Contacts between DG SANTE and alcohol industry representatives on labelling and health warnings (2019–2025)
Dear Health and Food Safety,
Pursuant to Regulation (EC) No 1049/2001, I hereby request access to documents held by DG SANTE 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 2025/2936.
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 Health and Food Safety - 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 Health and Food Safety,
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 03/06/2025 under the case number
2025/2936.
We will handle your request within 15 working days as of the date of
registration. The time-limit expires on 25/06/2025. 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 Health and Food Safety - Access to Documents
European Commission
References
Visible links
1. https://ec.europa.eu/info/principles-and...
Subject: Amendment to Access to Documents Request – 2025/2936
Dear Health and Food Safety,
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,
Please find attached a message concerning your request for access to
Commission documents registered under the above case number 2025/2936.
Kind regards,
SANTE ACCESS TO DOCUMENTS
Dear Ms Van Den Berg,
We are writing concerning your request for access to Commission documents
registered on 3 June 2025 under case number EASE 2025/2936.
We are currently working on your request. However, we have not yet been
able to gather all the elements necessary to carry out a full analysis of
your request. We will not be able to send you the reply within the
prescribed time limit expiring today 25 June 2025.
As mentioned in our earlier letter of today (fair solution proposal), the
application concerns a large number of documents, held from different
units and originating from third parties, which must be consulted.
Therefore, in line with Article 7(3) of [1]Regulation (EC) No 1049/2001,
we need to extend this time limit by 15 additional working days. The new
time limit expires on 16 July 2025.
We apologise for any inconvenience this may cause.
Kind regards,
SANTE ACCESS TO DOCUMENTS
References
Visible links
1. https://eur-lex.europa.eu/legal-content/...
Dear Ms Van Den Berg,
We are writing to you concerning your Access to Documents request EASE
2025/2936 and our email of 25 June 2025, with copy attached.
May we kindly ask you to follow up to our fair solution proposal as soon
as possible, so that we can further process your request? Please let us
know before Friday 4^th June 2025 or we will need to restrict the scope of
your application to those parts that can be dealt with within the extended
deadline of 30 working days.
Thank you very much in advance and we look forward to hearing from you.
With kind regards,
SANTE ACCESS TO DOCUMENTS
Dear Mr Pradalié,
Thank you for your message and for proposing a fair solution.
I agree to limit the scope of my request to documents covering the period 1 January 2023 to 31 December 2024.
As outlined in my original request, I am seeking documents held by DG SANTE relating to contacts with representatives of the alcohol industry concerning product labelling and health warnings on alcoholic beverages. My specific interest lies in the policy development and discussions on alcohol labelling, including ingredients and nutritional information, health warnings, and the debate on voluntary versus mandatory labelling.
This request concerns, in particular, communications involving or referring to Heineken, Brewers of Europe, Beer and Health, SpiritsEUROPE, Cerveceros de España, and other alcohol industry stakeholders registered in the EU Transparency Register.
Please do not hesitate to contact me if any further clarification is needed.
Kind regards,
Irene van den Berg
The Investigative Desk
Dear Mr Pradalié,
Thank you for your message and for proposing a fair solution.
I agree to limit the scope of my request to documents covering the period 1 January 2023 to 31 December 2024.
As outlined in my original request, I am seeking documents held by DG SANTE relating to contacts with representatives of the alcohol industry concerning product labelling and health warnings on alcoholic beverages. My specific interest lies in the policy development and discussions on alcohol labelling, including ingredients and nutritional information, health warnings, and the debate on voluntary versus mandatory labelling.
This request concerns, in particular, communications involving or referring to Heineken, ABInBev Brewers of Europe, Beer and Health, SpiritsEUROPE, Cerveceros de España, and other alcohol industry stakeholders registered in the EU Transparency Register.
Please do not hesitate to contact me if any further clarification is needed.
Kind regards,
Irene van den Berg
The Investigative Desk