COMMISSION STAFF WORKING DOCUMENT EVALUATION of the EU Drugs Strategy 2013-2020 and EU Action Plan on Drugs 2017-2020
Date: 2020-07-24
Institutions: Directorate-General for Migration and Home Affairs, European Commission
Subjects: EU action, EU strategy, European Monitoring Centre for Drugs and Drug Addiction, drug addiction, drug traffic, fight against crime, international cooperation, prevention of delinquency, project evaluation, psychotropic substance

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}  
 
 
Table of contents 

1. 

INTRODUCTION ....................................................................................................... 4 

1.1 Context, purpose and scope of the evaluation .......................................................... 4 

2.  BACKGROUND TO THE INTERVENTION ........................................................... 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: INTERVENTION LOGIC TABLE ................................................................ 41 

ANNEX II: PROCEDURAL INFORMATION ................................................................ 42 

ANNEX 

III: 

SYNOPSIS  REPORT  OF 

THE 

STAKEHOLDER 

CONSULTATION .................................................................................................... 44 

ANNEX IV: METHODS AND ANALYTICAL TOOLS ................................................ 54 

ANNEX V: EVALUATION CRITERIA AND QUESTIONS ......................................... 55 

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Glossary 

Term or acronym 

Meaning or definition 

CADAP 

CELAC 

CEPOL 

CND 

CSFD 

COSI 

COPOLAD 

ECDC 

EWS 

EEAS 

EMA 

EMCDDA 

EMPACT 

EU-ACT 

Europol 

HDG 

ICT 

JIT 

LSD 

MAOC-N 

MDMA 

NPS 

OCG 

Central Asia Drug Action Programme  

Community of Latin American and Caribbean States 

European Union Agency for Law Enforcement Training 

United Nations Commission on Narcotic Drugs 

Civil Society Forum on Drugs 

Standing Committee on Operational Cooperation on Internal 
Security at the Council of the EU 

Cooperation Programme between Latin America, the Caribbean 
and the European Union on Drugs Policies 

European Centre for Disease Prevention and Control 

Early Warning System on new psychoactive substances 

European External Action Service 

European Medicines Agency 

European Monitoring Centre for Drugs and Drug Addiction 

EU policy cycle for organised and serious international crime - 
EMPACT 

EU-Action against Drugs and Organised Crime  

European Union Agency for Law Enforcement Cooperation 

Horizontal Working Party on Drugs at the Council of the EU  

Information and communications technology 

Joint Investigation Team 

Lysergic acid diethylamide. 

The Maritime Analysis and Operations Centre-Narcotics  

3,4-Methylenedioxymethamphetamine (commonly known as 
ecstasy)  

New psychoactive substances 

Organised Crime Groups 

2 

 
 
 
SIENA 

UNAIDS 

UNGASS 2016 

Secure Information Exchange Network Application  

The Joint United Nations Programme on HIV and AIDS 

United Nations General Assembly Special Session on the World 
Drug Problem (2016) 

WHO 

World Health Organization 

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1. 

INTRODUCTION 

1.1 Context, purpose 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. 

4 

 
                                                           
implementation.” With the support of an external contractor7, the Commission conducted 
the  evaluation  of  the  Strategy  and  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, results and impacts. Based on the Commission’s 
Better  Regulation  Guidelines,  it  looked  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  Directorates-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.  

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 INTERVENTION 

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 with 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 Civil Society Forum on Drugs is a specific consultative body created and chaired by the European 
Commission. Learn more: https://ec.europa.eu/home-affairs/what-we-do/networks/civil-society-forum-
drugs_en  

5 

 
                                                           
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 has 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 challenges 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 evaluation results 
and  a  better  understanding  of  all  aspects  of  the  drugs  phenomenon  and  of  the 
impact  of  interventions  in  order  to  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  Intervention  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 objectives (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. 

6 

 
                                                           
achieved  through  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 actions 
covered a wide-range of support areas. For example, actions 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,  the  Action  Plan  encompassed  judicial  and  law  enforcement  cooperation, 
confiscation  of  criminal  assets  and  border  management.  Key  actors  and  bodies 
responsible 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 the 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  affected  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 
ultimately 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 achievements 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  consistently  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. 

7 

 
                                                           
study  supporting  this  evaluation.  These  data  were  combined  with  other  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.  Indicators  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 reduction: 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 population 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 was 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  100,000  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-Methylenedioxymethamphetamine. 

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 

For  more, 
https://www.emcdda.europa.eu/publications/joint-publications/eu-drug-markets-report-2019_en  

(2016).  EU  Drug  Markets  Report. 

and  Europol 

see: 

20  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. 

8 

 
                                                           
Coordination:  By  2013,  policies  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  as  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  consumption  (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 the World Health Organization (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.  

9 

 
                                                           
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 support monitoring and evaluation. To facilitate the measurement of the 
overall  effectiveness  of  the  Action  Plans,  fifteen  over-arching  indicators  were  set  out, 
along  with  additional  indicators  that  drew  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. 

Differences between the two Action Plans included the number and the topics 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,  new  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  included  focus  on  analysis  of  possible  links  between  drug  production  and 
trafficking  and  other  crimes,  most  notably  terrorism  financing,  migrant  smuggling  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, the 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, considerable progress had 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.  

10 

 
                                                           
The current evaluation concluded that the Action Plan covering 2017-2020 has 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 has been made 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 
larger degree.28 

Figure 2: Action Plan 2017-2020 – status of actions implemented per pillar29 

s
n
o
i
t
c
A
f
o
r
e
b
m
u
N

10
9
8
7
6
5
4
3
2
1
0

Demand
reduction

Supply
reduction

Coordination

International
cooperation

Information,
research,
monitoring and
evaluation

Green: on target

Amber: in progress

Red: no progress

28 See Annex 5 Traffic Light Assessment in ICF (2020), Evaluation study of the EU Drugs Strategy 2013-

2020 and EU Action 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. 

11 

 
 
 
                                                           
 
 
 
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 practice 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  enhance 
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  objectives  (7-8-9)  to  ensure  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 improve 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 align 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  networking  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 (15) 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 
the  Commission’s  Better  Regulation  Guidelines  (relevance,  coherence, 
effectiveness, efficiency and EU added value). The evaluation has covered EU-2830 and 
applicable international aspects from January 2013 to October 2019. 

in 

A wide range of stakeholders were consulted as part of the evaluation. A mixed-method 
approach  consisting  of  three  distinct  phases  (inception,  data  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.  

12 

 
 
                                                           
  112  interviews  covering  all  relevant  stakeholders  (Member  States  relevant 
authorities,  EU-level  stakeholders,  civil  society  organisation,  chemical  and 
pharmaceutical  industry  representatives,  and  international  organisations  and  UN 
agencies); 

  An  online  survey  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 case studies;  
  The  public  consultation  was  conducted  by  the  European  Commission  in  all  EU 
languages between 12 November 2019 and 4 February 2020, the results of which 
were made available to the contractor carrying out the external study.  

A  more  elaborate  description  of  the  methodologies  applied  and  the  stakeholder 
consultation activities are provided in Annexes III and IV. 

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  these  limitations  and  a 
description of how they were addressed follows: 

  Figures for the baseline assessment are not consistent across Member States. The 
figures are not necessarily representative of the entire EU at a set point in time. 
Specifically, some figures may not include data from all EU Member States, and 
may  not  reflect  the  exact  baseline  year  (2013).  Member  States  do  not  always 
consistently  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  combined  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  data  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’ 
see: 
http://www.emcdda.europa.eu/about/partners/reitox.  

observatories’; 

‘national 

more, 

drug 

For 

or 

13 

 
                                                           
available  whatsoever.  The  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  availability  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  through 
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 extensive stakeholder consultation activities 
and  an  EMCDDA  briefing  note  covering  an  overview  of  implementation  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 filled 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 
underlying 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, this allowed for methodologically robust conclusions. 

4.3. Deviations from the evaluation roadmap 

While the Evaluation Roadmap that was published in November 2018 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 order 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 QUESTIONS 

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 
expectations  concerning  what  the  Strategy  should  have  achieved  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 

14 

 
 
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 Question: To what extent are the Strategy and Action Plan relevant in view 
of current and future needs/challenges? 

Key findings  

  Owing  to  their  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,  the  Strategy  appears  to  have  partial  relevance  in  view  of  recent 
technological,  societal,  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,  technologic  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 sufficiently 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  pillars  of  the  Strategy  and  the  actions  in  the  Action 
Plans remain generally relevant, but due to lack of prioritisation, 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 confirms the continued relevance 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  addressed 
relevant cross-cutting themes.  

15 

 
However,  while  the  Strategy  and  Action  Plan  were  broad  in  scope  and  allowed  for 
flexibility  to  accommodate  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 
perspective,  prioritisation  of  actions  was  seen  as  necessary  in  view  of  the  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  also  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 considered 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  allowed  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  sufficiently 
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  insufficiently 
covered or not covered at all, include:  

  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;  the  effectiveness  of 
relevant  electronic  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  use  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  OCGs,  including  the  use  of  darknet 
marketplaces  for  drugs,  encryption  technologies  and  cryptocurrencies  for 
facilitating  anonymity,  and  the  ‘uberisation’  of  the  cocaine  market  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 authorities and usually do not have any known legitimate use. 

16 

 
                                                           
  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  international,  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  of  strengthening  the  harm  reduction 
approach, and highlighted human rights of drug users. 

5.2 Coherence 

Evaluation  Question:  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 
legislative 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,  migrant 
smuggling,  terrorism  and  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  preparing  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.  

17 

 
 
                                                           
policies. Overall, approximately half of Member States seem to have been more 
likely  to  closely  align  to  the  Strategy  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.  

  The Strategy is perceived  to  be  a comprehensive guiding document for national 
stakeholders 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 improvement 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  coherent  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 links 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  some 
extent.  However,  it  stressed  the  importance  to  better  integrate  precursor  issues  in  the 
Strategy,  especially  in  terms  of  coordination  and  consistency  between  the  involved 
actors. Particular attention should be paid to ‘designer-precursors’ as these chemicals are 

34 Ibid.  

35 ICF (2020). Evaluation study of the EU Drugs Strategy 2013-2020 and EU Action Plan on Drugs 2017-

2020. 

18 

 
                                                           
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 Strategy 
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  behaviours  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  determined  that  further  alignment  could  be  achieved 
with  relevant  emerging  challenges  in  other  security  priorities,  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  within  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 acceding 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,  environmental  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 
between 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  all 
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 Strategy 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 
judicial  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 

19 

 
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  provinces,  the  evaluation  had 
difficulties in articulating the level of complementarity.  

At  the  international  level,  the  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 comparison with the three UN Conventions36, the 
Political Declaration of 200937, the 2030 Agenda for Sustainable Development of 201538, 
the UNGASS outcome document of 201639, the Ministerial 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 the possible need for further alignment and link within security priorities.  

Overall,  the  tasks  of  the  Strategy  and  the  Action  Plan  have  been  allocated  at  the 
appropriate governance level, with improvements after the adoption of the second Action 
Plan.  A  horizontal  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 increased 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.unodc.org/documents/commissions/CND/2019/Ministerial_Declaration.pdf  

41 https://www.unaids.org/en/resources/documents/2015/UNAIDS_PCB37_15-18 

20 

 
 
                                                           
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  interventions  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  people.  Finally,  drug-
related deaths across the EU have also increased.  

  Similarly,  the  Strategy  has  been  only  partially  effective  in  achieving  the  drug 
supply reduction 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 nonetheless 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 insufficient to disrupt the illicit drug markets. 

 

In  terms  of  the  coordination  general  objective,  the  evaluation  found  that  drug 
policy  was  overall  effectively  coordinated  at  both  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 Strategy 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 coordination 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.  Dialogues  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  significant  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 accompanying country reports) 
by  the EMCDDA  and the joint  EMCDDA  – Europol  EU Drug Markets  Report, 
which  have  become  a  benchmark  for  high-quality  assessment  of  the  drugs 
situation  and  effectiveness  of  policies.  However,  other  areas  are  not  yet  as 
effective, such as the use of the EMCDDA Best Practice Portal on drug demand 
related  interventions,  which  has  not  been  mainstreamed  by  Member  States  into 
national  or  local  evidence  based  policies  and  measures.  Another  area  for 

21 

 
improvement  is  the  development  and  adoption  of  supply  indicators42  by  the 
EMCDDA  Reference  Group  on  Drug  Supply  Indicators,  which  have  been 
gradually  adopted  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  highly  potent  NPS,  the increased 
use  of  new  technologies  at  all  levels  of  the  drug  production,  supply  and 
distribution chains, and the increasingly poly-criminal nature of organised crime 
groups (OCGs) taking advantage of other emerging EU security challenges.   

By 2020, the 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  unintended  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 Action 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  general  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 of 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,  international  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  and  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 found 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 availability 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. 

22 

 
                                                           
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 young 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  dependent  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 (aged 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: Trends in last-year prevalence of drug use 2012-201748 

Population (15-
64) 

Young population (15-
24) 

Teenagers and young 
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 for 

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), 2004 
(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  Evidence  in  ICF  (2020),  Evaluation  study  of  the  EU  Drugs 

Strategy 2013-2020 and EU Action Plan on Drugs 2017-2020. 

23 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                           
Source: ICF, based on EMCDDA data statistical bulletin 

A  range  of  risk  and  harm  reduction  measures  for  problem  drug  users  has  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  misuse  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  assessed  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 consumption 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  overall  increased.  The  provision  of  healthcare  measures  for  incarcerated 
drug users has grown, with all Member States providing opioid substitution treatment in 
prison. However, even if opioid substitution treatment was indeed available for prisoners 
in  all  Member  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  the  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  specific  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 EMCDDA 

Briefing Note for the midterm assessment.  

24 

 
                                                           
with  the  adoption  and  initial  stages  of  implementation  of  the  common  European 
minimum  quality  standards.  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  availability  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 available 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  availability 
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) 

Purity change    
2013-17 (median) 

Cocaine 

Heroin 

Cannabis Resin 

Cannabis herb 

Amphetamine 

MDMA 

62.6 

5.6 

460 

130 

6.4 

no data 

Methamphetamine 

0.5 

140.4 

5.4 

466 

209 

6.4 

1.7 

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. 

25 

 
 
 
 
 
 
 
 
 
                                                           
The increase in cocaine and cannabis seizures likely prevented an 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  effective  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 became 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. Some stakeholders noted that the Strategy and Action Plan 
have given little impetus to larger scale 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 tackling of high-level, large-
scale drugs trafficking into the EU.  

Regarding the exchange of information between law enforcement agencies, the use of the 
Secure  Information  Exchange  Network  Application  (SIENA)  systematically  rose 
between 2013 and 2018, including in terms of drugs-related exchange of information.  

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  of 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) 

26 

 
online system and the precursors incident communication system (PICS) 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  period,  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’ provisions54 with a view to address the use of non-scheduled 
drug  precursors.  While  these  legislative  developments,  by  improving  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 States 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  measures  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 effectively 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 lack 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 Marketplaces (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-precursors.  

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  harmonised  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  instrumentalities  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 Commission, 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. 

27 

 
                                                           
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  as  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  emerging  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 momentum.  

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 determined 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 are 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 meetings 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 

28 

 
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  the  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  policy  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 priorities 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 illicit 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  Nations  General  Assembly  Special 
Session on Drugs and the UN CND Ministerial Declaration in 2019 were highlighted as 
the  main  success  stories  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,  through  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  constituted  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 
Balkans, all of which are largely in line with the Strategy. 

29 

 
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 aspects 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 specific 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 and 
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 
investment 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 knowledge 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  States’  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.  

30 

 
                                                           
The  two  flagship  reports,  the  EMCDDA’s  European  Drug  Report  with  accompanying 
country  reports  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  human  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,  the  EU  Early  Warning  System  on  New  Psychoactive  Substances  supported  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  Forensic  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 laboratories 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 outputs 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 policies 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 some 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 for 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.   

Diversification  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  2019  drugs  trafficking  has  been 
detected together with illegal migrant smuggling. 

31 

 
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 recreational 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  explain  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  remained  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  expenditure,  and 
also migration pressures. 

  Although the allocation of public spending between demand and supply reduction 
measures varied across Member States, balance was often maintained in the range 
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  address  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, including 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.  

32 

 
 
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 agencies in the field of drugs; (iii) costs of internal EU programmes (supporting 
actions within the EU); (iv) costs of external EU programmes (supporting actions outside 
of  the  EU).  Where  data  was  not  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’ expenditures, i.e. expenditures which are 
part of a broader area, e.g. public health, education, law enforcement, and 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 instruments. 

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 most  Member 
States falling within the 0.02% to 0.3% range. This would seem to indicate that the 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 Member 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 Member 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 under demand and supply reduction pillars.   

33 

 
                                                           
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  vary  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  was  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 supply 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  sufficient 
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 funding 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 fighting 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  programmes  implemented  in  the  evaluation  period  included 
COPOLAD, the 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  objective  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  needing  to 
respond  to  new  challenges  and  an  increasing  volume  of  tasks.  These  challenges  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.  

34 

 
                                                           
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  questioned  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 value 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  successful  consensus 
building  tool.  It  provided  EU  added  value  by  creating  a  common  ground  (in  the 
form of a conceptual and operational framework) to present the EU perspective of 
the  drug  phenomenon  and  the  realm  of  values,  priorities  and  actions  in  tackling 
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  organisations,  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 level, the Strategy and Action Plan supported coordination mechanisms and 
EU  level  actions.  It  encouraged  cross-border  coordination  and  exchange  of 
information  and best  practices among Member States and thus  created economies 
of scale in terms of synergies and efficiencies (instead of each Member State using 
resources for similar or overlapping issues or objectives). 

  The Strategy helped promote 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 

35 

 
 
achieved through longer, costlier and less well-articulated processes. 

The Strategy and Action Plan, and indeed drugs policy, cover different areas from health 
to security that have local to international impact. The evaluation found that the 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  challenges  faced  by 
Member  States.  Among  others,  one  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 demand 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 States shared 
this  interpretation  of  the  role  of  the  Strategy:  no  Member  State  alone  could  deliver  a 
common strategic framework for addressing 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  organisations.  Specifically,  the 
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 they deemed 
such action to be needed (e.g. funding for drugs harm reduction or treatment). 

the  country-specific  data  collected, 

At  EU  level,  the  Strategy  and  Action  Plan  encouraged  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  overlapping  issues  or  objectives.  Based  on 
the  Strategy 
stakeholder  consultations  and 
contributed to establishing a level playing field particularly in the three horizontal pillars, 
namely coordination, cooperation and information exchange, monitoring and evaluation, 
by  allowing  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  interventions  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 phenomenon, and in particular drugs trafficking, is international by 
nature, and it can only be tackled as a cross-border issue. 

36 

 
 
At the international level, the 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 implementation, 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  pointed  out  that  due  to  the  Strategy  and  the 
common  EU  position  they  can  participate  more  actively  in  international  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 evaluation 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  regularly  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 consequences 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 supply reduction measures could be more drastic and de-prioritisation 
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 lack 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  exchanges  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 
cooperation and monitoring 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.  

37 

 
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  impacts.  The  evaluation  considered  their  implementation  in  light  of 
evaluation  questions  under  the  five  mandatory  evaluation  criteria  provided  in  the 
Commission’s  Better  Regulation  Guidelines  (relevance,  coherence,  effectiveness, 
efficiency and EU added value). 

The  analytical  framework  that  was  developed  in  order  to  evaluate  the  Strategy  and 
Action Plan was able to overcome a number of limitations, including: a limited baseline 
situation  for 2013 to  be used  as a point of comparison;  the limited data on drug policy 
related costs, especially at the national level, along 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 collected 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 phenomenon, as well as recent technological, societal, 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 OCGs, 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 only partially effective in achieving the 
two  general  policy  objectives  (drug  demand  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 speaking, 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 difficult 
to carry out a sound assessment of the efficiency of implementing the five general 

38 

 
 
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  situation.  Further  to  the  proportionality  of 
allocated costs, civil society organisations used the Strategy to point out gaps in 
insufficiently  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 results that national or other EU initiatives would not have achieved. In 
particular, they established a common strategic framework for actions at the EU, 
national  and  regional  levels,  ‘bridging’  between  Member  States,  and  between 
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  efficiencies 
(instead of each Member State using resources for similar 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 evaluation 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, prioritisation 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  prioritised  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  involvement  in  drugs 

39 

 
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.  

40 

 
 
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. 

41 

 
                                                           
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  evaluation  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  Migration  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  consultations  took  place  in  the 
context of regular meetings, 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 2019, 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 to 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  stakeholder  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  the  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 (HR); Budget (BUDG); Justice and Consumers (JUST); 
International  Cooperation  and  Development  (DEVCO);  Mobility  and  Transport  (MOVE);  Internal 
Market,  Industry,  Entrepreneurship  and  SMEs  (GROW);  Taxation  and  Customs  Union  (TAXUD); 
Health and Food Safety (SANTE); 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). 

42 

 
                                                           
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 2020. 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 2020. 

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  international 
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 III. 

5. External expertise 

The evaluation drew 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 possessed expert 
competence. 

43 

 
 
 
 
 
 
 
 
ANNEX III: SYNOPSIS REPORT OF THE STAKEHOLDER CONSULTATION  

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 Plan 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,  coherence,  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  the  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. The 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 identified 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  researchers;  practitioners  involved  in  the  drugs  or  health  policy 
fields;  chemical  and  medical  industry  representatives;  the  general  public;  and,  the 
relevant  Directorates-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  tools).  All  stakeholder  groups  were  contacted 
and  consulted.  In  addition, 
times 
pharmaceutical  industry  representatives  with  requests  for  an  interview  but  received  no 
response. 

the  external  consultant  contacted  multiple 

44 

 
 
 
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  
Other national 
authorities67 
EU Agencies 
EU Inst. & EEAS 
EU-funded programme 
Civil Society Orgs.68 
Chemical and 
pharmaceutical industry 
Int. organisations 
Academic/research 
institutions 
Business association 
Consumer organisation 
EU Citizens 
Non-EU Citizens 
Public authorities 
Other 
TOTAL 

43 

23 

6 
15 
5 
9 
2 

9 

112 

51 
1 

18 

3 
4 
378 
2 
34 
13 
504 

9 

8 

10 
5 

10 

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 representatives 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 preparation 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  during  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 addiction and an NGO representing a network of NGOs advocating for better 
drug policies.   

45 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                           
2. Targeted stakeholder consultations 

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 (NFP), (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  interviewees,  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 Ministry 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 Plan. 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  Czechia.  The  participating 
civil  society  organisations  represented  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 organised 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 

46 

 
 
A  total  of  26  stakeholders  representing  different  Directorate  General  (DGs)  within  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 stakeholders 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 stakeholders specified that the  Strategy is reasonably well connected 
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, stakeholders 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 highlighted 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 brought 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 direction. 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  requires  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 

47 

 
comprehensive and broad, yet its long-time span of seven years means it does not reflect 
the rapidly evolving drug markets. Stakeholders highlighted trends in the field of  drugs 
that need to be addressed such as darknet, cryptocurrencies and access to information and 
treatment  for  migrant  populations.  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 extent. 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. Indeed, 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 
countries  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 institutional 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  for  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  that  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  stakeholders  also  pointed  out  that  the  Strategy 
has built a framework for consensus-building, facilitating exchange of best practices 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 candidate 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 

48 

 
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  policy,  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  aspects  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 inclusion 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 position 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  promote  civil  society 
engagement in policy design, implementation and monitoring. CSFD representatives also 
underlined  the  necessity  of  a  more  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 policymaking 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. 

49 

 
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 with the CSFD revealed that stakeholders believe the 
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 consolidate 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 states. 

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 position 
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.  

the 

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  African  continent. 
included 
Additionally, 
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.  

two  position  papers  submitted  by  UN  Agencies 

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 the Strategy as a guiding policy document.  

2.2.6 Academic experts 

50 

 
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  academic  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 field 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  internal  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  budgets,  the  limitations  of  only  using  ear-marked  data 
when analysing efficiency and the lack of impact studies. 

2.2.7 Chemical and pharmaceutical 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 effective 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 that  the  EU’s  work on 
drug precursors as outlined in the Strategy, strengthened and complemented their work.  

On EU-added value 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  February  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 

51 

 
of NGOs and public authorities. 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 responses 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 that 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 respondents 
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 reflected in the current Strategy. 
Other  challenges  mentioned  include  the  need  for  a  greater  focus  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  with  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  complementarity  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  objectives  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 objectives 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 

52 

 
funding for activities in 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-efficient 
budgeting for internal and external actions in the next EU budgetary cycle. 

to  encourage  coordination 

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  time,  however,  large  majorities  of  respondents  tend  to  agree  that  EU  support  is 
required 
through  active  discourse  and  analysis  of 
developments  and  challenges  in  the  field  of  drugs  at  the  EU  and  international  level,  to 
further  strengthen  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  duplication  and  inconsistencies,  was  effective  in 
making  the  European  approach  on  drugs  visible  and  a  leading  example  internationally, 
and  improved  coordination  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. 

53 

 
ANNEX IV: METHODS AND ANALYTICAL TOOLS 

In  this  annex,  the  methods  and  sources  that  were  drawn  upon  in  carrying  out  the 
evaluation are described, as well as the limitations that were encountered. 

A  range  of  methodological  tools  and  techniques  were  included  in  the  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 targeting 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 documents; 
  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  ‘EMCDDA 
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 extraction of all 
the relevant  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).  

54 

 
 
 
 
 
 
 
 
ANNEX V: EVALUATION CRITERIA AND QUESTIONS 

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 aspects relevant to 
the EU and covered 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 effectiveness: To what extent have the Strategy 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 general 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 external 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 years 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.  

55 

 
 
 
                                                           
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 relevant 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 activities 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? 

56 

 
 
 
 
EQ  19.  In  case  the  initial  problem  and  its  causes  (e.g.  negative  externalities,  spill-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 aspects? 

EQ  21.  Was  the  initial  problem  tackled  with  the  Strategy  and  Action  Plan  widespread 
across the EU or limited to a few Member States? 

57