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Lausunto EU:lle Cancer Plan -tiekartasta


response of the Cancer Society of Finland

BCP should aim to eliminate preventable cancers, as well as to ensuring equitable early access to diagnosis and proper treatment and care, including affordable cost-effective medicines.  Mindful of the competencies of the various bodies, Cancer Society of Finland wishes to emphasize structural means of cancer prevention and EU-level means to ensure equity and cost-effectiveness of cancer treatment, including through reviewing EMA procedures and investigating means of decreasing prices.


The EU should ensure proper health protection against major risk-factors of cancer, as identified in the European Cancer Code. Key is the creation of cancer preventing environments.  Including:

  • Health based-taxes should be facilitated and encouraged, in particular for tobacco, alcohol and foods, including sufficiently high excise duties on tobacco, nicotine and alcohol products (Directive 2011/64/EU), and an exemption to free trade within the EU (Directive 2008/118/EC) for import restrictions on tobacco and nicotine and alcohol products based on public health need and market failure reasons.
  • The TPD should include plain packaging and ban on flavours, and regulation on and approval of novel nicotine tobacco products replacing national notifications schemes.
  • Alcohol labelling should include explicit carcinogenic warnings, as well as energy contents and other nutritional info. Work towards a new alcohol programme
  • Appropriate information on to enable Healthy nutrition: ensure health and nutritional claims (with nutrient profiles), nutritional and energy contents, including fast food outlets and restaurants. Performance of the EU platform for action on diet, physical activity and health should be reviewed. Opportunities for healthy nutrition within the CAP should be seeked.
  • Clarify and streamline chemical legislation as regards work safety, according to the lines of the Council Conclusions on work safety.
  • Quality national vaccination programmes & organized screening for cervix ca



Early detection of cancer and timely diagnosis and treatment should be enabled, including through exchange of good practices and possible financial instruments. Monitoring and exchanging good practices at EU level should be supported.  EU should encourage the MSs ensure

  • Good quality national universal screening programmes & their monitoring. According to scientific evidence, these should include screening programmes for breast, cervical and bowel cancers.
  • Timely and equitable access to good quality primary health care
  • Ensure appropriate protection for individuals against health care costs



For enabling cost-effective and affordable modern cancer treatment at national levels, EU should

  • ensure robust regulatory environment for medicines’ approval, including a review critical review of accelerated review programmes.
  • investigate options for increasing transparency in medicines’ pricing policies, including  R&D costs and actual prices, means of crediting public sector investments in the R&D, and other means for decreasing prices, including through price negotiations.
  • ensure good quality HTA at EU-level, while respecting national level decision-making on introduction of medicines
  • ensure EU-level funding for health services research and clinical trials, especially for clinic- initiated research questions, including comparisons of treatments



Mindful of the increasing number of cancer patients, including with chronic cancers in the aging populations, enable exchange of best practices on

  • care and rehabilitation, psycosocial support for patients & families, particularly children
  • resourcing, incl. forecasting & building capacities
  • palliative care


Cancer Society of Finland contributed to ECL’s position paper.