Opinion of the Regulatory Scrutiny Board
Date: 2025-06-18
Institutions: European Commission, Regulatory Scrutiny Board
Subjects: EU strategy, action programme, drug addiction, drug traffic, fight against crime, psychotropic substance

EUROPEAN COMMISSION 

Brussels, 18.6.2025 
SEC(2025) 210 final 

REGULATORY SCRUTINY BOARD OPINION 

Commission Staff Working Document – Evaluation of the EU Drugs Strategy 

2021-2025 and EU Drugs Action Plan 2021-2025 

{SWD(2025) 187 final} 
{SWD(2025) 188 final} 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 
Regulatory Scrutiny Board 

Brussels,  
Ares(2025) 

Opinion 

Title: Evaluation of the implementation of the EU Drugs Strategy 2021-
2025 and of its Action Plan 

Overall opinion: POSITIVE 

(A) Policy context 

The  December  2020  EU  Drugs  Strategy  for  2021-2025  was  based  on  three  pillars:  (i) 
reducing drug supply, (ii) reducing demand, and (iii) addressing drug-related harm. 
The complementary EU Drugs Action Plan for 2021-2025 set out 85 actions to achieve 
the 11 strategic priorities listed by the strategy. 

This evaluation draws conclusions on progress to date and  seeks to provide inputs and 
recommendations for the future development of EU drug policy and the following cycle 
of the EU Drugs Strategy. 

(B) Key issues 

The Board notes the additional information provided in advance of the meeting and 
commitments to make changes to the report.  

The Board gives a positive opinion. The Board also considers that the report could 
further improve with respect to the following aspects:  

(1)  The report does not sufficiently explain to what extent the Drugs Strategy alone 
is responsible for delivering certain benefits, particularly taking into account 
that its actions and implementation are often rooted in other frameworks. 

(2)  The conclusions do not sufficiently reflect the uneven contribution of the 

Strategy across Member States. 

(C) What to improve 

(1)  The report should be clear about the Strategy, what it alone delivered, and the extent 
to which its delivery relied on the actions of existing structures e.g. Europol, Eurojust, 
etc. It should also be clear on the additionality of the Strategy over and above the work 
programmes and priorities of these agencies. It should better define the governance of the 
Strategy,  establish  who  is  responsible/can  contribute  to  what,  and  explain  how,  using 

  ________________________________   
This opinion concerns a draft evaluation/fitness check which may differ from the final version. 

Commission européenne, B-1049 Bruxelles - Belgium. Office: BERL 08/010. E-mail: regulatory-scrutiny-board@ec.europa.eu 

 
 
 
 
 
evidence and case studies, the Strategy and Action Plan contributed to guide the work of 
the EU, Member States and Commission initiatives (e.g. EUDA and Europol). The report 
should also better explain how the Roadmap fits in the overall evaluation of the Strategy. 
(2)  Conclusions and lessons learned should better reflect the uneven contribution of the 
Strategy across Member States, the changing drug-related challenges and corresponding 
needs including research needs. The conclusions should be better aligned with the analysis 
findings and proportionate to the data limitations. 
(3)  The report could further assess the uneven contribution  of the Strategy in Member 
States  by  looking  at  how  the  Strategy  has  been  reflected  in  annual  programmes  and 
Member States policies. The report could further elaborate the operational analysis of the 
role of Member States, and whether, how and where it can be improved. The evaluation 
could show ‘case studies’ that may serve as best practices.  
(4)  The report could deepen the analysis of success factors, both at the EU and Member 
States  levels,  and  explain  how  the  implementation  has  been  made  possible  e.g. 
procedures,  budget,  relationship  with  Agencies  and  how  they  have  contributed  to  the 
success  of  the  Strategy.  The  report  could  analyse  in  more  detail  barriers  to  the 
implementation. 
(5)  Given the stated limitations on data collection, evidence gathering and inconsistent 
reporting among Member States, the lessons learned on monitoring and standardised data 
collection should identify  concrete gaps  and  corresponding additional  indicators in  the 
next strategy which would be RACER (Relevant, Accepted, Credible, Easy to monitor 
and Robust).  
(6)  The  report  should  better  clarify  the  baseline.  Although  the  baseline  assessment  is 
referred  to  in  the  Evaluation  matrix  as  the  basis  for  the  data  analysis,  to  allow  for  a 
comprehensive comparative analysis, the report should gather the corresponding figures 
for the 11 overarching indicators (as per Annex I of the Action Plan) and present them in 
a table. 

Some more technical comments have been sent directly to the author DG. 

(D) Conclusion 

The lead Service may proceed with the initiative. 

The  lead  Service  is  advised  to  take  these  recommendations  into  account  before 
launching the interservice consultation. 

Full title 

Evaluation of the implementation of the EU Drugs Strategy 
2021-2025 and of its Action Plan 

Reference number 

PLAN/2023/1722 

Submitted to RSB on 

4 April 2025 

Date of RSB meeting 

30 April 2025 

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