Analysis of civil society comments to European Commission Green Paper on the role of civil society in drug policy in the EU
After the publication of the Green paper in June 2006, the Commission asked for comments from civil society organisations until 30 september. The Commission received 65 comments. In the beginning of July 2007, a total number of 63 comments were put online, 2 comments were sent by people who wished to remain anonymous.
Read the summary of these comments published by the Commission.
As to the political, social, ideological and geographical backgrounds of the respondents, we can add the following:
Political backgrounds
National Governments: 4 (Estonia, Finland, France, Slovakia)
Local/Regional authorities: 4 (ECAD, Sweden, Catalonian regional government, Spain, London NHS office, United Kingdom, City of Leipzig, Germany)
Not clear if they are (non-)governmental: 4 (DHS, Deutsche Referenstelle für die EMCDDA, Fachverband Sucht, Germany), and Association of Narcotic Police Officers (Sweden)
Individual citizens: 5
NGOs operating locally: 5
National networks, NGOs operating nationally: 21
European/International networks: 20
Social backgrounds
Advocacy work (professional and voluntary): 25
Public health (professional): 21
Policy experts/researchers: 8
Authorities: 9
Ideological background
For acceptance oriented drug policy (harm reduction): 25
For a drug-free society: 18 (among those several from Scientology Church)
For an end to the drug war: 8
Unclear: 12
Geographical background
Belgium: 11
Cyprus: 2
Estonia: 2
Finland: 6
France: 3
Germany: 7
Ireland : 2
Italy : 1
Netherlands : 3
Portugal: 1
Slovakia : 1
Spain : 2
Sweden : 8
Switzerland: 1
United Kingdom: 13
Complete analysis
Governments
1. Estonian government: in Estonian…
Separate technical debate (prevention/treatment) from political debate.
Member States should participate in selection process of participants, as they have better view on their importance in national processes
Need to increment outreach work of organisations especially to youth
3. French government (in French)
French government has already put in place a dialogue process with national civil society. Expresses concern with the way how European Commission will select participants, and how the dialogue will influence on Member States policy.
4. [Slovak government
>http://ec.europa.eu/justice_home/news/consulting_public/drugs_forum/contributions/member_states/contribution_slovak_republic_en.pdf ]
New dialogue should not become another bureaucratic instrument.
Good example: European Network on Smoking Prevention
Civil Society Organisations
5. Addaction, United Kingdom – www.addaction.org.uk
Treatment organisation – affiliated to the European Association for the Treatment of Addiction (mostly based in the UK)
Supports the general idea of a civil society forum combined with Internet based consultation. Promotes the idea of rehabilitation of the addict and supports the inclusion of different stakeholders (including users and especially ex-users, parents, housing providers, employers) in the dialogue.
6. Arts House, United Kingdom – Akzept, Germany – www.akzept.org
National network of acceptance oriented drug organisations, affiliated to ENCOD, IDPC and Correlation.
Supports the idea of a broad forum that is accessible to many organisations, accompanied by a thematic linkage of different networks.
8. Caritas Europe, European Coalition based in Belgium, www.caritas-europa.org
Several of their members are active in treatment and social support to drug users.
Suggests the creation of an observatory of scientific experts to provide top quality expertise on drug policies, which could be used as a basis for the dialogue.
9. Citywide Drug Crisis Campaign, Ireland – no address information
National network of community representatives, of citizens in areas affected by drug scenes.
Suggests the dialogue can be used to spread experiences of community based initiatives. States that repressive policies have not been helpful to solve the problems.
10. Katarina Cnattingius, individual citizen from Sweden.
Says no to a dialogue between civil society and authorities on drug policy. “This policy should be exclusively a matter of elected politicians.”
11. DHS, Deutsche Hauptstelle für Suchtfrage, Germany, www.dhs.de
Network of treatment and research organisations, not clear if they are (non-)governmental
Supports the civil society forum and the internet-based consultation. Suggests to be careful in proposing topics to discuss for the dialogue.
12. Deutsche Referenzstelle fur die EMCDDA, Germany, Email: simon@ift.de
German national contact agency for the EMCDDA, not sure if they are (non-)governmental?
Is concerned with the dialogue could become a coalition of lobby groups.. Proposes to collaborate with the EMCDDA focal points in each Member State (most of them based within the government).
13. DHV, Deutsche Hanf Verband, Germany, www.hanfverband.de
National network of cannabis organisations, affiliated to ENCOD
Supports the ENCOD comments
14. Andria Efthimiou-Mordaunt, individual citizen, United Kingdom, Email: andria3a@yahoo.co.uk
Affiliated to ENCOD
Insists on importance harm reduction and involvement of drug users
15. EMPASA, European Mediterranean Partners Against Substance Abuse, based in Cyprus (no address info)
Not much information on this network.
Supports the idea of a dialogue.
16. EURAD, Europe Against Drugs, European Coalition based in Ireland, [www.eurad.net
>http://www.eurad.net ]
For a Drug Free society.
Supports the dialogue, but is concerned that it would be too open. For instance, drug users should not be allowed to the dialogue, only formal drug users. The group should not become too large..
17. EATG, European AIDS Treatment Group, European Coalition based in Belgium, www.eatg.org
Network of HIV affected people.
No precise comments on the dialogue, wishes to be included.
18. EADPP, European Alliance for Drug Policy and Practice, European Coalition based in Netherlands www.eadpp.eu
This is the rapidly established network of various drug treatment, prevention and research networks that have been set up thanks to EU support during the past years: Correlation, ELISAD, ENDIPP, ERIT, Euro TC, EFUS/DC & D, ITACA, T3E.
Supports the idea of a dialogue but expresses concern with both proposal: open forum and thematic linkage of networks, as they may not fulfil the need of CSO’s or not guarantee them being properly represented.
They offer themselves to be the co-ordinating body between the European Union and civil society…
19. ECAD, European Cities Against Drugs, European Coalition based in Sweden, www.ecad.net
Network of local authorities, not sure if they are (non-)governmental
For a drug free society..
Propose the organisation of the dialogue in two blocks: one for those NGOs who support of the UN Conventions, one for all the rest. Then both blocks can present their arguments.
20. ENCOD, European Coalition for Just and Effective Drug Policies, European Coalition based in Belgium, encod.org
In summary we welcome the proposed dialogue process but question the concrete form that the Commission proposes, above all due to the lack of transparency and the top-down approach applied by the Commission.
21. FEANTSA, European Coalition based in Belgium, [www.feantsa.org
>http://www.feantsa.org ]
European Federation of National Associations Working with the Homeless
Support the idea of a dialogue, insists that also organisations whose core activities are not drug-related are included in the dialogue, such as themselves.
22. Correlation, European Coalition based in the Netherlands, www.correlation-net.org
Network of groups and people working in treatment, social inclusion of drug users, sex workers and other marginalized people. Affiliated to EADPP and IDPC.
Supports the idea of a dialogue, insists on inclusion of people directly affected by drug policies
23. EPHA, European Public Health Alliance, European Coalition, based in Belgium, www.epha.org
Network of organisations working in public health, service providers and advocacy groups.
Inisists on transparency as important element of dialogue, expresses concerns with the question who will be responsible for the selection process. Suggests to connect the dialogue to the Public Health Policy Forum, an already existing dialogue with CS and EU on health policy.
24. Fachverband Sucht, Germany, www.sucht.de
Treatment agency affiliated to DHS, is this a (non-)governmental organisation?
Questions the process, particularly the way that organisations will be selected, how to assure that they are representative, how will dialogue influence existing instruments like EMCDDA, distinction between legal and illegal drugs.
25. ERIT, European Professionals Working the Field of Drug Abuse, European Coalition based in the UK, contact dave@sdf.org.uk
Network of experts in treatment, affiliated to IDPC, EADPP.
Criticizes Commission for being too distant from civil society, CSO’s should not only give feedback but also participate in implementation, in order to increase “ownership” of drug policy.
Supports the thematic linking of networks in stead of an open forum (which could become too dominated by ideological debate), insists on theme of social inclusion, mentions need for funding opportunities.
26. SKY, Finnish Cannabis Association, Finland, www.sky.org
Cannabis association, affiliated to ENCOD
Forum should have a formal character, direct encounters with politicians with a formal agenda is fruitful.
27. Foundation for a Drug Free Europe, European Coalition based in Belgium, www.fdfe.org
For a drug free society, related to Scientology Church..
Concerned with the open character of the forum. It should be protected against the “legalisers”. Based on electoral reality, drug users and legalisers can only play a minority part in the discussion.
28. Generalitat de Catalunya, Regional authority of Catalonia, Spain (no contact address)
Harm reduction approach. Are they a (non-)governmental organisation?
A very long text, critical of the dialogue process, observing issues like the impact of the dialogue on decision-making processes, need to establish simple structures that are easily recognisable for civil society organisations.
29. GAT, Grupo Portugues de Activistas sobre Tratamientos VIH/SIDA, Portugal, contact gatcontactos@clix.pt
In Portuguese… I think their main concern is that people affected by drug policies should be involved.
30. HPPRY, Finnish Association for a Humane Drug Policy, Finland, www.hppry.org
Drug policy reform organisation, affiliated to ENCOD
Insists on need to make dialogue accessible to different voices.
31. Hans Hüsgen, individual citizen, Germany, contact hansahuesgen@compuserve.de
In German, difficult to understand what is meant here.
32. IDPC, International Drug Policy Consortium, International Coalition based in the UK, www.idpc.info
Network of treatment and research organisations, oriented towards “evidence based” drug policies
Suggest to make a smaller group inside the forum in order to provide input to decision making agenda, and suggest to select the participants through national forums.
33. IUHPE, International Union for Health Promotion and Education, Finland, www.iuhpe.org
Network of Finnish organisations of mainly abstinence oriented organisations.
Suggests increased involvement of organisations who are not primarily involved with drug issues, but whose work is related.
34. IREFREA, European Coalition based in Spain, www.irefrea.org
European network of people working on prevention, mainly based in Spain
Concerned with lack of effectiveness of the dialogue, prefers linking people with same thematic background, creating a common language.
35. JMT, John Mordaunt Trust, United Kingdom, www.usersvoice.org.uk
Co-ordinated by Andrea Efthimiou-Mordaunt, affiliated to ENCOD
Supports involvement of drug users in dialogue and inclusion of AIDS issue
36. KENTHEA, Cyprus, same contact person as EMPASA, but no contact information or background details on what this organisation is about.
Insists that the dialogue should be limited to non-governmental actors..
37. KSAN, Swedish Women’s Council on Drugs and Alcohol Issues, Sweden, www.ksan.se
Abstinence approach, but socially oriented, promotes the role of voluntary organisations and especially women in the dialogue.
38. Lars Erik Larsson, individual citizen, Sweden
Says no to a dialogue between civil society and authorities on drug policy. “This policy should be exclusively a matter of elected politicians.”
39. London Drug Policy Forum, United Kingdom, www.cityoflondon.gov.uk/ldpf
Network of treatment and prevention agencies in the city of London
Is supportive of any kind of exchange, insists on taking a broad scope, offers its expertise.
40. MTU, Me aitame sind, Estonia No contact information
All in Estonian, sorry
41. Narconon, International Coalition based in Italy, www.narcononeu.dk
For a drug free world, related to FDFE, Scientology Church
Criticizes tolerant attitudes towards drugs..
42. RNS, National Association for a Drug Free Society, Sweden, www.rns.se
For a drug free world..
Expresses concern with the option work along thematic expertise, out of fear that this will dominated by “treatment” agencies, also against too big influence of transnational networks. But propose that the dialogue should be as free and flexible as possible.
43. FMN, National Swedish Parents Anti-Narcotics Association, Sweden, www.fmn.org.se
For a drug free world, affiliated to EURAD
Says no to a dialogue between civil society and authorities on drug policy. “Our government and the citizens of Sweden know best our demands and what we need in our country.”
44. SDB, Stichting Drugsbeleid, Netherlands, www.drugpolicy.nl
Drug policy reform organisation, affiliated to ENCOD
Insists on an open approach to dialogue, no prejudices, need for diversity, on the basis of evidence, for instance the EMCDDA reports.
45. FREE FROM DRUGS, Finland, www.irtihuumeista.fi
Not clear which approach they prefer.
Insist on need to have representative participants in forum, including (former) drug users.
46. NHS, National Health Service, London EU Unit, United Kingdom, associated to LDPF
Local section of a national health authority Is this a (non-)governmental organisation?
Same answers as LDPF.
47. NON A LA DROGUE, SI A LA VIE, France, www.nonaladrogue.org
For a drug-free world, related to Scientologist Church
Supports the fight against the banalisation of cannabis.
48. PGEU, Pharmaceutical Group of the European Union, European Coalition based in Belgium, www.pgeu.org
Lobby group of community pharmacists. Promotes harm reduction like needle exchange and heroin substitution.
Suggests increased involvement of organisations who are not primarily involved with drug issues, but whose work is related.
49. RETHINK, United Kingdom, www.rethink.org
Treatment agency for the mentally ill.
Proposes special attention in the dialogue for the position of the mentally ill.
50. Royal College of Nursing, United Kingdom, contact: gensec.dept@rcn.org.uk
Organisation of nurses.
Promotes the inclusion of “not only drug-related organisations”, and suggests a simple structure.
51. SDF, Scottish Drugs Forum, United Kingdom, contact dave@sdf.org.uk
Affiliated to ERIT, supports their comment.
52. Senlis Council, International Coalition based in France, www.senliscouncil.net
Network of drug policy experts, reform-oriented
Suggests to give the dialogue a formal character, but expresses concern with the “competences” of civil society organisations, especially around the issue of the “supply reduction problem”.
53. Smoke Free Partnership, European coalition based in the United Kingdom, www.globalsmokefreepartnership.org
Network of anti-cancer and lungdisease institutes (subsidised among others by the pharmaceutical industry)
Expresses concerns with the growing illegal trade in tobacco, “which could even be linked to the funding of terrorist groups”. Suggests to also involve tobacco in the dialogue, and refers to the agreement against tobacco smuggling signed with Phillip Morris International..
54. Drogenreferat Stadt Leipzig, Germany (no contact info included)
Local drug service of the municipal authority of the city of Leipzig.
Is concerned with the transparency of the process, not sure about the term ‘civil society’
55. STANDING COMMITTEE OF EUROPEAN DOCTORS, European Coalition based in Belgium, www.cpme.eu
Coalition of doctors.
Welcome the dialogue, but insist on being careful when establishing a structure.
56. Carnegie Institut, Sweden, Box 16302, 103 Stockholm, Sweden
For a drug free world.
Says no to a dialogue between civil society and authorities on drug policy.
57. SNPF, Swedish Narcotic Officers Association, Sweden, www.snpf.org
The narcotics police officers. Is this a (non-)governmental organisation?
Wishes to be involved in the dialogue, but at the same time believe that drug policy is a matter of governments, and is concerned with the increase of “well funded liberal NGO’s”
58. Swiss Institute for Prevention of Alcohol and Drug Problems, Switzerland, no contact details added
They just inform the Commission that a similar dialogue process has taken place in Switzerland during the past years, with positive results.
59. Finnish Centre for Health Promotion, Finland www.tekry.fi
Same organisation as IUHPE, see there
60. European Network of People Who Use Drugs, section of International Coalition based in Belgium, www.inpud.org
Network of drug users and their organisations
Wish to be involved in every step of the process.
61. Verbond der Verzorgingsinstellingen, Belgium, www.vvi.be
Network of treatment centres
Expresses concerns with lobby groups, insists on need to invest in networks in addiction care.
62. Vlaams Platform Tegen Drugs, Belgium, contact Pierre.belpaire@pandora.be
Group of parents for a drug free world
Support the idea of a dialogue, but warn against the influence of lobby groups.
63. Shane Ward, individual citizen, United Kingdom
Complaints about lack of transparency in EU Communication, promotes the banning of tobacco.
Next steps
The organisations who sent these comments will probably apply also to be included to the first round of dialogue that the Commission has announced it will organise in the end of 2007.
For this event, the Commission will invite 30 representatives, who will be selected from all those who will apply before 17 August to the call for applications.
ENCOD as a platform will apply, although we may have many reservations about the entire dialogue process as it has been carried out so far.
The European Commission has announced it will apply the following criteria for applicants:
1. The organisation has to correspond to the concept of civil society as set out in the Green Paper:
“The associational life operating in the space between the state and the market, including individual participation, and the activities of non-governmental, voluntary and community organisations”
2. The organisation has to have its main base inside the EU, or in candidate countries
3. Priority will be given to organisations established in the form of transnational networks covering a number of Member States or candidate countries.
4. The organisation has to have drug-related activities as the core focus of its activities
5. The organisation should have a clear track record of its activity.
6. The organisation should be recognised as being able to speak on behalf of those it claims to represent
The organisation must be legally registered in a Member State or candidate country, membership of the organisation must be open to those that fulfil transparent criteria and the organisation must be financially accountable.
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