Notification Detail | TRIS - European Commission

Draft law ‘Amendments to the Handling of Alcoholic Beverages Law’

Notification Number:

2024/0351/LV (Latvia)

Date received:

01/07/2024

End of Standstill:

02/10/2024 (03/01/2025)

Issue of comments by:

Spain

Poland

Issue of detailed opinion by:

Romania

Czechia

Italy

European Commission

Draft Text:

LV LT MT PL PT RO SK SL ES SV BG HR CS DA NL EN ET FI FR GA DE EL HU IT

Impact assessment:

LV EN

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Communication from the Commission - TRIS/(2024) 1700

Directive (EU) 2015/1535

Notification: 2024/0351/LV

Notification of a draft text from a Member State

Notification – Notification – Notifzierung – Нотификация – Oznámení – Notifikation – Γνωστοποίηση – Notificación – Teavitamine – Ilmoitus – Obavijest – Bejelentés – Notifica – Pranešimas – Paziņojums – Notifika – Kennisgeving – Zawiadomienie – Notificação – Notificare – Oznámenie – Obvestilo – Anmälan – Fógra a thabhairt

Does not open the delays - N'ouvre pas de délai - Kein Fristbeginn - Не се предвижда период на прекъсване - Nezahajuje prodlení - Fristerne indledes ikke - Καμμία έναρξη προθεσμίας - No abre el plazo - Viivituste perioodi ei avata - Määräaika ei ala tästä - Ne otvara razdoblje kašnjenja - Nem nyitja meg a késéseket - Non fa decorrere la mora - Atidėjimai nepradedami - Atlikšanas laikposms nesākas - Ma jiftaħx il-perijodi ta’ dewmien - Geen termijnbegin - Nie otwiera opóźnień - Não inicia o prazo - Nu deschide perioadele de stagnare - Nezačína oneskorenia - Ne uvaja zamud - Inleder ingen frist - Ní osclaíonn sé na moilleanna

MSG: 20241700.EN

1. MSG 001 IND 2024 0351 LV EN 01-07-2024 LV NOTIF

2. Latvia

3A. Ekonomikas ministrija

3B. Veselības ministrija, tālrunis: +371 67717480, e-pasts: vm@vm.gov.lv (elena.zviedre@vm.gov.lv)

4. 2024/0351/LV - C51A - Beverages

5. Draft law ‘Amendments to the Handling of Alcoholic Beverages Law’

6. Alcohol, alcohol trade

7.
Regulation (EC) 1924/2006 concerning nutrition and health claims made on foods: Article 23
Regulation (EC) 1924/2006 requires that the majority of prepacked foods must have a nutrition and energy value. In turn, mandatory information on nutritional value, incl. the energy value according to Article 41 of Regulation 1169/2011 cannot be applied to alcoholic beverages whose alcohol content exceeds 1.2 percent by volume, and Member States themselves can apply national legislation on the list of ingredients to alcoholic beverages.

8. The requirements of the draft law, which are to be brought into line with the European Commission:
• Include on the labelling of alcoholic beverages information in the form of pictograms that encourage citizens not to use alcohol during pregnancy and when driving;
• Include information on ingredients, nutritional value, including energy value, on the labelling of alcoholic beverages, which would inform consumers about the food;
• Alcoholic beverages purchased on the website or mobile application are allowed to be delivered to the buyer at the earliest after six hours from the time of ordering.

Additional requirements included in the draft law:
• Require that information be provided at retail outlets with a warning that alcoholic beverages should not be consumed by minors and that their use has a negative impact on health;
• Ban on offering alcoholic beverages free of charge in gaming arcades and casinos and banning their sale, use, transfer to gaming machines, gaming desks and other gambling equipment;
• Limit the selling time for alcohol (Monday to Saturday, 10:00 a.m. to 8:00 p.m; Sundays, 10:00 a.m. to 6:00 p.m.)
• Prohibit the marketing of alcoholic beverages containing more than 22 % alcohol, with a capacity not exceeding 0.2 litres, filled in plastic (PET) packaging;
• Ban the advertising of prices and discounts for alcoholic beverages in printed media and printed materials, cinemas and the internet;
• Ban promotion measures (sales, etc.), including “2 for the price of 1” or “buy more bottles of alcoholic beverages at a lower price”, etc., and ban the promotion of discounted purchases of alcoholic beverages as part of the loyalty scheme.

9. The draft law aims to protect the interests of public health, in particular children and young people, by introducing evidence-based complex measures that not only limit the advertising and accessibility of alcoholic beverages, but also to ensure public awareness of the health effects of alcohol consumption. By introducing the requirements contained in the draft law, the aim is to reduce the consumption of registered absolute alcohol in litres per population aged 15 years and over, to reduce the proportion of at-risk users over the past year, and to reduce long-term alcohol-related illnesses and mortality from alcohol consumption (e.g., liver cirrhosis, traffic accidents, drowning, injuries, suicides).
According to data from the OECD ‘Health at a glance 2023’ report, recorded alcohol consumption in Latvia is the highest among the countries of both the European Union and the Organisation for Economic Cooperation and Development, at 12.1 litres per inhabitant, excluding tourist consumption [https://www.oecd.org/health/health-at-a-glance/]. The at-risk consumption of alcohol among the Latvian working-age population is also relatively high (40%) [Centre for Disease Prevention and Control. Study on the health behaviour of Latvian citizens. (Have used 6 doses of alcohol per in one drinking session): http://petijumi.mk.gov.lv/sites/default/files/title_file/Latvijas_iedziv_veselibu_ietekmejoso_paradumu_petijums_2018_Zinojums.pdf] and above the World Health Organisation (WHO) European region average (30.4%). At the same time, alcohol consumption in Latvia generates significant monetary costs, estimated in a study carried out in Latvia in 2023 at between 1.3% and 1.8% of GDP [https://esparveselibu.lv/sites/default/files/2023-10/Gala%20ziņojums.pdf], which is approximately twice as much as the income from alcohol excise duty.
In view of the available statistical data for Latvia, a comprehensive policy shall be implemented and a framework developed that restricts the advertising and marketing of alcoholic beverages, restricts the physical availability of alcohol, and provides additional information to consumers on its composition and harmfulness.

Placing additional labelling of alcoholic beverages on alcoholic beverages produced in Latvia and introduced from other countries would give consumers the right to know the nutritional value, energy value, and product ingredients of alcoholic beverages, similar to those applicable to wines in the European Union and to food products. This would enable consumers to make informed choices as to what drinks to use and in what quantities, and to alert certain groups of the public to whom the consumption of alcoholic beverages is dangerous to health. Such and similar requirements are already in place in other EU Member States.
Only the display of warning pictograms will apply to beverages produced in small alcoholic beverage breweries. The expected transition period is around 3 years. The requirement would enter into force on 1 January 2028. Beverages produced before that date will be able to be distributed until the end of their stocks or the expiry date determined by the manufacturer.
Although it is initially planned that, as part of Europe’s Beating Cancer Plan, the European Commission will review and encourage the development of common labelling requirements for alcoholic beverages in 2022 and 2023, such legislation has not yet started and Latvia, as a Member State, is entitled to draw up independent regulations under European law.
The supply of alcoholic beverages purchased on a website or mobile application to the buyer at the earliest six hours after ordering would reduce the physical accessibility of alcoholic beverages and the impulsive purchase of alcohol. This requirement should be brought into line the European Commission, as it may have an impact on organisational processes of traders in neighbouring countries of Latvia that alcoholic beverages bought online can be delivered within six hours.
According to the WHO recommendations to reduce alcohol consumption and its consequences, limiting the availability of alcoholic beverages is one of the recommended directions for a more effective reduction of alcohol consumption and its consequences. Limiting the purchase of alcohol is one of the solutions to reduce the high consumption of alcohol among the population. At the same time, the WHO’s European Alcohol Action Plan 2022–2025 [WHO Europe region, 2022, European framework for action on alcohol 2022-202https://www.drugsandalcohol.ie/37045/13/WHO_72nd_meeting_Framework_on_Alcohol-220604.pdf] highlights the need to focus on strategies to limit the availability of alcoholic beverages, given the rapid development of distance sales of alcoholic beverages in the Member States.
Until 2020, the sale of alcoholic beverages through a distance contract was prohibited in Latvia, but during COVID-19, to reduce people’s gatherings in retail outlets, it was allowed, thus making alcohol more accessible to the public. In Latvia, narcologists have drawn attention to the fact that the sale of alcohol on the internet has posed a significant risk in terms of increasing the availability of alcoholic beverages, resulting in particular in the behaviour of at-risk users of alcohol. Moreover, it should be noted that a European study on the impact of the COVID-19 pandemic on alcohol consumption concluded that Latvia was the only country among the 18 countries in the European region included in the study where the frequency of alcohol consumption increased during the COVID-19 pandemic. In particular, alcohol consumption increased among people who already had alcohol-related problems before the pandemic [Kilian C., Neufeld M., Manthey J., et al. (2022) Self-reported changes in alcohol and tobacco use during COVID-19: findings from the eastern part of the WHO European Region]. Although no studies have been carried out in Latvia on the impact of certain legislative changes on alcohol consumption, in other countries such studies have been carried out in recent years, including studies on the impact of distance sales of alcoholic beverages on people’s drinking habits. Studies show that the purchase of alcohol via the internet during the COVID-19 pandemic was associated with increased alcohol consumption and associated risks [Huckle, T., Parker, K., Romeo, J.S., & Casswell, S. (2021). Online alcohol delivery is associated with heavier drinking during the first New Zealand COVID-19 pandemic restrictions. Drug and alcohol review, 40(5), 826-834]. Other evaluations [Duthie, C., Pocock, T., Curl, A., et al. (2023). Online on-demand delivery services of food and alcohol: A scoping review of public health impacts. SSM-Population Health, 101349] also indicate that alcohol sales on the internet could contribute to alcohol overconsumption and the associated risks.
The requirement is subject to a transitional period with the date of entry into force on 1 June 2025.

10. References to the primary text:

11. No

12.

13. No

14. No

15. Yes

16.
TBT aspects:
The draft is a technical regulation or a conformity assessment
The draft has significant impact on international trade

SPS aspects: No

**********
European Commission
Contact point Directive (EU) 2015/1535
email: grow-dir2015-1535-central@ec.europa.eu

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BACKGROUND:

On 1 July, the Latvian government notified under TRIS 2024-0351-LV the “Draft law ‘Amendments to the Handling of Alcoholic Beverages Law’”. The proposal covers areas such as packaging, labelling, marketing and availability of alcoholic beverages. The notification opened up a standstill period until 02 October 2024, during which Member States and/or the Commission can issue Comments or Detailed Opinions to the TRIS notification.

Whilst a number of the mandatory labelling particulars are already voluntarily implemented by brewers across Europe (88% of beer labels energy values; 95% of beer labels ingredients; many beers already include logos advising against consumption when pregnant or when driving), the proposals contain many provisions that are unclear, potentially in contradiction with existing EU legislation or in breach of the EU treaties, discriminating against beer brewers and creating disproportionate barriers to trade.

We invite the Commission and Member States to issue Detailed Opinions addressing the critical points.

Critical points:

The draft law introduces restrictions on packaging format. From 1st of January 2028, the sale of alcoholic beverages of more than 5.8% abv will be prohibited in containers larger than 0.5L, and the sale of alcoholic beverages of less than 5.8% abv will be prohibited in containers larger than 1L. These provisions are disproportionate, do not respect the freedom of producers and restrict consumers’ choice. Also, some sources have indicated parts of these provisions already exist in Latvian law. If that is the case, the Latvian government should also clarify the situation and explain why this is renotified or else what is changing.
The provisions concerning the mandatory nutrition declaration must be clarified and renotified. The current proposal is incoherent, as it states the nutrition declaration can be limited to energy value only, but still ask for the full nutrition declaration (the Big 7) to be provided. The Latvian government should clarify whether the nutrition declaration needs to be provided in full or can be limited to the energy value only (as currently allowed by the Food Information to Consumers regulation 1169/2022/EU).
The law introduces a discriminatory treatment of lower alcohol beverages with regard to exemptions from providing the mandatory nutrition declaration and the list of ingredients. The provisions state that “alcoholic beverages produced in small distilleries” would not have to bear the nutrition declaration and the list of ingredients, creating discrimination vis-à-vis other alcoholic beverages, including those produced in small breweries. The Commission should invite the Latvian government to ensure a level-playing field for all alcoholic beverages concerning this rule.
The law seems to be in breach of EU law by stating that, in addition to the mandatory list of ingredients, “information on substances or products causing allergies or intolerances shall be directly indicated on the packaging or attached label”. Reg. 1169/2022/EU dictates that the allergen declaration should not be repeated on the labelling when it is already given through the list of ingredients.
The provisions concerning the pregnancy and drink-driving pictograms should be clarified. It is currently impossible to assess whether the measure is proportionate or not as there are no clear instructions concerning the pictograms. In some countries (France and Lithuania, and soon Ireland), a pregnancy pictogram is already mandatory. Latvia should ensure mutual recognition of products bearing such pictograms without the need to redesign for the Latvian market.
The draft text introduces a discriminatory treatment between physical retail outlets and online sales of alcoholic beverages since there must be a 6-hours delay between the time of sale and the time of delivery for online sales of alcoholic beverages (where there is no delay between order and delivery at physical retail outlets). In addition to being discriminatory between types of companies, it further restricts consumer freedom and choice. This provision should be deleted from the draft proposal of the Latvian government.
In retail locations, there must be a “prominent displayed sign” that “must warn that the consumption of alcoholic beverages has negative health effects, alcoholic beverages cannot be sold to minors and minors may not purchase, consume or possess alcoholic beverages.” This will apply as of the 1st of June 2025. The Latvian government should clarify the content and format of this sign as it is currently impossible to assess whether this is a proportionate measure.

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CEEV POSITION

Comité Européen des Entreprises Vins (CEEV) is providing comments to the Latvian draft law titled "Amendments to the Handling of Alcoholic Beverages Law”, notified by the Latvian authorities to the European Commission through the TRIS process in July 2024, to support fair internal market and trade rules.
The wine sector fully supports the Latvian authorities' goal of combating harmful alcohol consumption.
Despite its intention to improve public health, the Latvian Draft Law, as proposed, unfortunately raises some concerns:

I- ALIGNMENT ISSUES WITH EU LABELLING RULES
• Need to ensure that the list of ingredients can be provided by electronical means
We appreciate the Latvian authorities’ initiative to incorporate the EU wines labelling rules in its national legislation. However, the proposed Article 7 as notified via the TRIS process, appears to go beyond the EU requirement, by imposing the provision on label of the list of ingredients.
According to EU Regulations 1308/2013 and 1151/2012, as amended by Regulation (EU) 2021/2117, the provisions of the list of ingredients can be done on the label, or under certain conditions, through digital means.
We call on the Latvian authorities to clarify that the Article 7 will be written in a way that will be fully in line with the recently adopted EU wine labelling rules.
• Importance to take into account upcoming EU legislation on the provision of health-related information/guidance
The EU wine sector is committed to providing consumers with transparent, accurate and science-based
information related to the characteristics of wine products, as well as how to enjoy a moderate consumption
of wine as part of a balanced lifestyle. It also wants to provide consumers with relevant information to make
informed choices on whether to drink.
While our sector fully supports initiatives aimed at preventing alcohol consumption by pregnant women and drink driving, we ask the Latvian authorities not to define new labelling rules only applicable for Latvia before the publication of a European Commission’s proposal on this matter.
Harmonised legislation and Single Market are two of the greatest EU achievements and key assets for EU
wine companies and EU citizens. The use of pictograms should allow for a universal, language-free, system of communication that could adequately provide actionable guidance to customers while protecting the EU Single Market. As some logos are already used in other markets or voluntarily provided by some operators in the EU and beyond, it would also be important to take into consideration mutual recognition and harmonisation.

II- NEW LABELLING RULES UNDERMINING FREE MOVEMENT OF GOODS
• New requirements to provide consumption guidance logos would lead to Latvia specific labels
The Latvian draft law would require imported products to comply with local regulations, forcing manufacturers and importers to modify labels specifically for the Latvian market, hence creating barriers to trade and hindering the good functioning of the Single Market.
In addition, the concrete modalities of implementation of these measures are not detailed as the notified draft law only evokes “other visual elements (e.g., bordelines, background drawing, or colour)”. This makes impossible for the sector and Member States to precisely assess the concrete impact and efficiency of the proposed measure.
If the labelling requirements are unjustified, they may be considered measures equivalent to quantitative restrictions, which are prohibited by Article 34 of the TFEU.
As the EU will be working on a harmonised set of rules regarding the provision of health information for alcoholic beverages, we ask Latvia not to create such trade disruption and wait for a European framework on this specific issue.

III- IMPORTANCE OF PROPORTIONALITY & SCIENTIFIC EVIDENCE
• Health-related information/guidance should focus on harmful use of alcohol, not consumption per se
Article 2, which amends Article 6(2) of the current Latvian law, requires retail locations to display warnings about underage drinking and the health risks of alcohol consumption.
However, this provision does not distinguish between moderate and harmful alcohol use and fails to acknowledge more than four decades of independent scientific research.
Broad statements, warning about the danger of alcohol consumption whatever the drinking pattern (quantity, frequency, context of consumption), do not provide guidance on individual health risks to customers who chose to consume alcoholic beverages in the context of everyday life, or help them reduce excessive drinking.
Consumers should receive actionable guidance and information based on scientific evidence, and aimed at addressing the harmful use of alcohol as stated in the WHO Global Strategy, and related Action Plans, endorsed by Member States.

IV- RECOGNITION OF EXISTING INITIATIVES
According to the latest statistics produced by WHO and one of the world’s leading studies assessing the burden of disease (Global Burden of Disease), alcohol-related harms are decreasing in Latvia, and we welcome these positive trends. Indeed between 2010 and 2021 we saw:

2010 - 2019
• 17.5% reduction in the rate of age-standardized alcohol-related deaths
• 15.3% reduction in the rate of age-standardized alcohol-related disability

2010 - 2021
•    11% reduction in total attributable mortality
•    49% reduction of attributable morbidity for ages <20
•    34% reduction of attributable morbidity from road injuries.

• Wine in Moderation program
While the above data highlights the positive direction in which Latvia is moving, we acknowledge that more needs to be done to address harmful drinking patterns. We stand ready to collectively (the wine sector, government, and communities) accelerate this trend. Through initiatives such as Wine in Moderation, the wine sector actively promotes moderate and responsible drinking among those who chose to drink, and actively works towards reducing minors' exposure to alcohol advertising. [Cfr. WIM Communication Standards]. It represents a collective effort within our sector, a proactive approach, and a deep understanding of the science behind traditions, diets, lifestyles, and overall well- being. Based on the latest scientific information and through national and international campaigns (Wine in Moderation Day), through the future launch of a training on responsible service targeting a large network of professionals, and by empowering professionals and consumers to always enjoy wine moderately and responsibly, the wine sector aims and works towards a sustainable culture of wine.

•    Sharing tools and best practices to prevent minors from purchasing alcohol
It is our understanding that one of the main objectives of Article 2 is to ensure alcohol cannot be purchased by minors. On this issue, one of the main challenges is to ensure that ID controls actually take place in the retail outlets. To address this specific point, the International Alliance for Responsible Drinking (IARD) has launched free online training tools designed to support retailers and hospitality venues across the world in their efforts to ensure that their staff who sell or serve alcohol do so lawfully and responsibly. The online courses are available here and focus on:
-    The importance of verifying a customer's age and sobriety during in-store purchases or service.
-    The consequences of selling alcohol to those underage and intoxicated people.
-    Communication techniques to refuse sale and service of alcohol where necessary and to handle difficult situations.
-    Methods server staff can use to better promote and support responsible choices.
-    Advice on appropriate ways to respond if server staff are asked directly for drinking advice.
These useful tools, available freely for all, can be used to give staff the confidence to deny sales and service where necessary.

In light of the above, CEEV requests the Latvian government to:
1)    Clarify that the labelling requirements on the provision of ingredients information are in line with EU law.
2)    Wait for and eventually align with harmonised EU rules on the provision of responsible consumption logos for alcoholic beverages, in consultation with the sector.
3)    Withdraw its draft law or to the European Commission and other EU Member States to issue, under the TRIS procedure, a detailed opinion on the Latvian draft law against its adoption in its current form.

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EUROPEAN ALCOHOL POLICY ALLIANCE (EUROCARE) POSITION ON

Notification of the Draft law ‘Amendments to the Handling of Alcoholic Beverages Law’

TRIS Notification Number: 2024/0351/LV

THE EUROPEAN ALCOHOL POLICY ALLIANCE (EUROCARE) is an alliance of non-governmental and public health organisations with around 50 member organisations across 23 European countries advocating the prevention and reduction of alcohol related harm in Europe. Member organisations are involved in advocacy and research, as well as in the provision of information to the public; education and training of community care workers; the provision of workplace and school-based programmes; counselling services, residential support and alcohol-free clubs for people with alcohol use disorders.

The mission of Eurocare is to promote policies to prevent and reduce alcohol related harm, through advocacy in Europe. The message, in regard to alcohol consumption, is “less is better”.

Introduction

On 1 July 2024, the Latvian government notified the European Commission of the “Draft Law ‘Amendments to the Handling of Alcoholic Beverages Law’” (TRIS 2024/0351/LV). This proposal aims to restrict the advertising and marketing of alcoholic beverages, limit the availability of alcohol, and provide consumers with information on ingredients, nutritional content, and the risks associated with alcohol consumption.

We urge the European Commission to support Latvia in its efforts to address alcohol related harm and provide a detailed opinion on the Draft Law to facilitate its adoption, ensuring that the health and well-being of the Latvian population are prioritised over economic interests.

We applaud the Latvian Ministry of Health for their admirable efforts in advancing the ‘Amendments to the Handling of Alcoholic Beverages Law’. To enhance the effectiveness of the Draft Law, we strongly encourage the Latvian Government to better align the Draft Law with the WHO Best Buys:

Renew the National Alcohol Action Plan. This will ensure a responsive, cross-sectoral approach to address alcohol harm as a public health priority.
Prohibit all forms of alcohol advertising. This recognises the clear link between alcohol marketing and increased consumption, particularly among youth and other vulnerable groups.
Mandate cancer warnings. This aims to raise public awareness, as current knowledge is insufficient. Only one in four people in Latvia are aware that alcohol use causes cancer.
Avoid electronic labelling such as QR codes. Clear, on-label warnings are considerably more effective in communicating health risks to consumers than electronic alternatives.
Limit alcohol availability to youth. Young people are especially vulnerable to alcohol's effects, leading to risky behaviours and long-term social and health issues. Therefore:
1. Introduce total bans on sales at events involving minors.
2. Limit the density of alcohol outlets.
3. Raise the minimum legal age for purchasing and consuming alcohol to 20, aligning it with tobacco regulations set to take effect in 2025.
Establish regular evaluation mechanisms. Continuous assessment will ensure that interventions remain effective and responsive to emerging public health challenges.

Context

Latvia: the highest per-capita alcohol consumption in Europe

According to the WHO, the European Region has the highest levels of alcohol consumption and bears the greatest burden of alcohol-related harm globally. Of the 10 countries with the highest per-capita alcohol consumption in the region, seven are within the EU. Leading this list is Latvia, where alcohol consumption reached 12.4 Liters per capita in 2023, a significant increase from 9.8 Liters in 2010.

Per-capita alcohol consumption is closely related to the prevalence of alcohol-related harm. In 2022, only half of Latvians reported being in good health. Nearly 80% of the population consumed alcohol in 2022. Around 60% of men aged 35 to 44 engaged in binge drinking, which presents immediate health risks. Alcohol use in the country is linked to a range of serious outcomes, including cardiovascular and liver diseases, cancers, road injuries, drownings, violence, and suicides. Driven by unhealthy behaviours and made worse by Latvia having one of the lowest healthcare funding in the EU, mortality rates from preventable and treatable conditions significantly exceed EU averages.

Early alcohol use among Latvian youth predicts problems later in life

Alcohol use among children and youth is a special concern, as early consumption is a strong predictor of excessive drinking and related negative outcomes in adulthood. According to the 2019 ESPAD survey, 89% of 15-16 year olds in Latvia had tried alcohol once in their lifetime. Around 38% had engaged in binge drinking in the past 30 days. Additionally, 2023 data from the Emergency Medical Service show an increase in calls related to children who have consumed alcohol, whilst the National Health Service reported a sharp rise in the number of children receiving treatment for alcohol-related mental and behavioural disorders. This aligns with data from the ESPAD survey, which revealed that 80% of Latvian youth reported being able to easily access alcohol if they wished.

Delaying the onset of alcohol consumption among young people is crucial for safeguarding cognitive and neurological health and reducing the risk of long-term brain damage, alcohol dependence, and other alcohol-related harms. Recent data highlights that significant brain development continues throughout adolescence and young adulthood, making the brain highly susceptible to the adverse effects of alcohol, particularly binge drinking. High blood alcohol concentrations increase impulsivity and the risk of injuries, such as those resulting from violence, and in cases of traumatic brain injury, the damage can be permanent and lifelong.

Furthermore, binge drinking during adolescence is identified as a major risk factor for developing dementia later in life. Heavy drinking in adolescence, often in the form of binge drinking, is a critical risk factor for the later development of alcohol dependence. Data from a national study in the US indicates that a significant portion of alcohol dependence cases begin before the age of 21, with two-thirds developing by the age of 25.

The burden on Latvia’s economy

Additionally, a 2022 study commissioned by the Latvian Ministry of Health estimated the costs related to alcohol use in 2021, revealing the substantial societal losses caused by its high prevalence. In the given year, up to 88,620 years in good health were lost due to alcohol use. Around 1.3–1.8 percent of Latvia’s GDP (EUR 290 to 453 million) was lost due to alcohol related health-care expenses, reduced workplace productivity from absenteeism, presenteeism, and premature death, legal and crime-related costs within the judicial system, and increased social services expenditures. Revenues from the excise tax on alcoholic beverages in 2021 accounted only for 0.7 percent of the GDP.

Latvian Government's policy response

In the light of these challenges, on 30 June 2023, the Latvian Government introduced to Parliament comprehensive policy measures aimed at protecting public health with a particular focus on safeguarding children and young people. The notified Draft Law is a key component of these efforts. On 25 April 2024, the Latvian National Council on Alcohol Control announced that alcohol consumption in Latvia has reached epidemic levels, highlighting the urgent need for ambitious measures to address the crisis effectively.

Eurocare’s response

Health protection supersedes economic interests

We extend our sincere congratulations to the Latvian Ministry of Health for their commendable initiative in proposing the ‘Amendments to the Handling of Alcoholic Beverages Law’ aiming to restrict the advertising and marketing of alcoholic beverages, limit the availability of alcohol, and provide consumers with information on ingredients, nutritional content, and the risks associated with alcohol consumption.

Latvia has exercised its rights under Article 36 of the Treaty on the Functioning of the European Union (TFEU) to implement necessary measures in response to the serious and tangible risks posed by alcohol use to public health. This provision allows to derogate from the internal market freedoms of Articles 34 and 35 TFEU, since the protection of internal market is not an end in itself; higher priorities, such as the protection of human health and lives, take precedence. Article 35 of the Charter of Fundamental Rights of the EU reinforces this argument by stating that a high level of human health protection shall be ensured in all Union policies and activities.

The Draft Law: evidence-based initiative

The measures proposed by Latvia align with the WHO’s 'best buy' policies and other recommended strategies, which are recognised as effective approaches to mitigating alcohol-related harm at the population level. These are evidence-based policy solutions that are cost-effective and yield a significant return on investment for governments. The latest revision WHO’s 'best buy' policies was approved by WHO member states at the 76th World Health Assembly in May 2023. The table below illustrates the alignment between the WHO's 'best buys' and the measures proposed in the Draft Law, along with the rationale for these measures.

WHO recommends: RESTRICTING ADVERTISING & MARKETING

Proposed measures in the Draft Law: Prohibit the advertising of prices and discounts for alcoholic beverages, including in print media and online.

Prohibit alcohol promotion tactics, including "2 for the price of 1" deals and offering free alcohol as a gift or compensation with the purchase of a product or service.

Prohibit the promotion of discounted alcoholic beverage purchases through loyalty programmes.

Reasoning: To reduce exposure to alcohol and protect vulnerable groups such as children, adolescents, and abstainers from the pressure to begin consuming alcohol.

WHO recommends: RESTRICTING AVAILABILITY

Proposed measures in the Draft Law: Restrict alcohol sales: Monday to Saturday from 10am to 8pm, and Sundays from 10am to 6pm.

Prohibit alcohol consumption in gaming arcades and casinos.

Mandate a minimum six-hour delay for the delivery of alcohol purchased online.

Reasoning: To prevent easy access to alcohol by young people and other vulnerable and high-risk groups.

WHO recommends: INFORMING CONSUMERS

Proposed measures in the Draft Law: Mandate prominently displayed signs in retail locations warning consumers about the health risks of alcohol consumption, and stating that alcoholic beverages cannot be sold to minors, nor may minors purchase, consume, or possess them.

Require alcohol beverage labels to include pictograms warning against consumption during pregnancy and while driving, as well as information on ingredients and nutritional value, including energy content.

Reasoning: To equip consumers with relevant knowledge and empower them to make healthier choices.

To increase awareness of the harmful effects of alcohol on children and youth.

The Latvian authorities present comprehensive data and relevant information in the impact assessment attached to the notified Draft Law (see also Section 2 of our position). Thereby they have demonstrated that the proposed measures are appropriate to achieve better protection of public health and they do not go beyond what is necessary in order to attain this aim (see Commission Notice Guide on Articles 34-36, TFEU).

However, Eurocare urges Latvia to implement more ambitious measures to more effectively curb alcohol-related harm in society, as outlined in the sections below. Strengthening these actions would lead to more sustainable progress in reducing alcohol related harm and its negative impact on public health.

Opportunities for improvement

The measures proposed under the Draft Law are critically needed to address the alcohol epidemic in Latvia. However, they fall short of fully achieving the policy objectives and require further enhancement to effectively meet the desired outcomes.

The Latvian public health strategy, alcohol policy and the Draft Law could be further strengthened to enhance public health protection by:

Renewing the Latvian Action Plan for Control and Restriction of the Consumption of Alcoholic Beverages and Alcoholism 2020–2022, which was adopted on 30 July 2020. Its successor, the Plan for Improving Preventive Measures and Healthcare Services to Reduce the Prevalence of Alcohol and Narcotic Substance Use for 2023–2025, references the expired 2020 Plan, and falls short of ensuring the continuous and adaptive evolution of Latvia’s alcohol policy according to national needs and contexts and in line with the Global Alcohol Action Plan 2022–2030, adopted by the 75th World Health Assembly. A coordinated, cross-sectoral approach through comprehensive planning is essential to effectively combat alcohol-related harm, which remains one of the greatest threats to public health and citizens' well-being in Latvia.
Prohibiting advertising of alcoholic beverages altogether, not only of prices, discounts and offers. Restricting alcohol marketing is one of the WHO's recommended ‘best buys’ to address noncommunicable diseases (NCDs). Evidence shows a clear link between exposure to alcohol advertising and increased consumption and related harms, with young people being particularly vulnerable. One of the key priorities identified by WHO Member States in the European Framework of Action on Alcohol 2022-2025 is to limit the content and volume of commercial alcohol communications. This includes restricting messages and images to factual content, without connections to celebrities or influencers, or banning all alcohol-related communications altogether in television, radio, films and sports sponsorships. Regulatory frameworks should clearly define what is permitted, with the legal presumption that anything not explicitly allowed is prohibited.
Including information about the causal link between alcohol consumption and cancer on the pictogram warnings.Public awareness about the harms associated with alcohol consumption is low, with many people unaware of the cancer risks associated with even minimal alcohol intake. A 2022-2023 cross-sectional survey conducted across 14 European countries revealed that only 26% of those surveyed in Latvia were aware that alcohol is a cause of cancer. Consumers have the right to be informed about the risks posed by products they consume, including alcohol, which is not an ordinary commodity. This enables them to make informed choices. One of the priorities for action, adopted at the 72nd session of the WHO Regional Committee for Europe in September 2022, is the implementation of mandatory labelling requirements, guided by WHO recommendations. These labels should include nutrition and ingredients as well as health warnings to raise awareness at the point of purchase and consumption about the health risks related to alcohol consumption.

Additionally, we strongly urge the Latvian Government to exclude the option of using electronic means, such as QR codes, for alcohol labelling in the Draft Law. Research demonstrates that relying on QR codes for health information is largely ineffective, as many consumers are unlikely to access online content through these channels. Instead, clear, on-label warnings have proven to be a far more impactful and reliable way of ensuring consumers are properly informed about the dangers of alcohol use.

Further reducing the availability of alcohol to young people. The provisions of the Draft Law target certain environments, such as gaming arcades and casinos. However, since alcohol products currently serve as a form of self-promotion, it is crucial to reduce their physical availability to effectively reduce consumption among young people and the society at large. The European Framework of Action on Alcohol 2022-2025, adopted by WHO Member States at the 72nd session of the WHO Regional Committee for Europe in September 2022, identifies the following priority: considering total bans on alcohol sales at and around sporting and cultural events that involve minors. Other important measures include limiting the number and density of alcohol outlets, as alcoholic beverages in Latvia are sold not only in liquor stores but also in regular grocery stores, markets, and petrol stations.
Additionally, raising the minimum legal age for the sale and consumption of alcoholic beverages is crucial. In Latvia, the minimum legal age to purchase alcohol should at least be aligned with the age for purchasing cigarettes, which from 1 January 2025 will be 20 years of age. Delaying alcohol consumption in young people will help protect their cognitive and neurological health, reducing the risk of long-term brain damage, alcohol dependency, and other related harms. Early intervention will lower the likelihood of future alcohol-related issues, allowing for healthier brain development during formative years.
Incorporating provisions on regular evaluation and revision. While the proposed Draft Law represents a commendable step towards addressing alcohol-related harm among at population level in Latvia, it lacks critical elements needed for ensuring the law’s long-term effectiveness and adaptability. Specifically, the proposal does not clearly define the mechanisms for ongoing evaluation and revision. Although the Draft Law includes a provision for a one-time assessment of the impact of its restrictions on the economy and their alignment with public interests, regular evaluations and timely revisions are crucial to effectively address emerging challenges and measuring the effectiveness of the interventions implemented under the law.

Minimal impact on cross-border trade

The Draft Law introduces additional labelling requirements for alcoholic beverages, classifying it as a draft technical regulation under Directive (EU) 2015/1535. This necessitates notifying the EU Commission to prevent internal market barriers and ensure alignment with EU law.

The Draft Law is expected to have minimal impact on cross-border trade due to the flexibility it grants to producers, retailers, and wholesalers. It permits consumer information to be added via packaging or stickers, allowing imported products to be labelled before sale on the territory of Latvia. The presentation of information aligns with Regulation (EU) No 1169/2011, governing food labelling across the EU. A three-year transition period, effective until January 1, 2028, gives businesses ample time to adapt to the changes.

While the EU is reviewing food labelling regulations under Regulation (EU) No 1169/2011, including for alcoholic beverages, this process is still in the early stages. Many Member States such as Austria and Lithuania already mandate ingredient disclosure, and countries like France and Lithuania require pregnancy health warnings on alcoholic beverages. Ireland recently introduced legislation which is due to come into operation from May 2026 which will provide for comprehensive health information labelling including cancer warnings. These regulations have been accepted by the EU Commission as necessary and proportional to the scale of the alcohol issues in Ireland.

This national-level action is necessary to protect citizens while awaiting EU-wide regulation updates.

Conclusion

The health, economic, and social burdens associated with alcohol consumption in Latvia, the European Union and globally are largely preventable. The ‘Amendments to the Handling of Alcoholic Beverages Law’ represents a historical and commendable effort by the Latvian government to address alcohol related harm at national level.

However, to enhance the effectiveness of the Draft Law, we strongly encourage the Latvian Government to better align the Draft Law with the WHO Best Buys:

Renew the National Alcohol Action Plan. This will ensure a responsive, cross-sectoral approach to address alcohol harm as a public health priority.
Prohibit all forms of alcohol advertising. This recognises the clear link between alcohol marketing and increased consumption, particularly among youth and other vulnerable groups.
Mandate cancer warnings. This aims to raise public awareness, as current knowledge is insufficient. Only one in four people in Latvia are aware that alcohol use causes cancer.
Avoid electronic labelling such as QR codes. Clear, on-label warnings are considerably more effective in communicating health risks to consumers than electronic alternatives.
Limit alcohol availability to youth. Young people are especially vulnerable to alcohol's effects, leading to risky behaviours and long-term social and health issues. Therefore:
1. Introduce total bans on sales at events involving minors.
2. Limit the density of alcohol outlets.
3. Raise the minimum legal age for purchasing and consuming alcohol to 20, aligning it with tobacco regulations set to take effect in 2025.
Establish regular evaluation mechanisms. Continuous assessment will ensure that interventions remain effective and responsive to emerging public health challenges.

We urge the European Commission to support Latvia in its efforts to address the substantial harm caused by alcohol, and provide a detailed opinion on the Draft Law to facilitate its adoption, ensuring that the health and well-being of the Latvian population are prioritised over economic interests.

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The Slovak Alliance of Modern Trade (SAMO) is the first and the largest industry association of modern trade in Slovakia. It was established in 2014 on the initiative of 5 major representatives of the trade sector in Slovakia, who were gradually joined by other companies representing modern trade.

The companies associated in SAMO give work to more than 30,000 employees across Slovakia and indirectly to hundreds of thousands more people from the supply sectors - farmers, food manufacturers, technology suppliers, transport, logistics and security services and other companies.

The primary purpose of our association is to protect the interests of its members, the representatives of modern trade in Slovakia. Here we see the basic prerequisite for them to be able to develop their offer and services for customers in Slovakia.

On 1 July 2024, Latvia TRIS notified its draft law “Amendments to the Handling of Alcoholic Beverages Law”.

Please find below our comments on the requirement of the draft law “Alcoholic beverages purchased on the website or mobile application are allowed to be delivered to the buyer at the earliest after six hours from the time of ordering.”

Despite its intention to improve public health, the Latvian Draft Law, as proposed, raises serious concerns about competition and may create a dangerous precedence for other Member States:

We call for evidence-based policy making and we understand the health problems associated with excessive alcohol consumption.
Based on evidence, we call for targeted measures that have the greatest impact on improving public health.Restrictions on online sales in the requirement of the draft law will not contribute to the draft law's objective.

Comments on the six-hour delay:

The requirement of the draft law, which would introduce that alcoholic beverages purchased on the website or mobile application are allowed to be delivered to the buyer at the earliest after six hours from the time of ordering, will not reduce the volume of alcohol consumed but will lead to distortions of competition in the retail sector.
Restricting online sales does not respect the principles of fair competition and proportionality compared to other forms of retail.
No data is available to justify the differential treatment of online and traditional retailers in order to achieve the objective of the draft law. Restriction of online sales will not help to address the underlying problems of excessive alcohol consumption.
Introduction of a six-hour delay requirement for online sales will lead to a number of changes affecting consumers and retailers, including consumers will purchase alcoholic beverages at a nearby retail outlet, which is already a quicker way to buy alcohol, given the density of retail outlets in urban areas.

Supporting Latvia's Proposed Amendments to the Handling of Alcoholic Beverages Law and Addressing Industry Concerns

The Latvian government's draft law, "Amendments to the Handling of Alcoholic Beverages Law," introduces a comprehensive set of measures aimed at reducing alcohol consumption and mitigating its associated health risks. Given Latvia's high levels of alcohol consumption and the significant public health concerns arising from it, these measures are both timely and necessary. While some industry representatives have raised concerns about the proposed amendments, it is important to address these points and underscore the validity and importance of the measures from a public health perspective.

Addressing alignment with EU regulations

Industry Concern: The proposed labelling requirements clash with existing EU regulations, particularly regarding ingredient listings and pictograms. The industry suggests that EU regulations allow for digital provision of this information and that Latvia should wait for EU-wide harmonization to avoid trade barriers.

Counterargument:

While it is true that Regulation (EU) No 1169/2011 on food information to consumers allows alcoholic beverages to be exempt from mandatory ingredient and nutrition labelling, Article 36 of the Treaty on the Functioning of the European Union (TFEU) permits Member States to introduce measures necessary to protect public health, provided they are proportionate and do not constitute a means of arbitrary discrimination or a disguised restriction on trade.

Moreover, Member States have the right to implement national measures that go beyond EU minimum requirements to address urgent public health concerns. Latvia's alarming alcohol consumption rates justify immediate action rather than waiting for EU-wide harmonization. Requiring on-pack labelling ensures that all consumers, including those without access to digital platforms, receive critical health information at the point of purchase.

Precedents in other EU countries:

France mandates health warnings on alcohol labels, including a pictogram advising against drinking during pregnancy[1].
Ireland has recently enacted legislation requiring comprehensive health warnings and nutritional information on alcoholic beverage labels[2].

These examples demonstrate that national labelling requirements are both permissible and practicable within the EU framework.

Addressing impact on the single market

Industry concern: The draft law's labelling requirements could create barriers to trade within the EU's single market, leading to increased costs and logistical challenges, especially for smaller producers.

Counterargument:

While the industry raises valid concerns about potential costs, the public health benefits of the proposed measures outweigh the potential trade impacts. The measures are designed to be proportionate and non-discriminatory, targeting all alcoholic beverages regardless of origin. Under Article 36 TFEU, restrictions on trade can be justified on grounds of public health.

Furthermore, the proposed three-year transition period until 1 January 2028 allows producers ample time to adjust their labelling processes. This period mitigates potential disruptions and provides flexibility, including for smaller producers.

The long-term economic benefits of reducing alcohol-related harm, such as decreased healthcare costs and increased productivity, can offset initial compliance costs.

Addressing proportionality of measures

Industry Concern: The broad warnings fail to distinguish between moderate and harmful alcohol use. The proposed six-hour delay for online alcohol deliveries is seen as discriminatory and restricts consumer choice.

Counterargument:

Recent scientific evidence indicates that any level of alcohol consumption carries health risks, including increased cancer risk[3]. Therefore, broad health warnings are appropriate to inform all consumers of potential risks. The aim is not to stigmatize moderate consumption but to ensure that consumers are fully informed.

Regarding the six-hour delay for online deliveries, this measure addresses the specific risk of impulsive purchasing associated with immediate availability. Unlike physical retail, where purchasing involves more effort and time, online platforms can facilitate rapid and impulsive access to alcohol. Delaying online deliveries curbs immediate access to alcohol, which can reduce impulsive purchases often associated with binge drinking and alcohol misuse. [4] Studies have shown that immediate access via online platforms correlates with increased consumption and associated harms.[5] This measure is proportionate, targeting a specific mode of sale that poses unique risks.

Addressing existing initiatives and evidence

Industry concern: Alcohol-related harm in Latvia is already decreasing, and existing initiatives like the Wine in Moderation program are effective. The government should focus on supporting these initiatives instead of imposing new restrictions.

Counterargument:

While some progress may have been made, recorded alcohol consumption in Latvia is the highest among the countries of both the European Union and the Organisation for Economic Cooperation and Development, at 12.1 liters of pure alcohol per capita[6]. The prevalence of risky drinking behaviors remains significantly higher than the European average. There are no grounds to claim that any alcohol industry-backed initiatives have been effective in reducing alcohol consumption in Latvia.

Evidence of ongoing challenges:

High prevalence of at-risk drinking: Approximately 40% of Latvia's working-age population engages in risky alcohol consumption.[7]
Economic costs: Alcohol-related harms cost Latvia between 1.3% and 1.8% of GDP, indicating a substantial ongoing burden.[8]
COVID-19 Pandemic Impact: Latvia experienced an increase in alcohol consumption frequency during the pandemic, unlike other European countries.

These indicators suggest that stronger, evidence-based policy measures are necessary to achieve meaningful reductions in alcohol-related harm.

Supporting the proposed measures

Mandatory labelling requirements

Enhancing consumer awareness through on-pack labelling is crucial. Labels are a direct and immediate source of information at the point of purchase. By providing ingredient lists, nutritional information, and health warnings, consumers can make more informed choices, potentially leading to reduced consumption and harm.

Restrictions on alcohol availability and marketing

Limiting the availability of alcohol and restricting aggressive marketing are recognized by the World Health Organization as among the most effective strategies for reducing alcohol-related harm. The six-hour delay for online deliveries specifically targets the impulsivity associated with online purchases, which has been linked to increased consumption.

Alignment with international recommendations

The proposed measures are in line with international best practices and recommendations from health authorities:

WHO "Best Buys"[9]: Implementing restrictions on availability and marketing of alcohol 13.
European Framework for Action on Alcohol 2022–2025[10]: Emphasizes addressing online alcohol sales and implementing policies to limit availability.

Conclusion

The proposed amendments to Latvia's Handling of Alcoholic Beverages Law are proportionate, necessary, and justified responses to a significant public health challenge. In our view the measures are consistent with EU law provisions that allow Member States to enact public health protections.

Latvia's approach is both responsible and aligned with international standards. Implementing these changes is crucial for reducing alcohol-related harm and promoting the health and well-being of the Latvian population.

By proceeding with these amendments, Latvia not only adheres to its commitments under EU law but also demonstrates leadership in public health policy, setting a positive example for other nations.

Nordic Alcohol and Drug Policy Network (NordAN) is a collaborative network of over 60 non-governmental organizations (NGOs) dedicated to reducing alcohol and drug consumption in the Nordic and Baltic countries. Established in 2000, NordAN brings together voluntary organizations from Denmark, Estonia, Finland, Iceland, Latvia, Lithuania, Norway, and Sweden.

These NGOs share a common goal of promoting evidence-based alcohol and drug policies. Unlike many other organizations, NordAN is entirely independent of the commercial alcohol industry, ensuring that its work is driven solely by the best interests of public health and well-being.

www.nordan.org

[1]https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000006687998

[2]https://www.gov.ie/en/press-release/03997-ministers-for-health-bring-into-law-the-worlds-first-comprehensive-health-labelling-of-alcohol-products/

[3]https://www.who.int/europe/news/item/04-01-2023-no-level-of-alcohol-consumption-is-safe-for-our-health

[4]https://www.ncbi.nlm.nih.gov/pmc/articles/PMC9950721/

[5]https://onlinelibrary.wiley.com/doi/10.1111/dar.13222

[6]https://www.oecd.org/health/health-at-a-glance/

[7]https://petijumi.mk.gov.lv/sites/default/files/title_file/Latvijas_iedziv_veselibu_ietekmejoso_paradumu_petijums_2018_Zinojums.pdf

[8]https://esparveselibu.lv/sites/default/files/2023-10/Gala%20zi%C5%86ojums.pdf#page=49&zoom=100,92,481

[9]https://iris.who.int/handle/10665/259232

[10]https://iris.who.int/handle/10665/361662?search-result=true&query=European+Framework+for+Action+on+Alcohol+2022%E2%80%932025&scope=&rpp=10&sort_by=score&order=desc

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CEVI position – TRIS notification 2024-0351-LV

CEVI, the European Confederation of Independent Winegrowers, is the only organisation representing and defending the interests of Independent Winegrowers at European level. Independent Winegrowers are entrepreneurs at the head of micro, small and medium-sized enterprises (SMEs), often a family business. They make everything from the vineyard to the table, meaning that they produce and sell their wines directly (to the consumer), thereby contributing to the vitality of wine-producing regions. CEVI currently represents Independent Winegrowers from 12 European countries. In Europe there are 200,000 Independent Winegrowers.

On 1 July 2024, the Latvian government notified under TRIS 2024-0351-LV the ‘Draft law “Amendments to the Handling of Alcoholic Beverages Law”’. The proposal covers areas such as packaging, labelling, marketing and availability of alcoholic beverages. The measures introduced by this draft law would come into effect on 1 June 2025, except for the labelling requirements, which will be applicable from 1 January 2028. Products ‘manufactured and labelled’ before this date will be allowed to exhaust their stock without a time limit.

The proposal contains several unclear provisions, potentially in contradiction with existing EU legislation or in breach of the EU treaties, discriminating against Independent Winegrowers’ products and creating disproportionate barriers to trade. CEVI invites the Commission and Member States to issue Detailed Opinions addressing the following critical points.

Labelling requirements: lack of clarity, disproportionality, gold plating

Article 7: Mandatory pictograms that encourage citizens not to use alcohol during pregnancy and when driving on the labelling of alcoholic beverages;

The provisions concerning the pregnancy and drink-driving pictogramsfails to provide information about the content or the format of the health message, as the concrete modalities of the implementation of these measures only evoke ‘other visual elements (e.g., borderlines, background drawing, or colour)’. It is currently impossible to assess precisely whether the measure is proportionate or not as there are no clear instructions concerning the pictograms.

Moreover, in some Member States, a pregnancy pictogram is already mandatory. The Latvian draft law would require imported products to comply with another local regulations, forcing Independent Winegrowers to modify their labels specifically for the Latvian market, hence creating additional barriers to trade.

Article 7: Display of information on ingredients and nutritional value on the labelling of alcoholic beverages.

The proposed article 7 as notified via the TRIS process appears to go beyond the EU requirements regarding nutritional labelling, by imposing the provision on the label of the list of ingredients, while, according to EU regulations, the provision of the list of ingredients can be done on the label, or under certain conditions, through digital means. The lack of harmonisation and gold-plating on labelling will create barriers to trade and further increase the financial and administrative burden on businesses and in particular on micro and SMEs.

Harmonised legislation and single market are two of the greatest EU successes and assets for the EU Independent Winegrowers. Such measures will reduce the fluidity of the single market and undermine EU-wide efforts to improve its functioning. Should this be allowed and if other Member States follow suit in adopting similar unilateral disproportionate labelling requirements, the resulting divergences would lead to the fragmentation of the single market. Moreover, Member States should always take into consideration off label modalities to inform the consumers, in line with a process of increased digitalisation.

Furthermore, missing or unclear elements restrict the European Commission, the Member States and stakeholders’ ability to assess the draft law.

CEVI calls on the Latvian authorities to clarify the notified draft law. The future text must be written in a way that will be fully in line with the new EU wine labelling rules and contain the actual details upon which the European Commission and Member States can take an informed position.

Warning message in retail locations: unclear, beyond EU recommendations

Upon article 7 of the notified draft law, there must be a ‘prominent displayed sign’ in retail locations that ‘must warn that the consumption of alcoholic beverages has negative health effects, alcoholic beverages cannot be sold to minors and minors may not purchase, consume or possess alcoholic beverages.’

The notified draft law fails to provide any information regarding the concrete modalities of the implementation of this measure.

In addition, the content of the warning displayed appears to contradict the EU health recommendations about alcohol consumption and fails to acknowledge more than four decades of independent scientific research. On one hand, the Commission has set up the objective to reduce harmful use of alcohol. On the other hand, the European Parliament adopted the report on ‘strengthening Europe in the fight against cancer’ which distinguishes the harmful use of alcohol and moderate consumption and aims at addressing the harmful use of alcohol, an objective that CEVI shares.

CEVI calls the Latvian government to clarify the content and format of this sign as it is currently impossible to assess whether this is a proportionate measure.

In line with European Institutions’ recommendations, a distinction has to be made between the harmful use of alcohol and moderate consumption. CEVI therefore asks for the sentence to be rewritten in the following way: ‘In retail locations, a prominently displayed sign must warn that the harmful consumption of alcoholic beverages has negative health effects.’

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The Latvian Support and Prevention Center “For Your Freedom” urges the European Commission to support Latvia in its efforts to address the substantial harm caused by alcohol, and provide a detailed opinion on the Draft Law to facilitate its adoption, ensuring that the health and well-being of the Latvian population are prioritised over economic interests.

The Draft Law represents a significant effort by the Latvian government to address alcohol related harm at national level. However, to enhance the effectiveness of the Draft Law, we strongly encourage the Latvian Government to better align the Draft Law with the WHO Best Buys:

Renew the National Alcohol Action Plan. This will ensure a responsive, cross-sectoral approach to address alcohol harm as a public health priority.
Prohibit all forms of alcohol advertising, not just prices, discounts and promotions. There is a clear link between alcohol marketing and increased consumption, particularly among youth and other vulnerable groups.
Mandate cancer warnings. In addition to pictograms warning against consumption during pregnancy and while driving, and information on the ingredients and nutritional value of alcoholic beverages, there should be a mandated warning about the causal link between alcohol consumption and cancer. This will raise public awareness, as current knowledge is lacking.
Avoid electronic labelling such as QR codes. Research demonstrates that relying on QR codes for health information is largely ineffective, as many consumers are unlikely to access online content through these channels. Instead, clear, on-label warnings are considerably more effective in communicating health risks to consumers than electronic alternatives.
Limit alcohol availability to youth. Young people are especially vulnerable to alcohol's effects, leading to risky behaviours and long-term social and health issues. Therefore: introduce a complete ban on alcohol sales at events, including sports and cultural gatherings, where minors are present; limit the density of alcohol outlets. Currently, alcoholic beverages are widely available in Latvia, found not only in liquor stores but also in grocery stores, markets, and petrol stations; and raise the minimum legal age for purchasing and consuming alcohol to 20, aligning it with tobacco regulations set to take effect in 2025.
Establish regular evaluation mechanisms. Continuous assessment will ensure that interventions remain effective and responsive to emerging public health challenges.

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We urge the European Commission to support Latvia in its efforts to address the substantial harm caused by alcohol, and provide a detailed opinion on the Draft Law to facilitate its adoption, ensuring that the health and well-being of the Latvian population are prioritised over economic interests.

Renew the National Alcohol Action Plan. This will ensure a responsive, cross-sectoral approach to address alcohol harm as a public health priority.
Prohibit all forms of alcohol advertising, not just prices, discounts and promotions. There is a clear link between alcohol marketing and increased consumption, particularly among youth and other vulnerable groups.
Mandate cancer warnings. In addition to pictograms warning against consumption during pregnancy and while driving, and information on the ingredients and nutritional value of alcoholic beverages, there should be a mandated warning about the causal link between alcohol consumption and cancer. This will raise public awareness, as current knowledge is lacking.
Avoid electronic labelling such as QR codes. Research demonstrates that relying on QR codes for health information is largely ineffective, as many consumers are unlikely to access online content through these channels. Instead, clear, on-label warnings are considerably more effective in communicating health risks to consumers than electronic alternatives.
Limit alcohol availability to youth. Young people are especially vulnerable to alcohol's effects, leading to risky behaviours and long-term social and health issues. Therefore: Introduce a complete ban on alcohol sales at events, including sports and cultural gatherings, where minors are present. Limit the density of alcohol outlets. Currently, alcoholic beverages are widely available in Latvia, found not only in liquor stores but also in grocery stores, markets, and petrol stations. Raise the minimum legal age for purchasing and consuming alcohol to 20, aligning it with tobacco regulations set to take effect in 2025.
Establish regular evaluation mechanisms. Continuous assessment will ensure that interventions remain effective and responsive to emerging public health challenges.

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As the International Youth Health Organization (YHO), we strongly support the amendments to the Handling of Alcoholic Beverages Law in Latvia. These legislative changes represent a crucial step in protecting the health and well-being of youth, a particularly vulnerable group when it comes to alcohol-related harm.

Youth Vulnerability to Alcohol Harm

One of the most significant aspects of this law is its effort to limit the availability and marketing of alcohol, especially to youth. Evidence shows that young people are highly susceptible to the negative effects of alcohol, both physically and mentally. Early exposure to alcohol increases the risk of developing alcohol dependence later in life, and the earlier someone begins drinking, the more likely they are to face long-term health consequences, including brain damage, cognitive impairment, and alcohol addiction.

According to studies cited by WHO, the European region, including Latvia, has the highest levels of alcohol consumption globally, with youth being one of the most affected groups. In Latvia, a worrying 89% of 15-16 year-olds have tried alcohol, and 38% reported binge drinking. These statistics clearly indicate that urgent action is required to protect young people from alcohol-related harm, and this law is an important step in achieving that goal.

Protecting Youth through Advertising and Sales Restrictions

The restrictions on alcohol advertising are a critical component of the amendments. Marketing significantly influences the choices of young people, with research showing that exposure to alcohol advertising leads to earlier initiation of drinking and heavier alcohol consumption among youth. By prohibiting the promotion of discounts and offers, and limiting alcohol advertising in online and printed media, the law helps reduce the exposure of young people to pro-alcohol messages that normalize drinking.

Limiting Alcohol Access to Young People

The amendments also wisely restrict the times and venues where alcohol can be sold, such as prohibiting its sale at gambling venues or during late-night hours. These restrictions are essential in limiting youth access to alcohol. By creating a barrier between alcohol and young people, Latvia is not only preventing underage drinking but also addressing the normalization of alcohol in environments where it is often glamorized.

Promoting Health Literacy and Awareness

The law’s requirements for clear labeling of alcoholic beverages, including health warnings, are also key measures that align with our values of promoting health literacy. Young people often lack full awareness of the risks associated with alcohol, such as its links to cancer and other serious health conditions. By ensuring that alcohol products come with clear, on-label warnings, Latvia is empowering its citizens, particularly youth, to make informed decisions about their consumption.

Advocating for Further Action

While we fully support these amendments, we encourage the Latvian government to consider going even further. Raising the minimum age for purchasing alcohol to 20, as suggested in alignment with upcoming tobacco regulations, would be an even stronger protective measure for youth. Additionally, we advocate for further limitations on alcohol availability, particularly at events involving minors, to create safer environments for young people to thrive.

Conclusion

As an international body representing youth health interests, we applaud the Latvian government for their foresight in introducing these amendments. They represent a critical step forward in addressing the high levels of alcohol consumption in Latvia and mitigating its harmful effects, particularly on youth. We urge other nations to follow Latvia’s lead and prioritize the health of their young populations through similar, evidence-based policies. The protection of youth should always take precedence over economic interests related to alcohol sales, ensuring a healthier future for all.