Opinion of the European Economic and Social Committee – Commercial determinants of health (own-initiative opinion)
Date: 2025-09-18
Institutions: European Economic and Social Committee
Subjects: alcoholism, disease prevention, economic policy, food consumption, health care system, health determinant, marketing, multiannual financial framework, occupational health, smoking








C_202600003EN.000101.fmx.xml












Official Journal of the European Union


EN
C series













C/2026/3


16.1.2026






Opinion of the European Economic and Social Committee
Commercial determinants of health
(own-initiative opinion)
(C/2026/3)


Rapporteur: 
Alain COHEUR

Co-rapporteur: 
Christophe LEFÈVRE






Advisors


Martini HAGIEFSTRATIOU (to the rapporteur)




 


Aymeric BOILLOT (to the co-rapporteur)




Plenary Assembly decision


23.1.2025




Legal basis


Rule 52(2) of the Rules of Procedure
Own-initiative opinion




Section responsible


Section for the Single Market, Production and Consumption




Adopted in section


2.9.2025




Adopted at plenary


18.9.2025




Plenary session No


599




Outcome of vote
(for/against/abstentions)


95/0/5




1.   Conclusions and recommendations









1.1.


Regarding the commercial determinants of health, the European Economic and Social Committee (EESC) stresses the need to take a comprehensive, preventive approach based on fundamental human rights and the exposome concept. These determinants are defined as strategies and practices of private actors that negatively influence health and democratic checks and balances.












1.2.


The EESC reiterates the key role that the European Union (EU) and its Member States must play through ambitious policies, targeted action plans and strategic funding. In particular, the next Multiannual Financial Framework (MFF) for 2028-2034 must prioritise health and the shift towards prevention as a pillar of European resilience, and also respond to health, social, economic, professional and environmental vulnerabilities aggravated by pandemics, multidimensional crises and structural inequalities.












1.3.


The EESC stresses that comprehensive consideration of all aspects of health is fully in line with economic imperatives, which can be linked to public health objectives and be seen as a general interest. As such, the EESC encourages a balanced framework for action that offers European businesses the necessary conditions to move towards more positive health models. By including the precautionary principle and transparency and due diligence clauses in public policies, the EU can better protect citizens’ health, but also unlock the innovation potential of European businesses and actively help the EU be a pioneer of the well-being economy, combining economic performance, social cohesion, health solidarity and sustainable prosperity.












1.4.


The EESC is prepared to support a competitive EU, not through a race to the bottom in terms of health or society, but by making Europe the leading continent for quality of life, a pillar of the European project.












1.5.


The EESC also draws attention to the need to guarantee a strong approach to health and safety at work, in line with Principle 10 of the European Pillar of Social Rights. There is an urgent need to strengthen existing frameworks to prevent occupational risks, in response to working environments and ways of working that have a negative impact on health. An approach focused on the quality of working conditions improves both the competitiveness of businesses and the well-being of workers, in the spirit of shared prosperity.












1.6.


The EESC highlights a number of European projects that illustrate the need to take action on commercial determinants of health, including strengthening European governance on low-value care, by integrating commercial determinants of health into the assessment of health systems, in line with the work of the European Commission’s Health Systems Performance Assessment (HSPA). The EESC endorses EuroHealthNet’s analysis on the need for strict regulation of industrial practices that encourage overconsumption of health care and products with no demonstrable benefit for patients. The EESC supports initiatives such as the PreventNCD Joint Action on the prevention of cancer and other non-communicable diseases (NCDs), which promote coordinated policies to regulate harmful industries, tax harmful products and limit marketing of them. It also encourages cross-cutting approaches, inspired by international models such as Canada, to include NCDs in all public policies and to guarantee a sustainable and equitable health system based on quality of care.












1.7.


The EESC calls for the professionalisation of the health workforce and investment in ethical and scientific training, as recommended in the joint roadmap of the World Health Organization (WHO) and the Association of Schools of Public Health in the European Region (ASPHER). Competent staff is essential to ensure preventive policies are effective.












1.8.


The EESC recommends strengthening the strategic role of the European Centre for Disease Prevention and Control (ECDC) by extending its current mandate and resources beyond communicable diseases to include commercial determinants of health and NCDs with the aim of equipping the EU with a forward-looking and independent analytical capacity, commensurate with contemporary public health challenges. With this in mind, the EESC supports the creation of a European Observatory on Commercial Determinants of Health, as described in point 6.3, under the aegis of the ECDC and in coordination with other relevant agencies (the EMA, EU-OSHA, Eurostat, etc.).












1.9.


The EESC supports the funding allocated to health in the proposal for the 2028-2034 Multiannual Financial Framework, in particular through the Competitiveness Fund and the tobacco tax, but regrets the lack of a dedicated health programme, which makes health priorities less visible. The EESC calls for prevention, health education and strengthening health systems to be included in the national and regional partnership plan budgets (the NRPPs), with stronger governance to deal with the commercial determinants of health.












1.10.


The EESC stresses the crucial role that Member States could play, supporting a voluntary coalition of states promoting stricter regulation of aggressive marketing, including in the digital space.












1.11.


The EESC calls for the creation of a European healthy business label, issued on the basis of rigorous, independently verified criteria. This label would highlight businesses working to reduce the promotion of products that are harmful to health, maintain transparency in these sectors, and fund prevention campaigns, while at the same time regulating conflicting ‘healthwashing’ initiatives. Social and solidarity-based practices can be inspiring in this area.












1.12.


The EESC calls for the active and systematic involvement of civil society and patient organisations at all stages of the development, implementation and evaluation of health policies in the context of commercial determinants of health, both at European and international level. At the same time, it stresses the importance of a rigorous assessment of the financial links between patient organisations and industries that have an impact on health, making funding mechanisms more transparent. The aim of this approach is to analyse the impact of these links on public policies, in particular in authorisation, reimbursement and research procedures, while ensuring effective representation of citizens’ needs.












1.13.


The EESC recommends that the EU strengthen its role in global governance of public health, particularly in the work of the WHO, the G7, the G20 and the UN.




2.   An integrated approach to addressing determinants of health









2.1.


Health is a fundamental human right shaped by a complex set of social, economic, commercial, environmental and digital determinants. 70 % of the state of health is influenced by these factors, compared to only 10 % for individual behaviours. All environmental factors a person is exposed to throughout life and the impact they have on health are summarised by the exposome concept. The EESC encourages public policies based on a systemic approach that takes these determinants into account.












2.2.


NCDs – cardiovascular diseases, cancers, chronic respiratory diseases, diabetes – account for almost 90 % of deaths and 85 % of cases of incapacity in Europe. The EESC stresses the need to address their structural causes, in addition to prevention and access to care, to ensure better health for all.












2.3.


The EESC builds on the work of the WHO, in particular its study on commercial determinants of health (1), which defines these as the strategies of private actors to maximise their profits to the detriment of public health. The WHO calls for strict regulation, dissuasive taxation of harmful products and improved monitoring of harmful trade practices.












2.4.


Like digital platforms that drive disinformation, the tobacco, alcohol, agri-food and fossil energy industries have a considerable influence on public health, not only through the products they market, but also through their lobbying strategies, influence on scientific research and ability to influence public policies to their advantage.












2.5.


The EESC highlights the importance of multi-stakeholder and cross-sectoral cooperation. It is not enough to rely just on one tool: public policies need to be developed to transform living environments, reduce health-related social inequalities and redirect the influence of economic actors whose interests go against public health towards a well-being economy.












2.6.


As a model of a society that strikes a balance in which economic competitiveness and social well-being reinforce each other, the EU must adopt an integrated approach to regulating and preventing the negative impacts of the commercial determinants of health.




3.   Understanding the impact of commercial determinants



Documented analyses by international and European institutions










3.1.


The WHO has pointed to the commercial practices of certain industries that aggravate health and environmental impacts: aggressive marketing targeting children and vulnerable populations (80 % of advertising for ultra-processed food targets young people), the influence of biased industrial funding on research (e.g. covering up the dangers of tobacco), intensive lobbying (mobilising significant resources to prevent the adoption of public policies that would benefit the population), externalisation of the costs of diseases to society and strategies to shift responsibility (for example, falsely promoting e-cigarettes as less harmful).












3.2.


According to the latest available estimates (2), cardiovascular diseases, obesity, alcohol and tobacco result in major economic and health costs estimated at over EUR 700 billion per year for European health systems, with tobacco (700 000 deaths, EUR 98-130 billion, as much as 1,39 % of GDP), alcohol (255 000 deaths, EUR 125 billion), obesity (over EUR 10 billion in healthcare costs) and spending by harmful industries (e.g. EUR 30 million to curb sugar taxes) having specific impacts. Harmful substances (tobacco, alcohol, ultra-processed food) cause around 2.7 million deaths per year in Europe, or 25 % of total mortality (approximately 7 400 deaths per day).












3.3.


The EESC reiterates that occupational safety and health, enshrined in Principle 10 of the European Pillar of Social Rights, remains a priority. Workplace absences due to chronic diseases and psychosocial risks represent a cost of around 2,5 % to 4 % of EU GDP, or between EUR 470 and 750 billion per year, according to studies that include the direct and indirect costs (3).












3.4.


The EESC stresses the importance of prevention in relation to neurodegenerative diseases such as Parkinson’s, advocating stepping up assessment of the risk factors, scientific independence and the precautionary principle (4).












3.5.


The WHO (5) highlights the fundamental link between public health and economic stability, promoting interconnected policies and modelling tools.




4.   Fostering a virtuous circle for European businesses









4.1.


Far from being a hindrance to competitiveness, a shift towards healthy and responsible commercial practices is a major opportunity for European companies. By moving away from harmful products and integrating prevention of NCDs into their business models, companies can not only reduce regulatory and reputational risks, but also stimulate innovation and become more attractive to consumers and investors.












4.2.


The development and uptake of healthier and sustainable products can lead to a virtuous circle in which companies benefit from more stable regulations, increasing demand for responsible alternatives and alignment with societal expectations for public health. However, like greenwashing, healthwashing is a real risk. A reliable European ‘healthy business’ certification based on clear and rigorous criteria is therefore needed. The EU and its Member States could promote responsible innovation through tax incentive schemes and in public procurement.












4.3.


By ceasing to rely on marketing risky products, and investing in innovative alternatives, companies can not only anticipate regulatory developments but also become more competitive in the long term. Public health innovation – products, services, consumption patterns – is becoming a strategic lever for economic growth. At EU level, encouraging this transition is fully in line with the willingness to build competitiveness based on excellence, responsible innovation and sustainability, in a geopolitical context that requires enhanced health sovereignty, industrial independence and social attractiveness.






Rethinking prevention as a strategic lever for the European Union










4.4.


The cost of prevention must not be seen as a commercial constraint or threat. On the contrary, it is a key investment lever, both in terms of the sustainability of health systems and the well-being of the population, which is a distinctive feature of the European model and its competitiveness. The EESC supports a system of targeted taxation on harmful products such as tobacco, alcohol and ultra-processed foods to finance preventative actions by health systems.












4.5.


A well-trained public health workforce is essential to tackle the commercial determinants of health in the EU. Without skills or ethics, prevention efforts, regulating harmful industries and implementing evidence-based policies will not be enough. The EESC supports the WHO-ASPHER roadmap to boost the capacity of the public health workforce, which is essential for the resilience of health systems, ethical governance and protection from commercial influences.






Creating a favourable ecosystem










4.6.


The EU has a strong interest in speeding up this transition to a sustainable health economy by providing financial incentives, a coherent regulatory framework and rigorous public-private partnerships in the food, pharmaceutical, digital and health sectors. By building an ecosystem conducive to social innovation and health, the EU can make the prevention of NCDs a real driver of growth and resilience. This approach also includes improving existing treatments and reducing preventable diseases, such as certain forms of cancer or Parkinson’s disease when detected and addressed at an early stage.












4.7.


In line with the protection of personal data, the EESC calls for greater transparency regarding the real purposes of the exploitation of health and consumer data, especially when it feeds advertising algorithms or behavioural optimisation tools. It is necessary to prohibit the use of health data that boosts harmful business models (algorithmic suggestion of ultra-processed or polluting products). The EESC calls for a strict framework for systems used to target audiences based on their medical or social fragility, as well as for platforms and companies to be labelled according to their level of ethical compliance (principle of ‘digital health responsibility’).












4.8.


Patient associations, which represent citizens’ experiences, and civil society organisations are key democratic actors that are essential for health democracy as well as social dialogue. To preserve this legitimacy, the EESC recommends ensuring an enabling and transparent environment that allows them to fully play their role as guardian, advocate and representative of the general interest in the development, implementation and evaluation of health policies.




5.   Taking actual experiences and claims into account









5.1.


The EESC stresses the importance of greater consideration of concrete experiences and recommendations from recent European initiatives. The report of the European Commission’s HSPA Group (6) warns of the persistence of ‘low-value care’, i.e. medical interventions with no proven benefit, promoted by aggressive commercial strategies, to the detriment of quality of care and the financial sustainability of health systems. Similarly, the European EuroHealthNet and the global NCD Alliance (7) call for stronger regulation of harmful industries (tobacco, alcohol, ultra-processed food) and warn about their capacity to influence public policies through lobbying and targeted marketing, including digital marketing. The EESC agrees with these findings and calls for more rigorous governance of commercial determinants of health.












5.2.


In line with this momentum, the EESC supports the PreventNCD Joint Action (8), a coordinated European initiative to integrate commercial determinants of health into policies for the prevention of non-communicable diseases. It sets out the key proposals of taxing harmful products, limiting marketing of them, creating independent regulations and strengthening European cooperation. Like Canada, which has implemented a health determinants map and a well-being economy plan, the EESC calls on the EU to have a similar framework for cross-cutting action. It recommends the adoption of a comprehensive European strategy to combat the commercial determinants of health, anchored in the fairness, prevention and the resilience of public systems.




6.   Towards a stronger European framework for the well-being economy









6.1.


In the face of the challenges posed by commercial determinants of health, the EU must put in place an ambitious and structured well-being framework that includes health as a fundamental pillar of public policies. This requires a comprehensive approach that combines strengthened governance, monitoring commitment from companies, economic incentives and international cooperation.












6.2.


Applying the precautionary principle in all commercial and industrial policies that affect health:






—


the EU must incorporate the precautionary principle into its economic, social and commercial decisions in order to anticipate the harmful effects of industries on public health;










—


the EESC recommends a targeted application of the precautionary principle, avoiding an indiscriminate or generalised approach to all trade sectors. The aim is not to stigmatise an entire business ecosystem, but to concentrate regulatory efforts on industries whose products or practices have a proven, lasting and systemic impact on public health, such as tobacco and related devices (vapes, synthetic nicotine), alcohol and spirits (including through cultural marketing strategies), ultra-processed foods high in salt, sugar and trans fatty acids, digital platforms that promote a sedentary lifestyle, disinformation or overconsumption, chemical industries, pesticides and neurotoxic solvents (as highlighted in the case of Parkinson’s);










—


a systematic health impact assessment should be put in place before developing EU trade policies in these sectors, enabling heightened vigilance towards biased industrial financing.
















6.3.


Extending the mandate and resources of the European Centre for Disease Prevention and Control (ECDC), such as coordination with other European agencies (the EMA for medicines, EU-OSHA for health at work):






—


the EESC proposes that the ECDC, which is currently focused on communicable diseases, extend its mandate and resources to include specific monitoring of commercial determinants of health and NCDs. This would include an observatory element that could collect data, analyse trends and make recommendations on prevention policies, in conjunction with the European Commission’s directorates-general. This would make it possible to sustainably anchor prevention of NCDs in the European Health Strategy, while ensuring better coordination of long-term responses;










—


the EESC calls for a three-fold approach – enhanced monitoring, consolidated regulation based on independent multi-factor assessments, coordination of national commitment – to ensure effective, coherent and resilient prevention at EU level.
















6.4.


Incorporating prevention into the next European Multiannual Financial Framework:






—


The EESC takes note of the European Commission’s proposal regarding the 2028-2034 Multiannual Financial Framework and welcomes the funding for health provided for in the Competitiveness Fund and the creation of targeted own resources such as the tobacco tax to help finance prevention policies. However, the EESC regrets that the structure outlined does not include a dedicated health programme, which risks making European health priorities less visible and comprehensible. It calls for health – particularly in relation to prevention, health education and support for health systems – to be given a fundamental place in the future national and regional partnership plan budgets (the NRPPs).
















6.5.


Creating a European ‘healthy business’ certificate and taking inspiration from the social and solidarity economy:






—


the social economy proposes economic models that favour the general interest and that fully incorporate health issues by bringing production and consumption models into line with NCD prevention and reduction objectives;










—


the creation of a European ‘healthy business’ certificate would allow recognition of and support for companies that are taking concrete actions, such as reducing the promotion of harmful products, supporting prevention campaigns, improving working conditions and the transparency of their sectors. However, in order to avoid adverse effects of certification, such as hiding behind it in the case of greenwashing, this certification will need to be based on a rigorous and independent verification system with demanding and evolving criteria.
















6.6.


Bringing European policies into line with WHO and UN objectives:






—


the EU must take its fight against commercial determinants of health to an international scale, following the recommendations of global organisations on NCDs and bringing its policies in line with Sustainable Development Goal 3.4, which aims to reduce premature mortality due to NCDs.










Brussels, 18 September 2025.


The President


of the European Economic and Social Committee

Oliver RÖPKE
               





(1)  WHO, Commercial Determinants of Health, 2023.

(2)  European Commission (2021 and subsequent): Healthier Together: EU Non-Communicable Diseases (NCDs) Initiative; World Health Organization (2024): Report on the Commercial Determinants of Noncommunicable Diseases; European Commission and OECD (2024): Health at a Glance: Europe 2024: risk factors and prevention of NCDs; European Commission (2021): Europe’s Beating Cancer Plan; Eufic (2025): Obesity in Europe; Task Force on Fiscal Policy for Health (2024): Report on industrial pressure: lobbying by the sugar industry.

(3)  European Trade Union Institute (ETUI) (2025): The cost of psychosocial exposure in the workplace; European Commission and OECD (2024): Health at a Glance: Europe 2024; EU-OSHA (2017): An international comparison of the cost of work-related accidents and illnesses; European Commission, DG EMPL (2011): Socio-economic costs of accidents at work and work-related ill health.

(4)  Shan, L, Heusinkveld, H. J., Paul, K. C. et al. 
Towards improved screening of toxins for Parkinson’s risk
, npj Parkinsons Dis. 9, 169 (2023).

(5)  WHO, Shifting towards fiscally resilient, healthy societies, 2024.

(6)  
            https://ec.europa.eu/newsroom/sante/newsletter-archives/60029.

(7)  
            https://ncdalliance.org/resources/dispelling-health-harming-industry-myths-ncds.

(8)  
            https://preventncd.eu/.


ELI: http://data.europa.eu/eli/C/2026/3/oj
ISSN 1977-091X (electronic edition)