Putting behavioural health policy into context – the example of EU’s tobacco policy

Behavioural interventions, for quite some time now, have gained considerable scholarly attention. Due to increased application in public policy, research has started to take a more conceptual perspective in analysing these interventions. Thus, we have to ask when, where and under which circumstances policy-makers turn to Behavioural Public Policy (BPP). Likewise, it is worth to study whether behavioural and conventional policy tools become combined or blended by policy-makers. Especially, in health policy behavioural insights are deemed crucial for advancing health – on an individual as well as on a societal level. Based on recent advances in the debate on Behavioural Public Policy (BPP) (e.g. Ewert et al. 2021, Moseley and Thomann 2020), we take a closer look at EU’s tobacco policy. This area of EU’s health policy is characterised by an incremental development and a turn to behavioural instruments, i.e. using shocking pictures for front-of-package labelling. At first sight, this seems like a text-book example of policy-makers opting for behavioural policy design and acting as deliberate “choice architects”. However, closer inspection of the policy process reveals the crucial relevance of policy-makers general preferences regarding market intervention, target-group characterisations and, overall, the societal and political context in which policy-makers develop and revise EU’s tobacco policy. Hence, the choice of applied policy tools has been complex rather than straight-forward. The contribution is based on intensive case research, revealing the policy-making process with regard to EU’s tobacco policy in detail. By applying a behavioural model of policy processes (Ewert et al. 2021) that allows a nuanced understanding of the interrelations between social structures and individual action, we identify crucial moments and factors throughout the policy-making process leading to a behaviourally-tested intervention. Thus, this paper seeks to advance our understanding of how and under which circumstances behavioural interventions are put in place.