective, the evaluation found that drug 
policy was overall effectively  coordinated at bo th EU and international levels. 
This was marked for example by the ability of the EU to ‘speak with one voice’ 
in international fora and with third countries, and the increased involvement of 
civil society in the policy making process. Weak points included structured 
continuity of Strate gy and Action Plan monitoring between the Presidencies at the 
Council , including discussion of the evolution and development of the 
instruments . 
 The objective of international cooperation  has been to a great extent effective.  
The EU’s engagement and coordi nation in fora for international policy -making on 
drugs showed to be particularly effective in the context of the adoption of the 
Outcome Document of the UN General Assembly Special Session in 2016, and of 
the UN CND Ministerial Declaration of 2019, where the EU was successful in 
promoting its approach at multilateral -level. Such approach was also successfully 
promoted with third countries and regions, some of them having largely drawn 
inspiration from the EU’s Strategy when modelling theirs.  Dialogue s and 
cooperation on drug issues was mainstreamed in the EU’s external action 
(including enlargement, neighbourhood policies, and development policies ). EU-
funded projects covering supply and demand for drugs were implemented 
internationally and resulted in sign ificant activities especially in Latin America 
and the Caribbean.  
 The objective of information, research, monitoring, and evaluation  has been to 
a certain extent effective. Understanding of the drugs phenomenon  and the impact 
of interventions has improved particularly due to the development of the two 
flagship reports , the European Drug Report (and acc ompanying country reports) 
by the EMCDDA and the joint EMCDDA – Europol EU Drug Markets Report, 
which have becom e a benchmark for high -quality assessment of the drugs 
situation and effectiveness of policies. However, other areas are not yet as 
effective, s uch as the use of the EMCDDA Best Practice Portal on drug demand 
related interventions, which has not been mains treamed by Member States into 
national or local evidence based policies and measures. Another area for 
 
22 improvement is the development and adopti on of supply indicators42 by the 
EMCDDA Reference Group on Drug Supply Indicators, which have been 
gradually adop ted by the majority of Member States but still fail to provide 
sufficient understanding of Member States’ effectiveness in supply reduction.  
 Internal and external obstacles to the implementation of the Strategy impacted the 
progress towards achieving its general objectives through the Action Plans. 
Examples include the continued emergence of high ly potent NPS, the increased 
use of new technologies  at all levels of the drug production, supply and 
distribution chains, and the increasingly poly -criminal natur e of organised crime 
groups (OCGs ) taking advantage of other emerging EU security challenges.   
By 2020, t he Strategy aimed to achieve an overall impact on key aspects of the EU drug 
situation. . It sought to “ensure a high level of human health protection, social stability 
and security, through a coherent,  effective and efficient implementation of measures, 
interventions and approaches in drug demand and drug supply reduction at national, EU 
and international level, and by minimising potential un intended negative consequences 
associated with the implementation of these actions”43. The effectiveness of the Strategy 
was largely evaluated by matching the degree of implementation of the 55 actions in the 
Action Plan with the assessment of the trends in terms of the five general objectives. 
Although the impact of the Strategy and Actio n Plan on drugs demand and supply cannot 
conclusively establish a causal link with current trends, the current situation on drugs 
provides a  relative  benchmark for the effectiveness of implementation of the instruments.  
The evaluation found that the two g eneral objectives of demand and supply reduction 
have only been partially achieved, although progress in different areas covered has been 
made. While the Strategy has been partially effective in encouraging and coordinating 
implementation of a wide range o f measures covering both demand and supply reduction, 
there is evidence that the trend in both demand and reduction has not been as positive as 
expected. On the other hand, the remaining three general objectives in terms of improved 
coordination, internati onal cooperation, and data collection and research recorded more 
significant progress than reduction of demand and supply.   
Drug demand reduction  
The general objective to contribute to a measurable reduction of the demand for drugs, of 
drug dependence an d of drug -related health and social risks and harms, has only been 
partially achieved. Under this general objective, the Action Plan laid out three specific 
objectives, two of which are still in progress and the third, which is on track.  
The evaluation fo und that some progress was achieved in terms of the specific objective 
(1) on prevention measures and delaying the onset of drug use. Prevention measures are 
available in all Member States and their availability has generally increased  since 2013 . 
The avai lability of universal evidence -based measures has also increased in all Member 
                                                           
42 Following the Council Conclusions on improving the monitoring of drug supply in the European Union 
(November 2013).  
43 See paragraph 4 of the Strategy.  
 
23 States. Targeted prevention measures have been widely available, focusing mostly on 
groups such as students and young adults at risk, young offenders and families. However, 
indicated prevention measures44 were available in less than half of Member States. Most 
implemented such measures generally focused on young people, with the aim to prevent 
drug use and delay the age at which children and you ng adults first try alcohol, smoking, 
illicit drugs and risky behaviour. Data recorded during the evaluation period showed that 
the age of first use  increased. Among drug users entering treatment in 2017, the reported 
age of first use of cannabis was 17, and  of heroin was 24, as opposed to 16 and 23, 
respectively , in 2013.  
In terms of specific objective (2) – to enhance the effectiveness of drug treatment and 
rehabilitation  services and to support the recovery and social re/integration of 
problematic and depe ndent drug users – this specific objective has been assessed as 
effective only to some extent.  
Even though the trends in use of illicit drugs differ across Member States, overall,  last-
year prevalence (recent use) of drug use among the adult population (a ged 15 -64) either 
did not change or increased between 2012 and 201745, particularly for cannabis , and 
decreased for MDMA (see Table 1). On the other hand, the EU weighted average of last -
year prevalence of cannabis, cocaine, MDMA and LSD46 increased among the young 
population (aged 15 -24). As observed for the wider population, the main drug used 
among teenagers and young adults was cannabis, and its use increased  during the period 
covered by this evaluation in most Member States.47  
Table 1:  Trend s in last -year prevalence of drug use 2012 -201748 
 Population (15 -
64) Young population (15 -
24) Teenagers and y oung 
adults (15 -34) 
Cannabis     
Cocaine     
Amphetamines     
MDMA     
LSD     
                                                           
44 Designed to prevent the onset of substance abuse in individuals who do not meet the medical criteria f or 
addiction, but who are showing early danger signs.  
45 Only 10 Member States have reported 2012 data; data from the remaining countries mostly correspond to 
2010 and 2011, although in a few cases it goes back to 2009 (1 MS), 2008, (2 MS), 2007 (1 MS), 200 4 
(1 MS) and 1998 (1 MS). On the other hand, seven Member States have reported 2017 data; data from 
the remaining countries mostly correspond to 2015 -2016, except in a few cases where it dates back to 
2014 (3 MS), 2013 (2 MS), 2012 (1 MS) and 2008 (1 MS).  
46 Lysergic acid diethylamide.  
47 The countries reporting an increase in last -year prevalence of cannabis among teenagers and young 
adults’ use are: AT, BG, CZ, FI, FR, DE, EL, IE, IT, LV, N, PL, PT, RO, SI and SE.  
48 See Evaluation Question 1, and Annex 3 Ev idence  in ICF (2020),  Evaluation study of the EU Drugs 
Strategy 2013 -2020 and EU Action Plan on Drugs 2017 -2020.  
 
24 Source: ICF, based on EMCDDA data statistical bulletin  
A range of risk and harm reduction measures for problem drug users ha s also been 
available in a large majority of Member States, in some cases implemented through 
community -based organisations. Harm reduction measures specifically targeted at 
reducing drug use in festival and nightlife settings and  those targeted  at the misu se of 
medicines have been effective in reducing poly -drug use.  
However, the perceived effectiveness of the different types of harm reduction services 
based on their access has not been considered particularly high by some stakeholders, 
such as civil society organisations. While access to treatment, opiate substitution and 
needle /syringe programmes were generally positively assessed, the access to drug 
consumption rooms, drug -checking programmes and naloxone distribution programmes 
were overall assesse d negatively. These differences could be explained by the fact that 
opioid substitution treatment and needle and syringe exchange programmes have been 
implemented for a longer period of time and are widely accepted, whereas drug testing 
services and drug c onsumption rooms are still somewhat new concepts in many Member 
States. In terms of quality, most of the harm reduction measures were positively assessed.  
Increased efforts to tackle the risk of infectious diseases among drug users have also been 
reported at national level, most of which seem to have been effective. For instance, HIV 
home testing kits are available in pharmacies in a growing number of countries (and in 
some, they are provided by harm reduction services) and the number of Member States 
that provide unrestricted access to HCV antivirals for all groups of patients has also 
increased in the last years. The prevalence of HIV and AIDS among drug users decreased  
between 2012 and 2017 (latest available data), both in terms of EU average and in the 
large majority of Member States. However, injecting drug use remains an important issue 
as localised HIV outbreaks were documented between 2014 and 2017. 
Effectiveness of harm reduction measures in prisons remains limited even though it 
seems to have overal l increased. The provision of healthcare measures for incarcerated 
drug users ha s grown, with all Member States providing opioid substitution treatment in 
prison. However, even if opioid substitution treatment was indeed available for prisoners 
in all Memb er States, the coverage in terms of number of prisoners for whom it was 
available was often found to be low. In addition, in a small number of Member States 
treatment cannot be initiated in prison but only continued.  Continuation of treatment on 
release from prison was available only in some Member States. Testing for drug related 
infectious diseases was available in prisons in most Member States, although it seems to 
be limited to testing upon entry or to prisoners showing symptoms.  
When measuring the effectiveness of this specific objective, it is also important to 
highlight that t he number of drug -related deaths rose from 5,804 in 2013 to 8,238 in 
2017.49 Opioids were present in the majority of fatal overdoses reported in the EU, and 
there was an increase in the number of opioid -related deaths in some Member States.  
In terms of speci fic objective (3) on embedding coordinated, best practice and quality 
approaches in drug demand reduction, progress was made and it was considered on track 
                                                           
49 EMCDDA (2019). Drug Related Deaths and Mortality in Europe, and 2013 data from EM CDDA 
Briefing Note for the midt erm assessment .  
 
25 with the adoption and initial stages of implementation of the common European 
minimum quality standa rds. More than half of Member States reported the use of the 
minimum quality standards. However, most service providers have been  civil society 
organisations, some of which have seen decreasing financial resources and have limited 
capacities and skills, which in turn could hinder the implementation of the minimum 
quality standards.  
Drug supply reduction  
The general objective , to contribute to a disruption of the illicit drugs market and a 
measurable reduction of the availabi lity of illicit drugs, has also only been partially 
achieved. Under drug supply reduction, the Action Plan laid out three specific objectives, 
of which the first was assessed to be on target and the other two still in progress. Overall, 
based on the availa ble data, stakeholders agree that there is little evidence to indicate that 
criminal structures involved in drugs trafficking, distribution and production have been 
dismantled or fractured to a significant extent by supply reduction activities. In terms of  
seizures of drugs,  law enforcement and judicial cooperation to tackle the supply of drugs 
has improved since 2013 . Even though availability of drugs seems to have increased 
overall in the EU since the adoption of the Strategy, it can be deduced that avail ability 
could have been even higher if not for the record level of seizures .  
After a marked decrease in the number of drug law offences relating to cocaine use and 
seizures between 2009 and 2015, cocaine related offences increased significantly in 2016 
and 2017, when it reached levels similar to 2011. By 2017, cocaine seizure more than 
doubled since 2013. Cannabis seizures also increased during this timeframe (see Table 
2). Cannabis was linked to around three quarters of drug use or possession offences 
reported in the EU in 2017. Regarding heroin seizures, the number and quantity have 
remained largely unchanged in 2017, compared to 2013. The number of offences for 
heroin use and supply have also remained stable since 2013.  The purity or potency across 
drug types has increased across the majority of Member States.  
Table 2. Trends in the retail drugs market (2013 -2017)50 
 Seizures            
2013 (tons)  Seizures         
2017 (tons)  Purit y change    
2013 -17 (median)  
Cocaine  62.6 140.4   
Heroin  5.6 5.4  
Cannabis Resin  460 466  
Cannabis herb  130 209  
Amphetamine  6.4 6.4  
MDMA  no data  1.7  
Methamphetamine  0.5 0.7  
Sources: ICF based on EMCDDA and EUROPOL EU Drug Markets Report (2019)  
                                                           
50 See Evaluation Question 1, and Annex 3 Evidence  in ICF (2020),  Evaluation study of the EU Drugs 
Strategy 2013 -2020 and EU Action Plan on Drugs 2017 -2020.  
 
26 The increase in cocaine and cannabis seizures likely prevented a n even  larger availability 
of these drugs across the EU, which could have led to increased consumption or increase 
in demand. Related to this point, the evaluation found that the specific objective (4) - to 
enhance effec tive law enforcement coordination and cooperation within the EU to 
counter illicit drug activity, in coherence, as appropriate, with relevant actions 
determined through the EU policy cycle - recorded the most progress under supply 
reduction and was marked on track.  
Operational activities by Europol and Eurojust to tackle drug trafficking and support 
Member State law enforcement agencies have generally strengthened. In comparison to 
the period prior to the adoption of the Strategy, cooperation on drugs investigations via 
Eurojust has increased with a greater number of Joint Investigation Teams (JITs), 
coordination meetings, and drug trafficking cases registered. With the expanded mandate 
of Frontex after 2016, the Agency be came actively involved in contributing to detection, 
prevention, and combatting cross -border crime, including contributing to significant 
quantities of drug seizures. The Maritime Analysis and Operations Centre -Narcotics 
(MAOC -N) has continued to serve and  further strengthened its position contributing 
effectively to numerous operations.  As regards to Europol, the number of JITs has 
remained largely unchanged. S ome s takeholders noted that the Strategy and Action Plan 
have given little impetus to larger scal e operation activities in the field of drugs.  
Since the adoption of the EU Policy Cycle for organised and serious international crime 
(EMPACT) in 2010, the Joint Action Days have yielded positive results in terms of drug 
seizures. At the same time, the EU  Policy Cycle has also been described as a process 
supporting daily and routine cooperation between law enforcement  agencies . In that way , 
it improved cooperation on supply reduction  and information exchange . However, 
stakeholders gave an indication that the insufficient funding and a lack of initiatives by 
Member States could have acted to prevent more effective tackl ing of  high-level, large -
scale drugs trafficking into the EU.  
Regarding the exchange of information between law enforcement agencies, the us e of the 
Secure Information Exchange Network Application (SIENA) systematically rose 
between  2013 and 2018 , including in terms of drugs -related exchange of info rmation.  
In terms of training of law enforcement officers, the number of courses provided by the 
European Union Agency for Law Enforcement Training (CEPOL) on elements relating 
to countering drug -trafficking have steadily increased between 2013 and 2018. In 2013, 
only two courses were offered, while in 2018 a total of 13 courses were provided. The 
number of participants also increased, allowing CEPOL to reach a wider audience.  
Finally, efforts to prevent the diversion and trafficking of precursors were made during 
the evaluation period. The EU has continued to address the challenges linked to the 
diversion and trafficking of precursors. The European Commission has added a number 
of drug precursors to the list o f scheduled substances. In cooperation with the Member 
States, it has also issued new guidelines on cooperation between authorities and industry. 
The use of the International Narcotics Control Board  pre-export notification (PEN) 
 
27 online system and the precur sors incident communication system (P ICS) has increased in 
the EU between 2013 and 2018.51 
The specific objective (5) - to enhance effective judicial cooperation and legislation 
within the EU - was considered to be still in progress. During the evaluated pe riod, a 
number of legislative initiatives were adopted in  the EU.52 In addition, the 2013 
amendments to the EU legislation on trade of drug precursors53 established among others 
the introduction of the end -user registration obligation for example, for acetic  anhydride , 
and introduced a ‘catch -all’ provision s54 with a view to address the use of non -scheduled 
drug precursors. While these legislative  developments , by improv ing cooperation, 
tackling the diversion and trafficking of drug precursors and tackling NPS , have already 
been implemented in most Member States, according to stakeholders, there is little 
evidence on the practical application or effects on tackling supply of drugs.  
In terms of the application of alternatives to coercive sanctions, all Member S tates have 
at least one available alternative sanction for drug -using offenders. The conditions for 
applying alternatives to coercive sanctions range from a decision of the judge to the 
decriminalisation of drug use, but in many Member States, such measure s are applied 
when there is no suspicion of drug trafficking and in case of minor offences. The 
effectiveness in terms of access to and quality of these measures seems to differ greatly 
across Member States.  
The specific objective (6) - to respond effectiv ely to current and emerging trends in illicit 
drug activity  - was found to be still in progress. The main trend addressed was related to 
the role of new information and communications technologies (ICT) in support of drug 
supply activities. Despite the lac k of reliable and comparative data, there is an indication 
that between 2013 and 2018 drugs sales over the internet have evolved and fragmented 
into a growing number of small traders. Steps have been taken to address the role of ICT, 
including multiple cross-border operations to dismantle or shut down online 
marketplaces selling drugs. For example, Europol’s dedicated ‘Dark web team’ was 
established in 2018 to provide operational and technical support. The EU-funded project 
Illegal Trade on Online Marketpla ces (2013 -2015) established an EU network to finding 
                                                           
51 For more information on the evaluation of legislation on trade in drug precursors: 
https://ec.europa.eu/info/law/better -regulation/have -your-say/initiatives/1474 -Evaluation -of-
legislation -on-trade -in-drug-precur sors.  
52 Including: Regulation (EU) 2017/2101, better defining the procedure on the monitoring and control of 
new psychoactive substances, and Directive (EU) 2017/2103, which by including new psychoactive 
substances in the definition of ‘drug’, further har monised the definition of drug trafficking offences 
and penalties therefore further reducing problems arising in the cooperation between the judicial 
authorities and law enforcement agencies; Directive 2014/42/EU on the freezing and  confiscation of 
the ins trumentalities and proceeds of crime, which approximated Member State regimes thus 
facilitating cross -border cooperation; the 4th and 5th Anti -Money -laundering Directives, which further 
developed cooperation rules, in particular between FIUs and the Commis sion, or between competent 
Member State authorities.  
53 Regulations No 1258/2013 and No 1259/2013.  
54 The aim of these provisions was to allow the competent authorities to intervene in cases where non -
scheduled substances, including designer -precursors, were  traded or smuggled with a view to use in 
illegal drug manufacture.  
 
28 effective ways to combat illegal drug trade online. Another EU -funded project, I -
TREND, developed a tool in 2017 aimed at discovering web shops that sell NPS. The 
tool was then able to identify as many a s 500 web -shops in five Member States. At 
national level, many Member States had taken steps to address new trends, by means of 
trainings and participation in specific operational EMPACT actions. There is no 
information about the extent to which new emergi ng trends have been tackled at the 
national level and through national level responses.  
Coordination  
The evaluation determined that the general objective to encourage coordination through 
active discourse and analysis of developments and challenges in the  field of drugs at EU 
and international level, was overall achieved. All three specific objectives covered under 
coordination were found to be on target.  
Specific objective (7)  - to ensure effective EU coordination in the drugs field - was found 
to be on track. Drug policy was overall effectively coordinated at EU level. Since 2017 , 
there has been increased effective coordination at EU level in the field of drugs, 
concerning Council preparatory bodies  especially the HDG  and the Standing Committee 
on Operational Cooperation on Internal Security (COSI) , EU agencies and EU -funded 
projects with third countries. The HDG was found to be somewhat effective in terms of 
enhancing information sharing with other relevant Council preparatory  bodies , although 
most information was shared on an ad -hoc basis. Structured cooperation between Council 
preparatory bodies working on drugs , and the monitoring of the implementation of the 
Action Plan through thematic debates by Presidencies were found to  be among the least 
effective  actions in the Action Plan under this pillar . As thematic debates, especially after 
2017, were not organised in a consistent and planned manner, the state of implementation 
of the Action Plan was found to  have lost some moment um.  
EU agencies, especially EMCDDA, Europol, Eurojust and CEPOL , were effective in 
coordinating activities in terms of implementation of the Strategy . However, it was 
determined that the increased workload in the drug policy field , including the area of 
coordination, should also allow for increased financial and human resources available for 
EU agencies, where needed .  
The specific objective (8) - to ensure effective coordination of drug -related policy at 
national level  - was also d etermined to be on track. Even though there remain differing 
levels of successful implementation across the EU, horizontal and vertical coordination 
mechanisms and agencies tasked with the monitoring, evaluation and coordination of 
national drugs policy ar e now in place in most Member States.  
Finally, the specific objective (9) - to ensure the participation of civil society in drugs 
policy - was found to have made significant progress marked for example by the regular 
participation of the CSFD in HDG meeti ngs and their annual attendance at the CND , and 
an increasing number of Member States engaging with civil society on drugs policy 
issues. Challenges nonetheless remain , such as ensuring the formal involvement of civil 
society in drug policy while avoiding discrepancies between Member States, and 
increasing effective engagement with the scientific community beyond annual 
conferences.  
International cooperation  
 
29 The objective to further strengthen dialogue and cooperation between the EU and third 
countries and international organisations on drug issues was to a large extent 
implemented effectively and was determined to be largely achieved by the evaluation. 
From t he three specific objectives covered by international cooperation, the first was 
found to still be in progress while the other two to be on target.  
The first specific objective (10) – to integrate the EU Drugs Strategy within the EU's 
overall foreign poli cy framework as part of a comprehensive approach that makes full 
use of the variety of policies and diplomatic, political and financial instruments at the 
EU's disposal in a coherent and coordinated manner – was marked still in progress. Drug -
related prior ities have been effectively incorporated into EU external policies, strategies 
and actions relating to third countries and regions, but more focus should be put on 
improving the capacity and strengthening the role of EU delegations, and on emphasizing 
reporting on EU cooperation projects.  
The balanced approach of the Strategy has been commonly integrated within the EU’s 
external action in third countries  or regions . While on the one hand the Heroin Route and 
Cocaine Route Programmes mainly focused on supply  side measures, both demand  and 
supply  side programmes were implemented via the Cooperation Programme between 
Latin America, the Caribbean and the European Union on Drugs Policies  (COPOLAD ) 
and the Central Asia Drug Action Programme (CADAP –6). Despite lack  of evidence on 
the impact of the various activities and projects on drug supply or demand, they have 
contributed to an improved dialogue and cooperation at strategic, institutional and expert 
level.   
The specific objective (11) – to improve cohesiveness of EU approach and EU visibility 
in the United Nations (UN) and strengthen EU coordination with international bodies 
related to the drugs field – was found to be on target. The EU’s position and contribution 
to the United Nations global efforts to tackle i llicit drugs has been strengthened via joint 
EU action and better institutional cooperation between EU and UN agencies. The 
preparation of common positions allowing the EU Member States to promote the EU’s 
approach with a unified voice at the 2016 United N ations General Assembly Special 
Session on Drugs and the UN CND Ministerial Declaration in 2019 were  highlighted as 
the main success stor ies in this area during the evaluation period. Complementing the 
EU’s engagement at strategic and policy level,  EMCDDA,  Europol, and CEPOL 
furthered their cooperation with UNODC via various  capacity building and institutional 
cooperation projects. Although this specific objective was effectively met, the evaluation 
found that there is some room for improvement with regards  to the adoption of common 
positions on some drug related topics.  
The specific objective (12) – to support the process for acceding countries, candidate 
countries, and potential candidates to adapt to and align with the EU acquis in the drugs 
field, throug h targeted assistance and monitoring – was also found to be on target. 
Dialogue and cooperation on drug issues was mainstreamed in EU external actions, 
enlargement and neighbourhood policies, and development policy/ cooperation projects. 
The Strategy consti tuted a reference for third countries wishing to adopt similar 
documents at national level. In this sense, the impact on candidate and potential 
candidate countries is particularly relevant, as the Strategy provided some necessary 
guidance supporting these partner countries to better align with the EU acquis in the field 
of drugs. This was reflected in the national drug strategies adopted in the Western 
Balk ans, all of which are largely in line with the Strategy.  
 
30 Information, research, monitoring, and evaluation  
The general objective , to contribute to a better dissemination of monitoring, research and 
evaluation results and a better understanding of all aspec ts of the drugs phenomenon and 
of the impact of interventions in order to provide sound and comprehensive evidence -
base for policies and actions,  has been to a large extent effectively implemented, and has 
been overall achieved. The first and third specifi c objectives were determined to still be 
in progress and the second on target.  
Implementation was still in progress in some areas covered by the specific objective (13) 
– to ensure adequate investment in research, data collection, monitoring, evaluation a nd 
information exchange on all aspects of the drugs phenomenon. EU funding for drug -
related research and studies was available across several mechanisms, but slightly 
decreased throughout the evaluation period . Moreover, the priorities of the Strategy and 
Action Plan have  generally been taken into account by EU -funded projects, and 
stakeholders have been generally positive about the added value of these projects. . The 
evidence -based evaluations of policies and interventions have been supported, but 
investm ent in research, data collection, monitoring, evaluation and information exchange 
on all aspects of the drug phenomenon is still limited.  
The specific objective (14) – to maintain networking and cooperation and develop 
capacity within and across the EU's k nowledge infrastructure for information, research, 
monitoring and evaluation of drugs, particularly illicit drugs – was evaluated as 
implemented effectively and on target.  
Important steps have been made towards implementing this specific objective. The 
EMCDDA and Europol – in cooperation with Member States – have provided 
comprehensive analyses and organised relevant trainings in cooperation with CEPOL. 
Data collection tools have been further enhanced largely due to the work of the 
EMCDDA. The capacity to detect, assess and respond effectively to the emergence and 
use of NPS continued to progress under the EU Early Warning System on New 
Psychoactive Substances and the 2017 legislation on new psychoactive substances55. The 
latter also played an important role  in aiming for progress on the ability to identify, 
assess and respond at Member State and EU levels to behavioural changes in drug 
consumption and to drug -related epidemic outbreaks. However, it was too soon to 
identify what progress had been made during the evaluation period. At  the EU level, 
EMCDDA’s trendspotter methodology has been used since 2011 to provide analysis on 
new behaviours including on the use of cocaine, ecstasy, NPS, and online trade.  
In addition, the collection of data has been enhanced through the development and 
adoption of supply indicators by the EMCDDA Reference Group on Drug Supply 
Indicators. These have been gradually adopted by the majority of Member States, but still 
seem to fail to provide sufficient understanding of Member Stat es’ effectiveness in 
supply reduction. The core monitoring data related to drug  demand has remained 
relatively stable, and has been subject to only minor changes.  
                                                           
55 Regulations No 1258/2013 and No 1259/2013.  
 
31 The two flagship reports , the  EMCDDA’s European Drug Report with accompanying 
country report s and the joint EMCDDA – Europol EU Drug Markets Report , have 
become a benchmark for high -quality assessment of the drugs situation and policies.  
The potential links between drugs trafficking and terrorist financing, migrant smuggling 
and trafficking in hu man beings have been examined . However, some research topics 
remain underexplored. The EU -wide study on drug -related community intimidation and 
its impact has not been carried out yet.  
Lastly, t he EU Early Warning System on New Psychoactive Substances sup ported the 
identification of new psychoactive substances, among others through its contributions to 
the sharing of forensic science data on new psychoactive substances. Cooperation with 
the Customs Laboratories European Network, European Network of Forensi c Science 
Institutes and The International Association of Forensic Toxicologists also supported the 
sharing of this data. However, progress is still lacking on the ease of access to laboratory 
reference standards by forensic science laboratories, customs l aboratories and institutes, 
and on the development of a common methodology for the identification of new 
psychoactive substances.  
The specific objective (15) – to enhance dissemination of monitoring, research and 
evaluation results at EU and national level  – has been largely implemented effectively 
but remains in progress. While the EMCDDA has been continuously developing and 
improving the dissemination of EU level research, there seems to still be insufficient 
dissemination and outreach of results and outp uts at the national level as exemplified by 
their limited use by Member States. An example  is the EMCDDA Best Practice Portal on 
drug demand related interventions , which has not been mainstreamed by Member States 
into national or local evidence based polic ies and measures.  
Furthermore, concerns exist regarding the support for Reitox National Focal Points and 
their capacity to implement monitoring tasks agreed at EU level. A lack of adequate 
support may have already impacted and may impact the capacity of s ome National Focal 
Points to enhance dissemination of monitoring, research and evaluation results at national 
levels.  
Internal and external factors that have hindered the effective implementation of the 
Strategy and Action Plan  
The evaluation found that there were several developments that hindered the 
implementation of the Strategy and Action Plan. One of the most significant challenges 
has been the emergence of NPS , which are (partly) highly potent and therefore only in 
very small quantities  dangerous f or consumption , rendering detection difficult.  
The increased presence of new technologies at all levels of the drug production, supply 
and distribution chains continues to cause challenges in effectiveness of policy and 
operational responses.   
Diversific ation of the criminal activities carried out by OCGs that have increasingly 
moved into poly -criminality has highlighted the connection between emerging EU 
security challenges. For example, between 2013 and 20 19 drugs trafficking ha s been 
detected together with illegal migrant smuggling.  
 
32 Another important factor , which affected the effectiveness of the Strategy and Action 
Plans , could be the diverging viewpoints across Member States in terms of the debate 
surrounding legislation of therapeutic or recreationa l uses of cannabis.  
One last external factor to consider, are the socio -economic developments across 
Member States. It was found that rising unemployment, especially among young people, 
combined with rising inequalities could be important factors to expla in rising 
consumption.   
 
5.4 Efficiency  
Evaluation Question: To what extent have the Strategy and Action Plan achieved 
intended results in the most efficient manner?  
Key findings:  
 The lack of quantifiable data at national levels prevents making a sound 
assessment of the implementation costs for Member States brought by the 
Strategy. Furthermore, national financial estimates for the period of the 2017 -
2020 Action Plan are unavailable. However, the national budgets dedicated to 
drug-related policies have r emained relatively stable in the majority of Member 
States over the period under evaluation, based on opinions of national 
stakeholders. Seven Member States have reported declining and insufficient 
funding for the drugs field. Factors that have contributed  to a stagnation of 
national funds in the field of drugs include austerity programmes (in particular in 
the first half of the Strategy's timeframe), and competing priorities, especially in 
the security area, due to terrorism, cybercrime, higher defence exp enditure, and 
also migration pressures.  
 Although t he allocation  of public spending  between demand and supply reduction 
measures  varied across Member States , balance was often maintained in the ra nge 
of 40/60% – 60/40%. This balance could also vary for the same Member State 
during different time periods  since 2013 . 
 The EMCDDA , as reported by the Agency during this evaluation,  has not been 
allocated sufficient resources in line with the obvious hike in the volume of work 
and the higher funds required to addre ss the emerging new trends, such as new 
drugs and new consumption patterns.  
 Europol has also reported as part of this evaluation that it has not been allocated 
sufficient resources to tackle new challenges in the field of drugs, such as 
emerging new supply  channels and the ever -growing resources of organised 
criminal groups involved in drugs production and trafficking. Key indicators on 
supply reduction have not been achieved due to lack of sufficient resources to 
conduct large -scale investigations, includi ng financial investigations.  
 A best practice in terms of strengthening efficiency in this area has emerged on 
social reuse of confiscated assets associated with drug crimes allocated to fund 
drug demand and supply reduction measures.  
 
33 The assessment of efficiency was particularly affected by the lack of available data. The 
scarcity of relevant empirical data regarding drugs policy related costs, along with the 
lack of granularity of the available data , made it difficult for the external contractor to 
carry out the analysis of the Strategy and Action Plan’s efficiency.  
The external consultant assessed four groups of costs related to the Strategy and Action 
Plan: (i) public expenditure on drug -related programmes by Member States; (ii) costs of 
key EU agenc ies in the field of drugs; (iii) c osts of internal EU programmes (supporting 
actions within the EU); (iv) costs of external EU programmes (supporting actions outside 
of the EU). Where data was n ot available, the external contractor developed estimates 
and considered stakeholder opinions. For example, data on costs at the national level was 
based on estimates. For most Member States , these estimates were  outdated, and no 
trending data was available. For two Member States, there were  no estimates available at 
all. The main reason for the lack of exact data was that a large portion of the drug policy 
related expenditures are so -called ‘unlabelled’ expenditure s, i.e. expenditure s which are 
part of a broader area, e.g. public health, education, law  enforcement, a nd others.  
An additional challenge was the timing of the costs. The timeframe of national drug 
strategies and action plans do not always coincide with the timeframe of the Strategy. 
EU-funded external programmes were started prior to the launching of the Strategy or 
may continue to operate after 2020. These challenges made it impossible to conclusively 
quantify the costs incurred during the evaluation period as a result of the Strategy and 
Action Plan , and to establish the specific impact of the instrument s. 
There is no conclusive evidence that the results attributed to the Strategy and Action Plan 
have been achieved at either a reasonable  or unreasonable  cost. In terms of public 
expenditures by Member States, which represent the largest share of drug -related costs in 
the EU, estimates could only be made for 26 Member States based on mixed data from 
after and before 2013. Nevertheless, estimates of public expenditure, usually presented as 
a percent of GDP, seem to vary between 0.01% and 0.5% of GDP, with mos t Member 
States falling within the 0.02% to 0.3% range . This would seem to indicate that t he scale 
of the costs that could be associated  on account of the Strategy and Action Plan, appear  
to vary quite extensively . Levels of public spending on drug policy measures can be 
affected by austerity measures and changing priorities (e.g. due to economic slowdown 
or to security concerns triggered by the migration crisis  and terrorist attacks ). A 
significant reduction of public expenditure on drugs in a number of Me mber States was 
recorded especially in the timeframe covered by the first Action Plan under the Strategy . 
Whilst it is impossible to quantify the impact of the Strategy and the Action Plan on 
national spending on drugs, the evaluation revealed that in Memb er States where drugs 
policies were considered to lack funding, the Strategy was used as a supporting tool by 
civil society organisations to justify the need for continued funding, often regarding drug 
demand related measures.  
The distribution of public expenditure between demand and supply reduction efforts56 
varied across Member States. For most however, there seems to be a balance between 
                                                           
56 National costs regarding the other three pillars in the Strategy could not be quantified per each pillar for 
each Member State as such costs were not made available. However, in many cases, the costs covering 
the other three pillars were often integrated u nder demand and supply reduction pillars.   
 
34 spending on demand and supply reduction, in the range of 40/60% – 60/40%. The 
distribution of national funding for the same Member State can also var y in time with 
changing priorities.  
At national level, seven Member States  representatives  indicated that resources were 
declining, while in twelve Member States drug -related resources were reported as stable, 
but there wa s no indication whether they were sufficient or not. Nevertheless, a best 
practice for funding has been identified where the entire amount of confiscated assets 
associated with drug crimes has been dedicated to drug -related actions for both demand 
and supp ly reduction.57 
Among the key EU agencies responsible for a large portion of the actions in the Action 
Plan, namely EMCDDA, Europol and Eurojust, the evaluation raised the question 
whether  the increased hike in the volume of work was in balance with suffici ent 
resources , especially for the first two agencies. EMCDDA58, Europol and CEPOL 
indicated they had not been allocated sufficient resources in line with the obvious hike in 
the volume of work and the higher funds required to address emerging new drugs, new  
supply channels and the seemingly ever -innovative OCGs involved in drugs production 
and trafficking. It was also indicated that public funding for  Reitox National Focal 
Points59 has been declining and was insufficient.  
EU-funded programmes have to a great extent addressed the objectives of drug demand 
and supply reduction pillars. Within the timeframe of the Strategy, relevant projects 
related to demand and harm reduction were included for example under the Health and 
Justice programmes, the latter also fun ding projects related to coordination. Furthermore, 
projects in support of the supply reduction pillar were included under FP7 , Horizon 2020  
such as the ANITA project on advanced tools for fight ing online illegal trafficking or the 
BorderSense project on border detection of illicit drugs and precursors by highly accurate 
electrosensors , and  ISF Police  such as MAOC -N or the Wastewater Analysis of Traces of 
illicit drug -related Chemicals for law enforcement and public Health. .  
The external EU -funded programm es implemented in the evaluation period include d 
COPOLAD, t he Cocaine Route Programme, CADAP 5 and 6 , and the EU -Action against 
Drugs and Organised Crime (EU -ACT) -the former Heroin Route Programme . While all 
these interventions are fully in line with the o bjective to enhance international 
cooperation of the current Strategy and the Action Plans, most of them have been 
initiated before 2013.  
                                                           
57 For example in Spain,  was reported that the entire amount of confiscated assets associated with drug 
crimes is allocated to drugs -related actions (70% to demand reduction and 30% to supply reduction  
measures ).  
58  Based on the evaluation of the EMCDDA that concluded in May 2019 (SWD(2019) 174), the budget 
and number of staff of EMCDDA remained relatively stable  from 2012 -2017, while need ing to 
respond to new challenges and an increasing volume of tasks . These ch allenges have so far been 
managed efficiently by the Agency, as concluded by the evaluation . However, this finding does not 
take into consideration the exponential increase in trends and threats in the drugs policy filed, as 
reported in the EU Drug Markets  Report (November 2019 – by EMCDDA and Europol), and which 
the Agency, along with Europol and CEPOL, is thus also facing.     
59 Reitox National Focal Points are funded by Member States contributions, and in part by EU via the 
EMCDDA budget.   
 
35 There have been no reports on wasteful or inappropriate use of funds dedicated to 
implementing the objectives of the Strategy and the Action Plan. Stakeholders and 
experts consulted did not raise concerns about inefficient use of resources in the drug 
field. However, the efficiency of EU -funded drugs -related development programmes in 
third countries and regions was quest ioned by a limited number of national level 
stakeholders, on grounds of lack of transparency on how much is spent in total for 
international cooperation, and what long -term benefits were observed for the EU from 
these programmes.  
 
5.5 EU Added Value  
Evaluation Question : To what extent have the Strategy and Action Plan achieved EU 
added value as opposed to what could have been achieved at either the national or the 
international level?   
Key findings:  
 The Strategy and Action Plan generated EU added valu e insofar as they  achieved 
results that national or other EU initiatives would not have otherwise achieved.  
 In a field that covers many different areas from health to security, and that has local 
to international impact , the Strategy is an example of a su ccessful consensus 
building tool. It  provided EU added value by creating a common ground (in the 
form of a conceptual and operational f ramework) to present the EU perspective of 
the drug phenomenon and the realm of values, priorities and actions in tacklin g 
drug related challenges faced by Member States . The Strategy also supported the 
monitoring of the drug field at EU level and exchanges of information among 
Member States and international partners.  
 The Strategy and Action Plan played different roles for different stakeholders. At 
national level,  they were used to align national strategies, action plans and other 
relevant national drug policy initiatives . For civil society organisation s, the 
Strategy served as a tool and a reference to demand action at national levels where 
they deemed such action to be needed (e.g. funding for harm reduction or 
treatment) . 
 At EU leve l, the Strategy and Action Plan  supported coordination mechanisms and 
EU level actions . It encouraged cross -border coordination and exch ange of 
information and best practices among Member States and thus created economies 
of scale in terms of synergies and efficiencie s (instead of each Member State  using 
resources for similar or overlapping issues or objectives).  
 The Strategy helped promot e the EU approach to drugs policy with ‘one voice ’ in 
international fora and with third countries .  
 Many of the results of the Strategy and Action Plan would likely not have been 
achieved by Member States acting alone, in particular in terms of cross -border or 
international  aspects . Where some national initiatives might have been able to 
achieve the same or at least similar results , this would only have likely been 
 
36 achieved through longer, costlier and less well -articulated processes.  
 
The Strat egy and Action Plan , and indeed drugs policy , cover  different areas from health 
to security  that ha ve local to international impact . The evaluation found that t he Strategy 
is an example of a successful consensus building tool  in this context . As a conceptual and 
operational framework , both the Strategy and Action Plan provided EU added value by 
creating a common  ground  to present the EU perspective of the drug phenomenon and 
the realm of values, priorities and actions in tackling drug related challe nges faced by 
Member States.  Among others, o ne stakeholder noted that the very existence of the 
Strategy was an inspiring example to other regions and countries in the world that a 
consensus can be reached on such complex and controversial issues as drug d emand and 
supply reduction. The Strategy has served as a ‘common political declaration on drugs 
policy’, providing common ground and a reference document to represent EU’s values 
and priorities as regards to drugs. Most stakeholders representing Member Sta tes shared 
this interpretation of the role of the Strategy: no Member State alone could deliver a 
common strategic framework for a ddressing the drugs phenomenon.   
The impact on coordination was recognised as an EU added value. The expert workshop 
defined this as ‘bridging’ between Member States, between different levels of 
governance, and between researchers and civil society organisation s. Specifically, t he 
role that the Strategy and Action Plan played , differed  among stakeholder groups . At 
national level , they were used to guide common priorities in the field of drugs, and align  
national strategies, action plans and other  relevant drug policy documents.  Overall, the 
Strategy contributed to a process of convergence of national strategies, while certain 
differences remain in the structure and scope of national strategies such as the inclusion 
of other  addictions (e.g. tobacco, alcohol). For civil society organisations, the Strategy 
served as a tool and a reference to demand action at national levels where th ey deemed 
such action to be needed (e.g. funding for drug s harm reduction or treatment).  
At EU level, the Strategy and Action Plan encou raged cross -border coordination, 
exchange of information and best practices among Member States and thus created 
economies of scale in terms of synergies and efficiencies as oppose to  each Member 
States using resources for similar or o verlapping issues or objectives . Based on 
stakeholder consultations and the country -specific data collected, the Strategy  
contributed to establishing a level playing field particularly in the three horizontal pillars, 
namely coordination, cooperation and information exchange, monitoring and evaluation, 
by all owing all Member States to take advantage of common information and 
institutional resources, and by being represented in international fora on drugs. 
Furthermore, the Strategy and the Action Plan  prompted to a large extent actions which 
tackled significant  transnational and cross -border aspects in a number of areas, including 
exchange of best practices in demand and harm reduction; coordinating activities 
targeting drugs trafficking and combating cross -border organised crime (including 
continued interventio ns in third countries and regions, such as Latin America, West 
Africa and Central Asia); cooperation in the area of identifying NPS through the Early 
Warning System and combating their production and trafficking. Several stakeholders 
noted that the drugs p henomenon, and in particular drugs trafficking, is international by 
nature, and it can only be tackled as a cross -border issue.  
 
37 At the international level, t he Strategy helped the EU to promote a balanced, integrated 
and evidence -based approach to drugs with ‘one voice ’. Examples of achievements 
delivered thanks to the Strategy and the Action Plan (as opposed to actions by Member 
States): supported the creation of the Early Warning Systems in third countries; the 
promotion of the EU’s approach as part of the Outcome Document of UNGASS 2016  
and its implement ation, as well as the 2019 UN CND Ministerial Declaration , allowing 
the EU to ‘speak with one voice ’ to influence policy developments in international fora ; 
setting up of quality standards for drug treatment centres in CELAC countries, and 
preparation for the launch of new dialogues on Drugs  with China and Iran , to be chaired 
by the European Commission .  
Moreover, many of the results of the Strategy and Action Plan would likely not have 
been achieved by Member States acting alone, in particular at international level. 
Representatives of some Member States point ed out that due to the Strategy and the 
common EU position they can participate more actively in intern ational dialogues. 
Where national initiatives might have been able to achieve the same or at least similar 
results, this would only have been achieved through longer, costlier and less well -
articulated processes.  
Through the Action Plans, the Strategy has been the impetus for a range of activities, 
many of which have become more consolidated over the years. At the same time, with 
the fast emergence of challenges and trends, new initiatives, sectoral and cross -sectoral , 
have been developed. That is why the e valuation assessed whether the outcomes of the 
Strategy could be sustainable. The analysis showed that for example, the Strategy as a 
common framework for elaborating the EU approach to drugs; EU -wide coordination; 
the created evidence base, updated regula rly by the situational reports and other 
publications by EMCDDA, EUROPOL and other EU agencies; the visibility and 
recognition of the EU evidence -based, balanced and integrated approach to the drugs 
phenomenon among partners and regional and international organisations, could be 
considered sustainable outcomes. It should be noted however that all these benefits are 
sustainable only to a certain extent. They are still dependent on future resources.  
The evaluation also identified several possible negative co nsequences for Member States 
in the absence of the Strategy and Action Plan. Negative effects would likely be mostly 
felt by Member States that have been using the instruments for guidance. Possible 
negative effects could include deviation from the balanced approach to the drugs 
phenomenon to polarize focus on law enforcement aspects or the opposite, on health 
related aspects, or in the case of austerity measures,  cuts in available resources dedicated 
to drug demand or supp ly reduction measures could be more drastic and de -prioritis ation 
of drug policy  from the political agenda.  The ability of Member States to enact 
appropriate measures would be limited. National stakeholders pointed out that one 
consequence would be the lac k of the evidence base, which is currently provided within 
the framework of the Strategy. There would possibly be less cross -border coordination at 
EU level and among Member States. National stakeholders also pointed out that the 
benefits of information ex changes would be lost, and that countries would have to 
organise their own research and testing of solutions for issues that are common to many 
Member States. The most significant damage would be felt in the areas of international 
cooperat ion and monitorin g and research . Stakeholders representatives of Member States,  
international organisations and of civil society organisations agreed that many of the 
results of the 2013 -2019 period could not have been achieved without the Strategy and 
Action Plan .  
 
38  
6. CONCLUSIONS  
The overall objective of the evaluation was to assess  the implementation of the EU Drugs 
Strategy 2013 -2020, and the EU Action Plan on Drugs 2017 -2020 in terms of outputs, 
results and impact s. The evaluation considered their implementation in l ight of 
evaluation questions under the five mandatory evaluation criteria provided in the 
Commission’s Better Regulation Guidelines ( relevance, coherence,  effecti veness, 
efficiency and  EU added value).  
The analytical framework that was developed in order t o evaluate the Strategy and 
Action Plan  was able to overcome a number of limitations, including : a limited baseline 
situation for 2013 to be us ed as a point of comparison; the limited data on drug  policy 
related costs, especially at the national level, alo ng with the lack of granularity of the data 
that was available; and the limited usefulness of drug supply indicators and the delay in 
their reporting . The solutions that were devised in order to overcome these limitations 
ensured that the data that was col lected from a wide range of consulted stakeholders was 
of sound quality and provided a solid basis from which to answer the evaluation 
questions.  
On the basis of the comparison that was made between the baseline situation (described 
in Section 2 .3), the implementation state of play (in Section 3), and feedback from 
stakeholders, the evaluation found that:  
 The evolving threat picture and context in which the Strategy and the Action Plan 
were adopted has changed considerably since 2013. In view of the fast evolving 
drugs phe nomenon, as well as recent technological, soci etal, policy/political and 
environmental developments and the new and emerging challenges that they 
entail, the two instruments only have partial relevance.  
 The Strategy and Action Plan appear  to have remained  broadly consistent with 
relevant European sectoral legislation as well as policy at international level. 
Several complementarities exist. However, the dynamic developments in the 
drugs situation since 2013 (e.g. the criminal patterns of O CGs, and new ways of 
drug consumption) have been weakening the coherence between the Strategy and 
the two major policy fields it covers, namely health and security.  
 The Strategy and Action Plan have been on ly partially effective in achieving the 
two gener al policy  objectives (drug dem and and drug supply reduction). 
Meanwhile, because implementation of the actions under the cross -cutting themes 
made the most progress, the instruments  have been  closer to achieving their three 
general objectives  (i.e. in terms of coordination, international cooperation, and 
information, research, monitoring, and evaluation) . Generally spe aking, it would 
seem that the Strategy did not make significant  contributions  towards achieving 
its planned overall impact to ensure a high level of human health protection, 
social stability and security.   
 The evaluation found no conclusive evidence whether  the results attributed to the 
Strategy and Action Plan have been achieved at a reasonable nor un -reasonable 
cost. The lack of  available quantifiable data regarding drugs policy related costs, 
along with the lack of granularity of the data that was available, made it diffic ult 
to carry out a sound assessment of the efficiency of implement ing the five general 
 
39 objectives. EMCDDA, Europol and CEPOL indicated they had not been allocated 
sufficient resources in line with the hike in the volume of work precipitated by 
emerging new trends in the drugs s ituation. Further to the proportionality of 
allocated costs, civil society organisati ons used the Strategy to point out gaps in 
insufficie ntly funded measures at the national or regional level, and justify 
proposals for continued or increased funding.  
 The Strategy and the Action Plan generated EU added value insofar as they 
achieved result s that national or other EU initiatives would not have achieved.  In 
particular, they established a common strategic framework for actions at the EU, 
national a nd regional levels, ‘bridging’ between Member States, and betwe en 
different levels of governance.  They encouraged cross -border coordination and 
exchange of information and evidence -based best practices among Member States 
and thus created economies of scale in terms of synergies and efficiencie s 
(instead of each Member State  using resources for simila r or overlapping issues 
or objectives). The Strategy helped enhance the position of the EU Member States 
to promote the EU’s approach as ‘one voice ’, while providing a framework for 
engagement with third countries , including  candidate and potential candidate 
countries , regions and international partners, and at multilateral level.   
The evaluation makes clear that the Strategy , a central guiding model  in EU drugs policy , 
has played an important role in bringing attention to a wide array of areas and needs 
related to drug demand and drug supply, and it sparked a considerable amount of 
progress aimed at enhancing coordination, strengthening international cooperation, and 
contributing to better dissemination of monitoring, research and evalu ation results  in the 
drugs field.  
Even though overall, all areas addressed by the instruments remain pertinent, new trends 
and threats have emerged.  Examples include the increased poly -criminality of OCGs and 
their adaptive and innovative modus operandi , the increased role of the EU as a producer 
and exporter , the increased levels of violence and corruption that enable the drug trade, 
the new patterns of drug consumption between young people and the aging population of 
drug users in Europe, as well as detrimental  effects of the drugs phenomenon  on the 
environment . The direct and indirect consequences of the drugs situation are becoming 
more complex and intertwined, extend across different sectors, go beyond Europe’s 
borders, and need to be accounted for in addressing the level of health and security of 
Europeans in the years to come. This could mean closer synergies and further integration 
with EU level security challenges as well as relevant health -related topics to better 
achieve the Strategy’s two policy general objectives and overall impact.  
The evidence collected during the evaluation indicated that the lack of prioritization of 
the topics covered by the instruments,  limits the value of the broad coverage of issues. 
From a practical perspective, priorit isation of actions has been seen as necessary in view 
of the limited resources available . Therefore, the structure of the Strategy and Action 
Plan could be overall revisited to be  made more concrete  and focused and in this way, 
accentuate the issues that should be priorit ised according to current as well as fast -
emerging  needs. In this context, the Strategy’s current lifespan  of 8 years could be shifted 
to a shorter one , especially given the dynamic nature of the drugs policy area.  
The consultations with stakeholders that were carried out as part of the evaluation 
suggest that there is continued support on the part of Member States and other 
stakeholders such as civil society organisations for  strategic EU involvemen t in drugs  
 
40 policy. While opinions on the matter varied, the outright discontinuation  of the Strategy  
was seen by Member States and civil society  as likely to have negative effects .  
 
 
41 ANNEX I: INTERVENTION LOGIC  TABLE    
Intervention logic of the EU Drugs Strategy and consecutive Action Plans60 
                                                           
60 See Annex 12  in ICF (2020),  Evaluation study of the EU Drugs Strategy 2013 -2020 and EU Action Plan on Drugs 2017 -2020.  

 
42 ANNEX II: PROCEDURAL INFORMATION  
1. Lead DG and Decide Planning  
The Evaluation Roadmap for the initiative was published by DG Migration and Home 
Affairs (DG HOME) on the Commission’s ‘Have your say’ webpage61 in November  
2018. The Terms of Reference for engaging a contractor to carry out the external study as 
part of the ev aluation were drawn up starting later in the spring of the same year . A 
request for service was issued on 15 February 2019, and a contractor selected by an 
evaluation committee consisting of staff from DG HOME later during the spring.62 The 
study commenced in June 2019 and ended in May 2020. The  agenda planning (Decide) 
reference assigned to the evaluation is PLAN/2018/ 4584 . 
2. Organisation and timing  
As per the Better Regulation Guidelines, an inter -service steering group was set up 
within the Commission to  oversee the evaluation. Several Directorates -General (DGs) 
within the Commission63 and the European External Action Service (EEAS) were invited 
to nominate representatives to the steering group.  
The meetings of the steering group were chaired by DG Migrati on and Home Affairs 
(HOME). The steering group was regularly consulted over the course of the evaluation, 
typically in conjunction with the submission of specific draft reports by the contractor 
responsible for carrying out the external study. These consul tations took place in the 
context of regular mee tings, via email and telephone.  The steering group was convened 
to meet at every milestone of the evaluation in order to receive information and provide 
feedback ( meeting on the inception report  in August 201 9, meeting on the interim report 
in November 2019, and meeting on the final report  in March 2020). Input on the draft 
reports and final report was also provided by email before and after the meeting.  
The steering committee was also consulted and invited t o provide feedback by email and 
telephone on relevant steps in the evaluation starting with the Terms of Reference for the 
external study ; the Stakeholder Consultation Strategy  which described how the 
Commission intended to consult with different stakehold er groups in the context of the 
evaluation ; templates related to stakeholder consultation activities and other research 
tools (public consultation questionnaire, interview questionnaire, case studies templates). 
The steering group was consulted during the drafting of this staff working document.  The 
                                                           
61 The Roadmap is published via the following link: https://ec.europa.eu/info/law/better -regulation/have -
your-say/initiatives/1980 -Evaluation -of-the-EU-Drugs -Strategy -2013-2020   
62 The call for service was issued via framework contract HOME/2015/EVAL/02. Two contractors 
submitted bids to carry out the evaluation. The evaluation committee considered a number of criteria 
in selecting a winning bid, namely: compliance with th e technical specifications described in the 
Terms of Reference; demonstrated understanding of the objectives and tasks; the quality of the 
preliminary assessment of difficulties and expected results; the quality of the proposed methodology; 
and the quality  of the project management and team organisation. The Commission ultimately awarded 
the contract to ICF.  
63 The DGs invited to participate in the steering group included: the Secretariat -General of the Commission 
(SG); Legal Service (LS); Human Resources (H R); Budget (BUDG); Justice and Consumers (JUST); 
International Cooperation and Development (DEVCO); Mobility and Transport (MOVE); Internal 
Market, Industry, Entrepreneurshi p and SMEs (GROW); Taxation and Customs Union (TAXUD); 
Health and Food Safety (SANT E); Neighbourhood and Enlargement Negotiations (NEAR); Maritime 
Affairs and Fisheries (MARE); Trade (TRADE); Agriculture and Rural Development (AGRI); 
Research and Innovation (RTD); and the Joint Research Centre (JRC).  
 
43 evaluation was extended given the fact that the public consultation was launched later 
than initially anticipated. This decision was made out of respect for the Better Regulation 
Guidelines and in order to allow  the contractor adequate time to account for all responses 
to the Consultation (which ended on 4 February 20 20. In practical terms, this led to the 
postponement of the delivery of the contractor’s draft Final Report in March 2020 and 
Final Report in May 20 20. 
3. Exceptions from the Better Regulation Guidelines  
In conducting the evaluation, no exceptions from the usual procedural requirements 
described in the Better Regulation Guidelines were required.  
4. Evidence, sources and quality  
The evaluation drew on different types of documents at EU, international and national 
level, respectively. Documents at the EU level provided indications as to the nature and 
scope of EU policy in the field of drugs and organised crime, as well as security , health, 
precursors and cooperation . Particular attention was paid to relevant  legislation, other 
initiatives and developments in the sectors covered by the Strategy. At internatio nal 
level, documents were reviewed describing international initiatives and developments 
relating to drugs policy  and those where the EU has influence. Finally, at the national 
level,  documents of relevance included  national drug strategies, action plans and 
legislative measures that in one way or another were relevant to the EU approach to 
drugs as illustrated by the Strategy or relevant in implementing the actions  contained in 
the Action Plan .  
In addition to the review of relevant documents, the evaluation also relied on extensive 
consultations with a wide range of stakeholders . These consultations served as 
opportunities to collect new data , fill gaps or confirm the validity of already collected 
data. Additional information concerning the stakeholder consultations is provided in 
Annex II I. 
5. External expertise  
The evaluation d rew on a number of external experts. Besides subject matter experts at 
Member State level, civil society  were also consulted  along with international 
organisations . Some of the respondents to the public consultation also possess ed expert 
competence.  
 
 
 
 
 
 
 
 
44 ANNEX III: SYNOPSIS REPORT OF TH E STAKEHOLDER CONSUL TATION  
1. Introduction  
1.1 Overview of stakeholder consultations  
A broad range of stakeholder consultations were carried out as part of the evaluation of 
the EU Drugs Strategy 2013 -2020 and EU Action P lan on Drugs 2017 -2020 . The aim of 
the consultations was to gather different views that could be useful in answering the 
evaluation questions concerning the relevance, coher ence, effectiveness, efficiency and  
EU added value of the instruments . 
This synopsis report aims to describe and summarise the consultation activities carried 
out during the evaluation period and the results.  
1.2 Methodology  
The evaluation involved a number of different types of broad -based and targeted 
consultations on the implementation of the instruments  as part of t he evaluation itself.  
However, no input was received on the Evaluation Roadmap .  
The nature and scope of the consultations were guided by a Stakeholder Consultation 
Strategy, which was approved by an inter -service steering group established by the 
Commission to oversee the evaluation. Th e Consultation Strategy served to identify key 
stakeholder groups  within a consultation methodology developed to most effectively 
reach these different groups .  
Specific details concerning the methodology used in consulting different stakeholders at 
different points during the evaluation are provided in subsequent sections, along with the 
results and findings.  
1.3 Consulted stakeholder groups  
The key stakeholder groups ide ntified in the Stakeholder Consultation Strategy include:  
Member States competent authorities at the national, regional and local levels; civil 
society organisations including those that are members of the Civil Society Forum on 
Drugs; academia and researc hers; practitioners involved in the drugs or health policy 
fields; chemical and medical industry representatives; the general public; and, the 
relevant Directorate s-General within the Commission, EU agencies and the European 
External Action Service (EEAS).  International organisations and relevant stakeholders 
from third countries were also consulted when looking at the international cooperation 
pillar  of the Strategy . (See Table 3 that shows how many and what type of stakeholders 
were reached through main  consultation too ls). All stakeholder groups were contacted 
and consulted.  In addition, the external consultant contacted multiple times  
pharmaceutical industry representatives with requests for an interview  but received no  
respon se. 
 
 
 
45 Table 3. Overview of consulted stakeholders64 
 Interviews65 Public 
Consultation  Online survey  Workshop with 
civil society  
Horizontal Working 
Group on Drugs 
(HDG)/National Drug 
Coordinators (NDC)66  43 
 
 
  
 
 9 
  
Other national 
authorities67 23  8  
EU Agencies  6    
EU Inst. & EEAS  15  10  
EU-funded programme  5  5  
Civil Society O rgs.68 9 51  10 
Chemical and 
pharmaceutical industry  2 1   
Int. organisations  9    
Academic/research 
institutions   18   
Business association   3   
Consumer organisation   4   
EU Citizens   378   
Non-EU Citizens   2   
Public authorities   34   
Other   13   
TOTAL  112 504 39 10 
 
 
 
                                                           
64 ICF (2020).  Evaluation study of the  EU Drugs Strategy 2013 -2020 and EU Action Plan on Drugs 2017 -
2020.  
65 This column also includes the interviews conducted for the case studies. The figures reflect the number 
of interviews and not the number of people interviewed. In some cases, several rep resentatives were 
interviewed within the same interview.  
66 HDG representatives and NDCs are in some cases the same person. They were interviewed once and 
their views from the two points of view were gathered in the same interview.   
67 In support of the pr eparation of eight country case studies, additional national authorities were consulted 
via interviews. These included law enforcement authorities, prison authorities and civil society.  
68 Different types of civil society organisations were consulted durin g the interview process including 
representatives of drug users (general drug users, women drug users and recreational drug users), an 
NGO representing professionals working to provide healthcare to drug users, an NGO representing 
young people with drug ad diction and an NGO representing a network of NGOs advocating for better 
drug policies.   
 
46 2. Targeted  stakeholder consultation s 
 2.1 Consultation methods/tools  
Online survey : The online survey was launched on 18 December 2019 via the European 
Commission’s EU Survey platform, and it closed on the 4 February 2020. This survey 
complemented the PC, further focussing on questions about relevance , coherence, 
effectiveness  and EU added value. It targeted four types of stakeholders: (1) Reitox 
National Focal Points (N FP), (2) Regional and local authorities in the field of drugs, (3) 
EU Delegations, and (4) Project beneficiaries of EU -funds (e.g. H2020, FP7, DPIP 
Justice Programme). The survey received 39 responses.  
Interviews : As outlined in Table 3, the external consultant  carried out interviews with 
112 key stakeholders (138 stakeholder representatives in total)  at EU, national and 
international level . These interviews were conducted face -to-face or by phone, depending 
on the location and availability of the inte rviewee s, and covered  all evaluation criteria. 
For 22 interview requests across stakeholder groups the external consultant  either 
received a rejection or no response.  
The figures in Table 3 also include interviews conducted regarding  the eight country case  
studies, namely Bulgaria, Estonia, Finland, France, Germany, Netherlands, Poland and 
Spain. The country case study interviews focussed on the implementation of selected 
actions of the Action Plan , namely prevention and awareness raising (actions 1,  2 and 4), 
drug treatment and rehabilitation (actions 6,  7 and 9), drug supply reduction (actions 14,  
15 and 16) and coordination (action 30).  The same questionnaire was used across all 
interviews with Member States  representatives . Interviews were conducted with  14 
HDG/NDC representatives, 4 law enforcement  representatives , 4 penitentiary authorities 
and 2 relevant Ministr y of Justice  representatives .  
Workshop with civil society stakeholders : A workshop was held with the Civil Society 
Forum on Drugs (CSFD) on 5 December 2019. The goal of the workshop was to capture  
the expertise, perspective and level of involvement of civil society organisations 
regarding  implementation and monitoring of the Strategy  and Action P lan. The workshop 
was attended by 10 participants and lasted 2.5 hours with one 10 -minute break. The 10 
participants represented a range of civil society , either operating at the EU, international 
level or from  Member States:  Spain, Hungary, France and Cze chia. The particip ating  
civil society organisations  represent ed the interests of youth, AIDS -patients and others 
covering drugs in their wider work on human rights and working with vulnerable people. 
This was complemented by aforementioned one -on-one interviews with civil society  and 
a position paper sent by the CSFD to the external consultant . 
Expert meeting : The external consultant  convened an expert validation meeting with 
four academic experts and two representatives of the European Commission. The 
meeting was held on 20 February 2020 on ICF premises and was organis ed to discuss the 
preliminary conclusions and findings of the external study .  
2.2 Findings  
2.2.1  The European Commission, the European External Action Service, and EU 
Agencies  
 
47 A total of 26 stakeholders representing different Directorate General (DGs) wi thin the 
European Commission, the European External Action Service, EU -funded projects and 
programmes ( CRIMJUST, CADAP, Cocaine Route programme, COPOLAD I and II) 
and EU Agencies  and bodies  (EMCDDA, Europol, MAOC -N, CEPOL, Frontex , EMA 
and CHAFEA) were consulted as part of the assessment through interviews and the 
online survey.  
Relevance : Through the interviews, the majority of EU stak eholders highlighted that the  
Strategy and Action Plan contributed to improved coordination by solidifying a platform 
to discuss common problems and a convergence in a European approach on drugs. EU 
stakeholders agreed that the Strategy and Action Plan are relevant documents in guiding 
Member States, especially smaller ones, and avoiding duplication and inconsistencies 
across work on drugs. This stakeholder group stressed that the promotion of a balanced 
approach to drug demand and supply reduction was a highly relevant aspect of the 
Strategy.  
Coherence : Most stakehold ers specified that the Strategy is reasonably well connec ted 
with EU strategic planning tools such as the EU policy cycle. EU stakeholders however 
highlighted some room for improvement with coherence with EU strategies on health and 
security, such as by including direct links and cross -references. Here, stakehol ders also 
highlighted that there could be further coherence between the work of the HDG and other 
Council Working Parties.  
Effectiveness:  EU stakeholders agreed that the Strategy prompted coordination and 
cooperation between EU actors. Here, stakeholders underlined that the Strategy has been 
most effective in bringing together relevant stakeholders at the EU, Member State and 
civil society levels and fostering consensus -building and trust. Additionally, EU 
stakeholders noted that the Strategy has been effective in making the European approach 
on drugs visible and a leading example on the international stage. Nonetheless, 
stakeholders highlig hted the fragmented  implementation across Member States and that 
not enough scientific research is being used to detect new substances.  
EU Added Value  for EU stakeholders was the Strategy’s ability to fine-tune a European 
approach to drugs policy, which br ought cohesion across the EU but also made the EU 
position at the UN and with third countries clear. Indeed, EU stakeholders underlined that 
drugs is a cross -border issue, thus one that Member States cannot tackle alone and 
warrants EU -level strategic dire ction . Another added value of the Strategy suggested by 
EU stakeholders was that it has prompted debates in certain countries that may not have 
arisen if it were not for the cooperation with other Member States.  
2.2.2  Member States  
Stakeholders at the Member State level were consulted through interviews, the online 
survey, and the public consultation. The three main groups at Member State level that 
were the subject of targeted consultations included: National Drug Coordinators (NDCs ), 
Reitox  NFPs, and national and regional authorities.  
Relevance:  Interviews with Member State authorities outlined that the Strategy and 
Action Plan were relevant documents, in their acknowledgement that the drug 
phenomenon is a cross -border issue that re quires a multidisciplinary response. 
Interviewees also argued that the documents continue to satisfy the need for streamlining 
drug policy across Member States. National authorities pointed out that the Strategy is 
 
48 comprehensive and broad, yet its long -time span of seven years means it does not reflect 
the rapidly evolving drug market s. Stakeholders highlighted trends in the field of drugs 
that need to be addressed such as  darknet, cryptocurrenc ies and access to information and 
treatment for migrant  populat ions. The Strategy and the Action Plan are perceived as 
highly relevant by respondents to the online survey. A majority of this stakeholder group 
report that the Strategy and the Action Plan addressed the needs of their organisation to 
some or to a great e xtent. Almost all NFPs and authorities answered that there were no 
other needs and challenges that have not been addressed in the Strategy.  
Coherence : Interviews with national stakeholders revealed differing patterns of 
coherence across Member States. Ind eed, whilst some Member States used the Strategy 
and Action Plan to formulate their own national drug policy documents, others chose to 
create national strategies that significantly diverge from them . Additionally, some 
national stakeholders revealed that they feel their national strategies go beyond the 
Strategy . Notwithstanding, Member States highlighted the value of coherence in research 
efforts brought by the Strategy.  
Effectiveness : Interviews with national authorities reflected a heterogeneous picture of 
effectiveness of the Strategy and Action Plan across the EU Member States.  The majority 
of stakeholders highlighted that legislation on NPS, the HDG and dialogues with third 
countri es were particularly successful elements of the Strategy. Indeed, national 
authorities emphasised that the strategic documents significantly improved coordination 
and cooperation between EU Member States, not only through the HDG but also 
bolstering other avenues of communication such as the EMCDDA, Reitox and other 
networks. Internal coordination was not as successful in all Member States, as 
stakeholders underlined that for some Member States this was far easier to implement 
than others due to their insti tutional structures.  
Efficiency : National authorities had differing accounts of financial and human resources 
in their respective Member States on drugs policy. Most national authorities underlined 
that exact figures were difficult to obtain, especially f or Member States with federal 
structures. Some national stakeholders argued they would like the EU to provide 
guidance on distribution of financial and human resources for specific actions in the 
Action Plan .  
EU Added Value : National stakeholders agreed t hat the documents facilitated 
cooperation between Member States on cross -border issues, especially on the issue of 
NPS. The interviews also revealed that the documents were instrumental in facilitating  
dialogues with third countries . National stakeholde rs also pointed out that the Strategy 
has built a framework for consensus -building, facilitating exchange of best practice s and 
information -sharing.  
A majority of respondents to the online survey agree or strongly agree with the 
statements that the Strategy and Action Plan have had a positive impact on national and 
regional actions of Member States in the field of illicit drugs and on national drug 
strategies and action plans of candid ate and neighbouring countries. A short majority of 
respondents agree or strongly agree that the Strategy and the Action Plan have had a 
positive impact on national drug  strategies and action plans of other third countries . 
2.2.3  Civil society organisations  
 
49 Civil society stakeholders were consulted through interviews, the public consultation and 
a dedicated workshop. The nine stakeholders interviewed represented different relevant 
areas and target populations in drugs polic y, including drug users, youth, addiction, 
human rights and public health.  
Regarding relevance , civil society  representatives underlined that they would like  to see  
health and social inclusion initiatives  as higher priorities . Civil society  representatives 
nonetheless underlined that the Strategy and Action Plan  have been vital, but could do 
more to promote the voices of drug users.   
Coherence : Civil society stakeholders agreed that achieving policy coherence in both 
internal and external as pects of EU drugs policy has been successful while noting that 
more can be done to ensure the balanced approach to drug demand and supply reduction 
in relation to Member State and EU budgets.  
Effectiveness:  Interviews revealed that coordination and the in clusion of civil society in 
policy debates has significantly improved. Stakeholders also underlined that the Strategy 
has been key in improving research in the field of drugs, making the EU a leading 
example. It was  however highlighted the need for more emphasis on alternatives to 
coercive sanctions in future strategic documents.  
EU added value : Stakeholders argued that the Strategy is a useful document for non-
governmental  and civil society  organisations  across the EU to argue for issues mentioned 
above .  
2.2.4  Civil Society Forum on Drugs  
In addition to the targeted interviews with civil society  representatives, ten CSFD 
representatives were consulted to deepen understanding of civil society involvement in 
EU drugs policy in a workshop. Additionally, the CSFD also submitted a positio n paper .  
Relevance : Throughout the workshop and position paper,  CSFD representatives 
highlighted that whilst the need for the Strategy has not changed, the possible future 
strategic document should include more  links to other EU policy aspects (health, gender, 
security, development, human rights) and should strongly p romote civil society 
engagement in policy design, implementation and monitoring. CSFD representatives also 
underlined the necessity of a m ore meaningful engagement with civil society  
representing drug users. Throughout the workshop, participants underlined  the improved 
cooperation between NGOs and the EU, the Strategy as a strong advocacy tool and its 
positive higher emphasis on harm reduction.  
Effectiveness : CSFD representatives highlighted the varying levels of inclusion of civil 
society  in the policy making process at EU level . Workshop participants emphasised that 
the Strategy and Action Plan formalised cooperation between civil society and 
policymakers and acted as effective tools for civil society to advocate at national level  for 
the EU approach  on drugs policy. Moreover, participants underlined that potential 
improvements to amplify the documents’ effectiveness include a more comprehensive 
understanding of drug demand reduction, especially of vulnerable groups to target for 
harm reduction measures.  
 
50 On efficiency , CSFD representatives shed light on budget cuts to harm reduction services 
in several Member States and alerted to ensure that EU funds will remain available to 
NGOs working in the field of demand reduction.  
EU Added Value : Consultations wit h the CSFD revealed that stakeholders believe t he 
Strategy and Action Plan significantly improved coordination between EU, national and 
civil society stakeholders. The CSFD argued that without the Strategy,  drugs policy 
across the EU, and globally due to the EU’s influence  in the  UNGASS  document , would 
be less focussed on evidence, data collection, human rights and health.  
2.2.5  International organisations  and bodies  
A total of nine stakeholders representing  different international organisations  and bodies  
(UNAIDS, UNODC, WHO, CICAD, Interpol, African Union and Pompidou Group) 
were consulted as part of the study through targeted interviews, two of which (UNODC 
and WHO) also submitted position papers to consol idate their contribution to the study.  
Relevance : Stakeholders from international organisations agreed that the Strategy and 
Action Plan recognise the importance of shared responsibility over the drug problem . The 
position papers submitted as part of the  PC underlined other aspects  to focus on, 
including incorporating a gender -sensitive and environmental dimension and a larger 
focus on cooperation with third countries, particularly suggesting the concrete 
involvement of African, Caribbean and Pacific stat es. 
Coherence : International stakeholders argued that the Strategy and Action Plan fit well 
in the EU and international landscape, showing strong coherence with the African Union 
Action Plan on Drugs and the Pompidou Group and UN’s work. However, the posit ion 
papers emphasised how a larger focus on human rights  could be included , such as by 
ensuring compliance of treatment services for drug use disorders with human rights 
obligations.   
Effectiveness : International stakeholders underlined the significance of  the Strategy in its 
impact on the UNGASS document and honing a ‘European approach’ on drugs policy, 
recognised internationally. However, stakeholders noted that its impact whilst felt very 
significant in Latin American countries, is limited across the Afr ican continent. 
Additionally, the two position papers submitted by UN Agencies  included 
recommendations with regards to effectiveness, including for demand reduction to 
include gender -inclusive targeted prevention campaigns, the removal of barriers to 
accessing harm reduction and health services such as discrimination and stigma. 
Additionally, regarding supply reduction , the position papers suggested that success 
should be measured in amount of dismantled drug trafficking groups  and transnational 
organised criminal groups, rather than drugs seized.  
EU-added value : Interviews with international stakeholders revealed that the Strategy  
and Action Plan facilitate high -level dialogue with the EU due to the more homogenised 
approach to drugs policy across Member States. Stakeholders also underlined that a lot of 
the progress seen on synthetic drugs and opioids comes from the EU’s strong work on 
the matter, showing the EU’s leading work on drugs. Indeed, stakeholders claimed that 
other regions also consult t he Strategy as a guiding policy document.  
2.2.6  Academic experts  
 
51 The expert workshop included consultation with four academic experts for validation of 
the research conducted by the external consultant and expertise on recommendations.  
Coherence : The acad emic experts underlined the necessity for a more structural 
connection between the Pompidou Group and the HDG. Additionally, participants of the 
expert meetings underlined that the tasks of the Pompidou Group in comparison to those 
of EU bodies in the fiel d should be clarified.   
Regarding effectiveness , the academic experts underlined that there could be better, more 
concrete and measurable indicators, especially on the supply side. Additionally, the 
academic experts underlined that some clarifications should  be made such as:  there is not 
one but many drug markets with varying intern al and external dynamics . Also, more 
focus is needed on registration and reporting of drug law offences, with a stronger 
differentiation between drug supply and demand by law  enforcement authorities. Lastly, 
the academic expert meeting included discussions on including a better overview of 
national and EU -level funding, a lower threshold for civil society for EU funding, and a 
roadmap for the dissemination of data and research . 
Efficiency : Throughout the academic expert meeting, participants highlighted the 
difficulties in assessing efficiency, for example, due to the challenges faced by those  
collecting data on drugs -related budget s, the limitations  of only using ear -marked da ta 
when analysing efficiency and the lack of impact studies.  
2.2.7  Chemical and pha rmaceutical industries  
Consultations with chemical and pharmaceutical industries consisted of targeted 
interviews with two stakeholders and contributions to the public consultation. The 
smaller number of stakeholders interviewed has resulted in a more concise consultation 
synopsis than for other stakeholder groups.  
Industry representatives focussed primarily on the Strategy’s work on drug precursors, 
arguing that this is  very relevant to their work and has led effect ive cross -EU work on the 
issue. Additionally, stakeholders underlined the need for opioid use disorder to be 
recognised as a medical condition.  
Moreover, regarding coherence , industry representatives argued th at the EU’s work on 
drug precursors as outlined in the Strategy , strengthened and complemented their work.  
On EU-added v alue industry stakeholders argued that the documents helped homogenise 
EU approaches to drug precursors, which is especially useful for  multinational 
companies dealing with multiple Member States . 
3. Public consultation  
3.1 Summary  
The public consultation was open to all citizens and stakeholders, and collected views 
covering four of the five evaluation criteria, namely effectiveness, coherence, relevance 
and EU added value. It was launched online on 12 November 2019 and was open for 12 
weeks until 4 Februa ry 2020. It was published on the European Commission’s ‘Have 
your say’ webpage and was available in all official languages of the EU. It received 
contributions from 504 respondents, ranging from private individuals to representatives 
 
52 of NGOs and public aut horities. Additionally, three position papers were submitted to the 
Commission as part of the PC from international and industry stakeholders.  
Of the 378 responses submitted by EU citizens, 287 (76%) were submitted by German 
citizens, with similar response s pointing to the legalisation of the use of cannabis. Almost 
all of these responses (267 or 93%) were submitted in three days of each other between 
14-16 January 2020. Prior to that date , there were only two responses from German 
citizens. This suggests t hat it is likely that the participation in the PC from this group was 
inspired by a local campaign to legalise the use of cannabis. As these replies were similar 
but not identical, they were  nonetheless  included in the analysis of the PC.   
The findings of the public consultation should be taken into consideration within the 
limitation that the majority of respondents indicated that they do not have detailed 
knowledge of the Strategy nor the Action Plan . 
3.2 Findings  
Overall, the respondents to the PC found the Strategy to be limited  in relevance . The 
dominant opinion was that the Strategy addresses only to some extent or does not address 
at all the ten challenges and needs identified in Strategy. Only a minority of re spondents 
indicated that the Strategy has addressed to a great extent seven of the ten challenges and 
needs. About half of the respondents said that there are other drug -related challenges that 
their organisation/Member State are facing that are not reflec ted in the current Strategy. 
Other challenges mention ed include  the need for a greater foc us on harm reduction 
among drug  users, the need to react faster to new synthetic drugs coming to the market , 
and the effects of the criminalisation of cannabis .  
In contrast to the aggregate results, public authorities and academic institutions 
contributing to the PC found the Strategy to be highly relevant.  
Coherence : A greater share of respondents to the PC disagrees than agrees wit h the 
statements that the Strategy  complements the actions of national initiatives in the 
respondent’s Member State, the actions of other EU -level programmes and initiatives, 
and EU external actions. Public authorities, NGOs and academic institutions have a more 
positive outlook on the com plementarity of the Strategy than EU citizens. National 
ministries and authorities have a more positive outlook on the complementarity of the 
Strategy than regional authorities. A greater share of respondents agrees that there is 
overlap with the objective s of national instruments and programmes (34%) and the 
objectives of other EU -level instruments and programmes (24%) . About a third of 
respondents tend to agree that the objectives and activities of the Strategy are in line with 
the drugs related objective s and activities of EMCDDA, Europol and the ECDC. Opinion 
is almost equally split on the alignment of the Strategy with the EMA. International 
stakeholders in a position paper submitted to the PC emphasised how the future EU 
strategic document on drugs  must place a larger focus on human rights.  
As for effectiveness , the majority of respondents to the PC disagree that the five key 
objectives of the Strategy have been achieved. Only a minority of respondents agree or 
strongly agree that the implementation of the Action Plan has contributed to its 15 
objectives.  
Efficiency : About half of the respondents to the PC disagree or strongly disagree with 
the statements that the Strategy and the Action Plan provided for adequate distribution of 
 
53 funding for activities i n the field of drugs and drugs addictions at national level and that 
considering the costs of the actions and the archived results, the benefits outweigh the 
costs. A short majority disagree or strongly disagree with the statement that the activities 
outlined in the Strategy and its Action Plan in the field of drugs and drug addictions 
received sufficient funding. International stakeholders in the position papers submitted to 
the PC also underlined that the EU must ensure a drugs responsive and cost -efficie nt 
budgeting for internal and external actions in the next EU budgetary cycle.  
EU Added Value : A majority of respondents indicate that the Strategy and the Action 
Plan did not contribute to providing effective EU response to drugs challenges. At the 
same t ime, however, large majorities of respondents tend to agree that EU support is 
required to encourage coordination through active discourse and analysis of 
developments and challenges in the field of drugs at the EU and international level, to 
further stren gthen dialogue and cooperation between the EU and third countries, 
international organisations and fora on drugs issues, and to achieve better dissemination 
of monitoring, research and assessment results and a better understanding of all aspects 
of illicit  drugs. In contrast to the aggregate results, greater shares of public authorities, 
NGOs and academic institutions tend to see more EU added value.  
4. Conclusions based on the outcomes of the consultations  
The findings from the targeted consultation activities demonstrate that stakeholders who 
are closely involved with the Strategy and the Action Plan (i.e. EU and national public 
authorities, relevant civil society groups and industries) find the EU policy documents to 
be relevant, coherent with other  EU and MS level legislation and initiatives, effective and 
efficient. The Strategy helped avoid duplica tion and inconsistencies , was effective in 
making the European approach on drugs visible and a leading example internationally, 
and improved coordinatio n and cooperation between EU Member States. The key EU 
added value of the Strategy is the promotion of cooperation between Member States on 
cross -border issues, especially on the issue of new psychoactive substances and the 
framework created for consensus -building, facilitating best practice and information -
sharing. Some of the negative feedback received related to for example, the lack of 
financial and human resources to implement the Strategy.  
In contrast, the findings from the public consultation – open to a broader set of 
stakeholders – were less positive.  The majority of respondents did not find the Strategy 
and the Action Plan relevant, effective, efficient and coherent. It should be noted, 
however, that the majority of respondents indicated that they  do not have detailed 
knowledge of the instruments .  
5. Feedback to stakeholders  
The Commission is involved in a number of activities aimed at providing feedback to the 
stakeholders that were consulted as part of the evaluation. One of the primary target 
groups is the Member States representatives . The contractor responsible for carrying out 
the external study provided a summary of their findings  for example regarding the 
country fiches and case studies , to which the Member States representatives were offered 
the opportunity to respond. Other follow -up activities  may be organised  by other 
Directorates -General within the Commission, as well as the relevant networks . 
Furthermore, a Synopsys  Report of the responses to the public consultation will be 
published on the Commission’s website.  
 
54  
ANNEX IV: METHODS AND ANALYTICA L TOOLS  
In this annex, the methods and sources that were drawn upon in carrying out the 
evaluation are described, as well as the limit ations that were encountered.  
A range of methodological tools and techniques were included in t he analytical 
framework that were  developed during the preparatory phase of the study. This contained 
both desk and field research involving interviews, online surveys, workshops, and case 
studies targe ting a wide range of stakeholders. The external consultant  also made use of 
the results of the public consultation, which was open from 12 November 2019 until 4 
February 2020 .  
The field research is described in detail in Annex III.  It should be noted that limitations 
related to data collection have already been detailed in section 4.2 Limitations and 
robustness of findings.  
Desk research  
As part of the desk research, a systematic mapping, collection and analysis of relevant 
sources  was carried out, including academic literature, and policy, legislative and other 
documents published at EU, national and international level. The relevant sources for the 
evaluation were classified as follows:  
 EU policy documents;  
 EU legislative docume nts; 
 EU reports and communications;  
 National drugs strategies and action plans and other documents;  
 International reports;  
 Web-based sources;  
 Academic publications.  
Additionally, a briefing note from the EMCDDA (referred to as the ‘EMCDD A 
contribution’ ) was developed by the Agency for the purpose of the evaluation, giving an 
overview of relevant data for the indicators listed under each action as well as an 
overview of relevant data and (to some extent) trends for the overarching indicators.  
Generally speaking, much of the desk research described above was completed at the 
first stage of the evaluation. The review of pertinent  sources enabled the extract ion of  all 
the rele vant evidence for each of the evaluation questions (which has been triangulated 
with the data collected through field research  in order to answer the evaluation questions , 
which finally, are  listed in Annex V ).  
 
 
 
 
  
 
55 ANNEX V: EVALUATION CRITERIA A ND QUESTION S 
In accordance with the Commission’s Better Regulation Guidelines, the evaluation’s 
overall objective was to assess the relevance, coherence , effectiveness, efficiency  and EU 
added value of the Strategy and Action Plan in EU-28. International aspe cts relevant to 
the EU and cover ed by the Strategy and Action Plan were also evaluated. In achieving 
this aim, a number of specific evaluation questions related to the different evaluation 
criteria were developed and are listed below.  For clarity and simplicity, the evaluation 
questions were grouped together under each criteria in the analysis section (see section 5 
Analysis and answers to the evaluation questions).  
 
Evaluation question on e ffectiveness : To what extent have the Strateg y and Action 
Plan been effective in delivering intended results?  
EQ69 1. To what extent have the general objectives of the EU Drugs Strategy and the EU 
Action Plan on Drugs 2017 -2020 been met? To what extent is the progress/ lack of 
progress towards the gen eral objectives linked to the strategy?  
EQ 2. To what extent have the operational and specific objectives of the Strategy and the 
Action Plan been met in the five pillars? In particular, what have been the results and 
impacts (both quantitative and qualitative) of the actions on drug demand reduction , drug 
supply reduction, coordination, international cooperation and information, research, 
monitoring and evaluation?  
EQ 3. What factors have hindered and facilitated the achievement of the Strategy and 
Action Plan objectives? What was the influence of ex ternal factors on the effectiveness 
of the implementation?  
 
Evaluation question on efficiency: To what extent have the Strategy and Action 
Plan achieved intended results in the most efficient manner?  
EQ 4. What are the benefits of the EU Drugs Strategy and  the Action Plan on Drugs 
2017 -2020 and costs generated? To what extent have they been cost -effective?  
EQ 5. What are the factors that have influenced the efficiency of the Strategy and the 
Action Plan?  
EQ 6. To what extent have the Strategy and the Action Plan had an impact on the 
Member States' budgetary resources and to what extent are these costs proportionate 
given the associated benefits?  
EQ 7. To what extent have the resources allocated throughout the y ears been relevant for 
reaching the general objectives of the Strategy and the Action Plan?  
EQ 8. Could the results delivered through the implementation of the Strategy and Action 
Plan have been achieved with less EU and/or national funding?  
                                                           
69 EQ refers to Evaluation Question.  
 
56  
Evaluation question on relevance: To what extent are the Strategy and Action Plan 
relevant in view of current and future needs/challenges?  
EQ 9. To what extent has the EU Drugs Strategy and the Action Plan on Drugs 2017 -
2020 been relevant in view of the EU  needs/challenges and is it still relevant in view of 
current needs and challenges, and likely future needs?  
EQ 10. To what extent has the Strategy and the Action Plan been relevant in view of 
specific needs of stakeholders, in particular Member States and  civil society?  
 
Evaluation question on coherence: To what extent are the Strategy and Action Plan 
coherent and complementary to other relevant policy interventions at Member 
State, EU, and international level?  
EQ 11. To what extent are the objectives and activities determined by the EU Drugs 
Strategy and the Action Plan on Drugs 2017 -2020 coherent with other relevant EU policy 
developments and interventions in the EU as well as candidate and neighbouring 
countries?  
EQ 12. To what extent are the objectives and activities determined by the Strategy and 
the Action Plan coherent with the objectives and activities of the relevant EU Agencies? 
Are there any overlaps and synergies between the Strategy and Action Plan with the 
objectives and activities of these rel evant EU Agencies?  
EQ 13. To what extent are the objectives and activities determined by the Strategy and 
the Action Plan coherent with and complementary to the objectives and activities of the 
Member States?  
EQ 14. To what extent are the objectives and ac tivities determined by the Strategy and 
the Action Plan  coherent with and complementary to relevant international policy 
developments?  
EQ 15. To what extent have the  Strategy and Action Plan allocated the tasks in 
accordance with the responsibility at the appropriate governance level (e.g. EU, national, 
local and regional levels)?  
 
Evaluation question on EU added value: To what extent have the Strategy and 
Action Plan  achieved EU added value as opposed to what could have been achieved 
at either the national or the international level?  
EQ 16. What is the European added value of the EU Drugs Strategy and the Action Plan 
on Drugs 2017 -2020?  
EQ 17. To what extent are the outcomes of the Strategy and the Action Plan sustainable?  
EQ 18. What would be the most likely consequences of not having an EU -wide Drugs 
Strategy and Action Plan on Drugs?  
 
57 EQ 19. In case the initial problem and its causes (e.g. negative externalities, sp ill-over 
effects) varied across the national, regional and local levels, did the EU level action help 
establishing a level playing field?  
EQ 20. To what extent have the Strategy and Action Plan tackled significant/appreciable 
transnational/cross -border asp ects?  
EQ 21. Was the initial problem tackled with the Strategy and Action Plan widespread 
across the EU or limited to a few Member States?