Contacts between DG GROW and alcohol industry representatives on labelling and health warnings (2019–2025)
Dear Internal Market, Industry, Entrepreneurship and SMEs,
Pursuant to Regulation (EC) No 1049/2001, I hereby request access to documents held by DG GROW relating to contacts with representatives of the alcohol industry concerning product labelling and health warnings on alcoholic beverages.
This request covers the period from 1 January 2019 to 30 May 2025.
I am seeking all relevant documents concerning policy development or discussions about alcohol labelling, including the inclusion of ingredients and nutritional information, health warnings on packaging, and the debate on voluntary versus mandatory labelling. Requested documents include, but are not limited to: emails, meeting agendas and minutes, briefing notes, internal memos, talking points, and stakeholder submissions.
The request specifically concerns communications involving or referring to the following organisations: Heineken, Brewers of Europe, Beer and Health, SpiritsEUROPE, Cerveceros de España, and other alcohol industry stakeholders registered in the EU Transparency Register.
If any part of the requested documents is exempt under Article 4 of Regulation 1049/2001, I kindly ask that partial access be granted, for example by redacting sensitive information.
I prefer to receive the documents in electronic format.
Thank you for your consideration.
Yours sincerely,
Irene van den Berg
The Investigative Desk
Dear Sir or Madam,
We are writing to you concerning your request for access to documents sent
on 30/05/2025 and registered on 02/06/2025 under case number 2025/2923.
Since you have not indicated your postal address, we are not able to start
handling your request. The 15 working days to reply to your request will
start running only when you send us your postal address.
You can send your postal address by replying to this e-mail. If we do not
receive your reply we may close this case.
Please note that you can submit a request for access to Commission
documents via the portal [1]'Request a Commission document', which does
not require you to indicate your postal address.
Why do we need your personal postal address?
Since 1 April 2014, the submission of a postal address became a mandatory
feature when submitting an application for access to Commission documents
via an e-mail. We would like to explain why we need your postal address in
order to register and handle your application for access to documents when
submitted via e-mail:
• Firstly, to obtain legal certainty as regards the date you received
the European Commission reply to your application for public access to
documents. Article 297 of the Treaty on the Functioning of the
European Union (TFEU) states that 'decisions which specify to whom
they are addressed, shall be notified to those to whom they are
addressed and shall take effect upon such notification.' In line with
this provision, if the Commission does not grant full access to the
requested documents, it notifies the reply to the applicant via
registered mail with acknowledgement of receipt or via delivery
service. This requires an indication of a valid postal address by the
applicant;
• Secondly, to apply correctly the [2]Data Protection Regulation (EU)
2018/1725. Knowing whether the applicant is an EU resident (or not) is
necessary for deciding which conditions shall apply for the
transmissions of personal data to applicants for access to documents.
These conditions are not the same for recipients established in the
Union and for recipients in third countries. As the vast majority of
the documents requested contain personal data, the Commission cannot
ensure the correct application of the data protection rules in the
absence of a postal address;
• Thirdly, to apply correctly [3]Regulation (EC) No 1049/2001. Article
4(1)(b) of that Regulation refers to the protection of the privacy and
integrity of the individual and has to be applied in line with the
Data Protection Regulation;
• Fourthly, to protect the interest of other citizens and safeguard the
principle of good administration. The Commission has to treat all
citizens equally by ensuring that the legal framework for public
access to documents is respected. For example, it has to verify
whether Article 6(3) of Regulation (EC) No 1049/2001 is being evaded
by introducing several requests under different identities. Indeed, in
its Ryanair judgment ([4]EU:T:2010:511), the General Court confirmed
that Article 6(3) of Regulation (EC) No 1049/2001 cannot be evaded by
splitting an application into several, seemingly separate, parts. In
addition, the Commission has to make sure that the legal framework is
respected and the right of access to documents is not abused by making
requests under an invented identity.
The considerations above show that the request for and the consequent
processing of the applicant's postal address is not only appropriate, but
also strictly necessary for the performance of a task carried out in the
public interest within the meaning of Article 5(1)(a) of Data Protection
Regulation, namely providing a smooth and effective access to documents.
Yours faithfully,
Directorate-General for Internal Market, Industry, Entrepreneurship and
SMEs - Access to Documents
European Commission
References
Visible links
1. https://www.ec.europa.eu/transparency/do...
2. https://eur-lex.europa.eu/legal-content/...
3. https://eur-lex.europa.eu/legal-content/...
4. https://eur-lex.europa.eu/legal-content/...
Dear Internal Market, Industry, Entrepreneurship and SMEs,
My postal address is:
The Investigative Desk
T.a.v. Irene van den Berg
Overhoeksplein 2
1031 KS Amsterdam
The Netherlands
Yours faithfully,
Irene van den Berg
Dear Sir or Madam,
We hereby acknowledge the receipt of your request for access to documents
sent on 30/05/2025 and registered on 02/06/2025 under the case number
2025/2923.
We will handle your request within 15 working days as of the date of
registration. The time-limit expires on 24/06/2025. We will let you know
if we need to extend this time limit for additional 15 working days.
To find more information on how we process your personal data, please see
[1]the privacy statement.
Yours faithfully,
Directorate-General for Internal Market, Industry, Entrepreneurship and
SMEs - Access to Documents
European Commission
References
Visible links
1. https://ec.europa.eu/info/principles-and...
Subject: Amendment to Access to Documents Request – 2025/2923
Dear Internal Market, Industry, Entrepreneurship and SMEs,
Further to my request for access to documents submitted on 30/05/2025, I would like to make a minor amendment to the list of stakeholders mentioned in the request.
Specifically, I kindly ask that AB InBev be added to the list of alcohol industry organisations covered by my request. The relevant paragraph would then read as follows:
"The request specifically concerns communications involving or referring to the following organisations: Heineken, AB InBev, Brewers of Europe, Beer and Health, SpiritsEUROPE, Cerveceros de España, and other alcohol industry stakeholders registered in the EU Transparency Register."
I would be grateful if this addition could be taken into account and included in the scope of the request.
Thank you for your assistance.
Kind regards,
Irene van den Berg
The Investigative Desk
Dear Ms Van Den Berg,
We refer to your request of access to documents registered on 30/05/2025
under the above mentioned reference number.
Your application is currently being handled. However, we were not in a
position to complete the handling of your application within the time
limit of 15 working days, which expired on 24 June 2025.
We had to extend the time limit with 15 working days in accordance with
Article 7(3) of Regulation (EC) No 1049/2001 regarding public access to
documents. The new time limit expires on 15/07/2025.
In addition to that, as your application concerns a large number of
documents stretching back to several years ago, we will not be in a
position to complete the handling of your application within the extended
time limit, which means you might receive the final reply few days later
than on 15/07.
Please be reassured that we are doing our best to be able to send you the
reply as soon as possible.
We apologise for this delay and for any inconvenience this may cause.
Kind regards,
Joanna Ligaszewska
Secretary to Unit GROW/F3 Textiles, Food and Retail
European Commission
DG for Internal Market, Industry, Entrepreneurship and SMEs
Unit F3
N105 09/023
B-1049 Brussels/Belgium
+32 2 299 53 46
[1][email address]
[2]recycle
Dear Ms Ligaszewska,
Thank you for your message.
Given that the extended deadline of 15 July 2025 has now passed without a final reply, I hereby submit a request for an internal review in accordance with Article 8(1) of Regulation (EC) No 1049/2001.
I look forward to your response.
Kind regards,
Irene van den Berg
Dear Internal Market, Industry, Entrepreneurship and SMEs,
Please pass this on to the person who reviews confirmatory applications.
I am filing the following confirmatory application with regards to my access to documents request 'Contacts between DG GROW and alcohol industry representatives on labelling and health warnings (2019–2025)'.
Although the deadline was first extended under Article 7(3) of Regulation 1049/2001, the final deadline of 15 July 2025 has passed without a reply. No justification was provided for this further delay, and no partial access or progress update was communicated.
This lack of response beyond the statutory time limits constitutes a failure to handle the request in accordance with Regulation 1049/2001. I therefore request an internal review under Article 8(1).
A full history of my request and all correspondence is available on the Internet at this address:
https://www.asktheeu.org/request/contact...
Yours faithfully,
Irene van den Berg
Good morning,
Please find attached a message concerning your request for access to
Commission documents registered under the above case number 2025/2923.
Please acknowledge the receipt of this message by return email.
Kind regards,
Secretariat of Unit GROW F3
Good morning,
Please find attached a message concerning your request for access to
Commission documents registered under the above case number 2025/2923.
Please acknowledge the receipt of this message by return email.
Kind regards,
Secretariat of Unit GROW F3
Dear Internal Market, Industry, Entrepreneurship and SMEs,
Thank you for providing the documents in response to my FOIA request. I have carefully reviewed the file titled “220926 TRIS email pdf Redacted.”
In this document, there is a reference to an attachment described as “endorsement related to the submissions made by Ibec in relation to Ireland's draft regulation.” However, this attachment was not included in the release.
I would therefore kindly request that the missing attachment be provided at your earliest convenience, or, if it has been withheld, that you indicate the applicable exemption under which it was withheld.
Thank you again for your assistance with my request. I look forward to your reply.
Yours faithfully,
Irene van den Berg
Dear Sir or Madam,
We hereby acknowledge the receipt of your request for access to documents
sent on 16/09/2025 and registered on 16/09/2025 under the case number
2025/4676.
We will handle your request within 15 working days as of the date of
registration. The time-limit expires on 07/10/2025. We will let you know
if we need to extend this time limit for additional 15 working days.
To find more information on how we process your personal data, please see
[1]the privacy statement.
Yours faithfully,
Directorate-General for Internal Market, Industry, Entrepreneurship and
SMEs - Access to Documents
European Commission
References
Visible links
1. https://ec.europa.eu/info/principles-and...
Dear Ms van den Berg,
We acknowledge receipt of your email.
We are dealing with your request.
Kind regards,
Secretariat of Unit GROW F3
Dear Ms. Van Den Berg,
We refer to your request for access to documents, registered on 16/09/2025
under the above mentioned reference number.
Your application is currently being handled. However, we were not be in a
position to complete the handling of your application within the time
limit of 15 working days, which expired on 07/10/2025.
An extended time limit is needed as in order to retrieve the documents
requested, large files have to be examined.
Therefore, we have to extend the time limit with 15 working days in
accordance with Article 7(3) of Regulation (EC) No 1049/2001 regarding
public access to documents. The new time limit expires on 28/10/2025.
We apologize for this delay and for any inconvenience this may cause.
Yours sincerely,
DG GROW – Access to documents team
European Commission
Directorate-General for Internal Market, Industry, Entrepreneurship and
SMEs
DG GROW/B1 – Planning and Simplification
Link: [1]File-List
Link: [2]themeData
Link: [3]colorSchemeMapping
[4]RE access to documents request - Contacts between DG GROW and alcohol
industry representatives on labelling and health warnings (2019–2025) -
Ares(2025)8756112 (Please use this link only if you are an Ares user –
Svp, utilisez ce lien exclusivement si vous êtes un(e) utilisateur d’Ares)
Dear Ms van den Berg,
Please find in attachment 3 documents you requested.
Kind regards,
Secretariat of Unit GROW F3
Dear Ms. Van Den Berg,
We refer to your request for access to documents, registered on 16/09/2025
under the above mentioned reference number.
Your application is currently being handled. However, we will not be in a
position to complete the handling of your application within the time
limit of 15 working days, which expires on 05/11/1025.
An extended time limit is needed as in order to retrieve the documents
requested, large files have to be examined.
Therefore, we have to extend the time limit with 15 working days in
accordance with Article 7(3) of Regulation (EC) No 1049/2001 regarding
public access to documents. The new time limit expires on 26/11/2025.
We apologize for this delay and for any inconvenience this may cause.
Yours sincerely,
DG GROW – Access to documents team
European Commission
Directorate-General for Internal Market, Industry, Entrepreneurship and
SMEs
DG GROW/B1 – Planning and Simplification