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Peep Peterson, Minister of Health, Estonia Sent via email to: [email protected]; Brussels, 3 November 2022 Urgent request for support for Europe’s leadership moment in early detection of cancer Dear Minister Peterson, Since the last meeting of the Health Working Party of the Council of Ministers on Friday 28 October, the European Cancer Organisation has been consulting widely on the proposed changes to the text of new EU Council Recommendations on Cancer Screening, including with our 41 European oncology medical societies and 22 European cancer patient associations. We are writing to provide constructive feedback and suggestions for your consideration, ahead of the upcoming meeting of EU government representatives taking place this coming Wednesday 9 November 1. This meeting of officials from 27 EU Member States - the Health Working Party of the Council of Ministers – is expected to conclude, for your personal approval at the December EPSCO Council Meeting 2, final text of new EU Council Recommendations on Cancer Screening. The European Cancer community has placed on record its strong reservations about significant weakening of the text that we have become aware of 3. We write to you today seeking your urgent support in respect to four important requests for the final text of the Recommendations to ensure the broadest possible support of oncology professionals, patients and citizens across Europe. The updated EU Recommendations on Cancer Screening will be foundational in terms of pan-European cooperation on early detection of cancer. It is therefore right and proper that all efforts are made to come to conclusions which balance both broad support with suitable ambition. 1. The repeated and heavy caveats placed upon lung, prostate and gastric cancer screening in the text deflate the Recommendations and go beyond what is required. As the title ‘Recommendations’ suggests, this text represents a statement of shared aspiration by countries, of a non-legally binding nature. We consider inserting subjective terms such as “to a lesser extent” and “preliminary evidence”, alongside several cautionary insertions on balancing the recommendations with national contexts and priorities undermining of that intended expression of ambition. We believe the proposed changes to the tone of these sections of the text risk a strong reaction from citizens, cancer patients and oncology professionals who will feel let down by this process, after engaging in a transparent way with the Commission’s consultative scientific advice mechanisms. Therefore, we request a re-balancing of this text to maintain the original while 1 https://www.consilium.europa.eu/en/meetings/mpo/2022/11/public-health-(324695)/ 2 https://www.consilium.europa.eu/en/meetings/epsco/2022/12/08/ 3 https://www.europeancancer.org/screening Rue de la Science 41 +32 2 775 02 00 1040 Brussels, Belgium [email protected] europeancancer.org emphasising that these represent recommendations rather than legal requirements. ECO is available to advise on re-wording that would achieve maximum European cancer community support. 2. The basis behind the EU Chief Scientific Advisors Recommendations to update the age ranges for breast cancer screening is strong and should be retained in the final text. The advice to amend the recommended age range for breast cancer screening, is drawn from a wide range of scientific evidence, which the Chief Scientific Advisors described as ‘compelling’. The recommendation for amendment to the age range also reflects the highly deliberated advice conveyed by the European Commission Initiative on Breast Cancer 4. We believe the recommended age range for breast cancer screening should be as originally proposed in September 2022 and as based on these expert sources. Higher age ranges (as were previously included in the 20-year-old current recommendations) should, we believe, be the exception rather than the rule. 3. Let’s commit to a full stakeholder approach on implementing the new Recommendations Recent events in respect to the text of the Council Recommendations on cancer screening have served to highlight the importance of all stakeholders working in alignment to implement high performance cancer screening and early detection strategies, underpinned by a shared understanding of science and evidence. We would welcome some recognition and commitment to this form of implementation approach within the final text. 4. Regularity of review is essential As the current Recommendation text rightly acknowledges, the present policy environment in respect to cancer screening and early detection is subject to “rapidly developing technological possibilities and scientific knowledge”. Gaps in our knowledge are being continually filled and fresh policy evidence created. Given the long passage of time since these recommendations were last updated, we believe there is a real risk of scepticism on the timing of the next review and therefore consider the commitment to regular review of the Recommendations of utmost importance. Further commitment to this within the final text would be most welcome. We hope that Europe’s oncology professionals and cancer patient community may trust upon your support for these suggestions. We are available to support and advise you as needed and you can contact Mike Morrissey by mobile on +33 6 61 96 29 90 or email: [email protected] Yours sincerely, Professor Andreas Charalambous Mike Morrissey President Chief Executive 4 https://healthcare-quality.jrc.ec.europa.eu/ecibc/european-breast-cancer-guidelines/screening-ages-and- frequencies Rue de la Science 41 +32 2 775 02 00 1040 Brussels, Belgium [email protected] europeancancer.org ANNEX: NOTES ON AMENDMENT 1. TEXTUAL CAVEATS Revisions to Commission’s September 2022 proposals Commentary: These amendments serve to deflate the tone and expression of ambition from the Recommendation text, whilst simply stating what is already implicit and well understood by the status of a Council Recommendation text: that the Recommendations are of an aspirational nature and not legally binding on Member States. Repeated restating of this does not strengthen what should be a statement of shared vision. Rue de la Science 41 +32 2 775 02 00 1040 Brussels, Belgium [email protected] europeancancer.org  2. BREAST CANCER SCREENING AGE RANGES Revisions to Commission’s September 2022 proposals Commentary: The recommended age range as the default position of the recommendations should be kept in line with those provided by the EU’s Chief Scientific Advisors and the European Commission Initiative on Breast Cancer. 3. COMMITMENT TO STAKEHOLDER LED IMPLEMENTATION APPROACHES Commentary: In this paragraph on implementation considerations, we would recommend an additional sentence be added. “In implementing cancer screening programmes, close working with key stakeholders, such as relevant scientific societies, healthcare professional organisations, and patient representatives, is recommended to achieve well-aligned and fully-supported implementation strategies.” Rue de la Science 41 +32 2 775 02 00 1040 Brussels, Belgium [email protected] europeancancer.org  4. REGULARITY OF REVIEW Commentary: Given the almost twenty years that elapsed since update of the 2003 Council Recommendations on Cancer Screening, and the rapidly developing scientific field, we recommend explicit commitment to formal review of the Recommendations no less than every five years. Rue de la Science 41 +32 2 775 02 00 1040 Brussels, Belgium [email protected] europeancancer.org Saatja: Mike Morrissey <[email protected]> Saadetud: 03.11.2022 17:41 Adressaat: SM Info <[email protected]> Koopia: Richard Price <[email protected]> Teema: Urgent request for support for Europe’s leadership moment in early detection of cancer Please find attached an important communication from the President of the European Cancer Organisation and me. Do not hesitate to contact me on my mobile number (&#43;33 6 61 96 29 90) if you would like to discuss any aspect of this letter. Mike Morrissey (he/his) * Chief Executive Join us for the on 16 &amp; 17 NovemberFind out more about our work for Ukrainian cancer patients: European Cancer Organisation Please note our new address: Rue de la Science 41, 1040 Brussels, Belgium Office telephone: &#43;32 2 775 02 00 Mobile: &#43;33 6 61 96 29 90 Twitter: @MorrisseyMike Follow us: @EuropeanCancer | | | | *Legal representative of Morrissey Global Management