Background
On 1 December 2022, the European Commission opened a call for evidence on the proposed EU Disability Card. The card aims facilitate free movement for people with disabilities in the EU. With the card, disability status recognised in one EU country should be recognised in others too, giving the holder access to preferential conditions for some services across the EU. It aims to build on the 2019 pilot project on the EU Disability Card (covering culture, leisure, sport and transport) and apply to a wider range of services. .
This call for evidence aimed to inform further development and fine-tuning of the initiative.
On 10 February 2023, the European Commission launched a consultation inviting contributions as they began to fine tune the initiative. These included more specific questions about the operation of the card and differences between EU Member States.
Both of Alzheimer Europe's responses can be downloaded below.
Overview
Alzheimer Europe supports the introduction of a European Disability Card. We believe that such a measure has the potential to address some of the barriers faced by persons with disabilities across Europe, including persons living with an “invisible” disability, such as dementia.
We recognise that there is currently no mutual recognition of disability status between EU Member States and no guarantee of national disability cards between Member States. As such, the introduction of an EU Disability Card has the potential to address issues which disadvantage people with disabilities when exercising their right to freedom of movement.
However, the proposed limited application of the Disability Card, coupled with outstanding issues related to disability recognition by Member States and longstanding issues with the EU parking card for people with disabilities (i.e. the Blue Badge Scheme), mean we have concerns about how the scheme will operate in practice.
Alzheimer Europe has outlined our concerns below. In addition, we would like to express our support for the points raised by the European Disability Forum in their response.
Dementia as an overview
Conditions such as dementia, which cause cognitive impairment, are considered as disabilities under the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD). Dementia is sometimes referred to as an “invisible” disability, as symptoms are not always outwardly visible and generally not physical until the late stages of the disease. Despite all Member States being signatories of the UNCRPD, the recognition of dementia as a disability varies across member states. This has a significant impact on the types of social protection to which a person with dementia is entitled, including the Blue Badge Scheme..
As the proposal stands, the Disability Card will not address issues of national eligibility criteria, national definitions of disability or issuing procedures. These longstanding issues duplicate some of the most serious shortcomings of the Blue Badge Scheme. Whilst understanding the shared competence in this area and the Commission’s wish to respect the principle of subsidiarity, the approach proposed will not achieve the goals outlined in the call for evidence (especially those related to the UNCRPD and the Sustainable Development Goals). We believe that the Commission must address these shortcomings in the existing Blue Badge scheme, to remove disparity between Member States.
Additionally, whilst the origins of this initiative relate to freedom of movement, the broader applicability of the card during the pilot (in the areas of culture, leisure and sport) has demonstrated that the card can be used in other service areas. As such, we would wish to see the scope of the card broadened.
EU Disability Card - Petri Lampinen
In support of the objectives of the Disability Card, Alzheimer Europe would highlight the case of Petri Lampinen, from Finland, who is a member of the European Working Group of People with Dementia (EWGPWD). He took part in the pilot project for the European Disability Card and wrote an article in our Dementia in Europe magazine in June 2019, to share his experience:
“I have been using an EU Disability Card for about a year now and have been very happy with it. I have used it at airports. Thanks to the card, I have had access to priority boarding, which helps because hustle and bustle and being rushed causes me problems when travelling. I keep my disability card ready to show at security too, to avoid difficulties.
Another good point has been that the card includes a symbol showing the need for assistance. If I need help, it is always close at hand.”