1. How relevant is the mental health of the population for the EU’s strategic policy objectives, as detailed in section 1?

Mental health is clearly relevant to a number of EU strategic policy objectives, but the Green paper fails to outline how these objectives differ from those of the individual nations that comprise the EU. In short how EU-level policy objectives add in any way to those already in place at national level.

2. Would the development of a comprehensive EU-strategy on mental health add value to the existing and envisaged actions and does section 5 propose adequate priorities?

Section 4 acknowledges widespread mental health inequalities within and between member states, illustrating this point with regard to national suicide rates. The Green paper states that there are no uniform solutions and restricts its aim to ‘exchange and cooperation between Member States and the opportunity to learn from each other’. Section 5 lays out the reasons for an EU-wide strategy:

• Creating a framework for exchange and cooperation between Member States;
• Helping to increase the coherence of actions in different policy sectors;
• To open up a platform for involving stakeholders including patient and civil society organisations into building solutions.

Aim a. appears sensible since the EU possesses appropriate resources and experience in setting up frameworks to enhance exchange and cooperation between member states.

Aim b. is appropriate insofar as it relates to EU institutions, in particular ensuring coherence of policies proposed by the EU Commission in different spheres (e.g. trade, environment, education etc).

Aim c. is less clearly defined. Many platforms already exist within individual nations to take forward solutions locally. It is unclear how an EU-wide platform would add to this, especially since it is unclear how representation at such a platform could be equitably organised. Otherwise, those organisations with the greatest resources within the EU may end up over-represented compared with less well-resourced organisations, perhaps from newer EU members. The EU needs to address this issue before such a platform could be supported as adding value.

3. Are the initiatives proposed in sections 6 and 7 appropriate to support the coordination between Member States, to promote the integration of mental health into the health and non-health policies and stakeholder action, and to better liaise research and policy on mental health aspects?

Numerous initiatives are proposed in Sections 6 and 7. Many overlap with current EU member state priorities. It is unclear how far practices in one state are relevant to very different cultural traditions and economic circumstances in other states. A guide here would be to use available resources to focus on those initiatives where the EU can clearly add value rather than merely replicate nationally established programmes. There is a role for the EU to provide guidance based on the EC Treaty and European Human Rights legislation as interpreted by the European Court of Human Rights. There are initiatives, such as those relating to the mental health of migrant workers, which may be addressed better at an EU than at a national level. Similarly the EU has a clear role in promoting collaborative research between member states into mental health.