As Competere, we submitted a contribution in response to Belgium’s draft Royal Decree on alcohol advertising, notified to the European Commission under the TRIS procedure (2026/0161/BE). 

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Our Contribution draws attention to TRIS Notification 2026/0161/BE and calls on the European Commission to issue a detailed opinion on the Belgian Draft Royal Decree and to request Belgium to reconsider the measure. 

Our Key Concerns

• The mandatory health warning “Alcohol is harmful to health” does not distinguish between harmful use, abuse, moderate consumption and responsible consumption.
• The measure risks replacing contextual, evidence-based consumer information with a uniform and decontextualised message.
• The technical, linguistic and format requirements may create unnecessary barriers to trade and increase compliance costs for companies operating across borders.
• These costs are not neutral from a competition perspective: they are more easily absorbed by large incumbents than by SMEs, new entrants and cross-border producers seeking to build brand recognition in the Belgian market.
• The proposal may restrict freedom of commercial communication and limit the ability of companies to compete through quality, identity, reputation and responsible consumption messages.
• The extension of the measure to digital communication raises concerns regarding legal certainty, cross-border services and the country-of-origin principle.
• If replicated by other Member States, the Belgian approach could contribute to regulatory fragmentation within the internal market, creating a patchwork of national warning, language, format and placement requirements.

In conclusion, public health objectives should be pursued through proportionate, targeted and evidence-based instruments that protect health without creating unnecessary barriers to trade, restricting cross-border services, or undermining consumer choice and fair competition. 

A more targeted and coordinated EU approach would better protect public health while preserving the proper functioning of the internal market.