European Commission - Mental Health Initiative


On 18 January 2023, the European Commission published a Call for Evidence in relation to a proposed initiative on a comprehensive approach to mental health. The initiative had been announced by European Commission President Ursula von der Leyen during her State of the EU speech in November 2022. The initiative will set out:

·         How action at EU level can help promote good mental health and prevent, mitigate and respond to mental health challenges

·         How mental health considerations should be factored into a wide variety of resilient EU and national policies for the benefit of people across the EU.


Alzheimer Europe welcomes the Commission’s decision to take action in this area and acknowledges the context approach of the initiative within the scope of the EU’s existing programmes and those of the World Health Organization (WHO) and the Sustainable Development Goals (SDGs).

However, we believe there are some crucial points which the Commission has not addressed within the call for evidence, which must be included in the development of a dedicated initiative on mental health.

Dementia as a part of mental health

Dementia as a policy issue sits across many areas, including those related to health, research, disability rights and older persons. Within healthcare systems specifically, the condition is often dealt with by different medical specialties, including mental health and psychiatry, neurology and gerontology.

Under the WHO and WHO Europe administrative structures, dementia falls under mental health and specifically, by the latter, dementia is addressed in the European Framework for Action on Mental Health (EFAMH) and the accompanying Mental Health Coalition, in which Alzheimer Europe participates. Within EFAMH, there is a dedicated workstream focused on the mental health of older people, which focuses on dementia, as well as other causes of poor mental health in older people (e.g. social isolation, stigma etc.)

We strongly encourage the Commission to ensure that the initiative more closely reflects the work of the WHO in these areas, identifying the aims and objectives of these workstreams, and how EU programmes such as EU4Health (including the Healthier Together initiative) can support Member States to achieve the goals of these existing policy drivers.

Omission of carers

Alzheimer Europe is surprised that the Commission’s call for evidence does not reference informal carers, a group which generally experiences poorer physical and mental health outcomes, as well as greater socio-economic pressures than the general population. As identified in the call for evidence, mental health outcomes for the population as a whole were worsened by the pandemic. For carers of persons with dementia, this experience was particularly difficult, with stress, isolation and burnout especially prevalent due to the interruption of care and support service, disruption to daily routines, disruptions to daily routines and the worsening of symptoms of the care for person.

We therefore strongly encourage the Commission to specifically consider the mental health of informal caregivers, to identify the key causes of poorer mental health and to support Member States to address these in the policies and services within their countries.

Monitoring and targets

Alzheimer Europe believes the Commission must consider broader monitoring and targets revise its targets and intended measurement for an initiative. Whilst measurement against SDG 3.4, as well as European Core Health Indicators (ECHI) on depression and suicide, are suitable indicators, others such as the ECHI number of available psychiatric beds provide little insight, other than a slight indication of whether countries are moving towards deinstitutionalisation.

In relation to dementia (and likely for other mental health conditions), diagnosis rates, timeliness of diagnosis (particularly important for progressive conditions), access to and quality of care (including post diagnostic support), use of psychotropic medications etc. are all key issues which should the Commission should consider how to address and monitor within their proposed initiative.