During the COVID-19 pandemic, the European Union (EU) observed a major centralisation of competence in public health policy – the EU Vaccines Strategy. Yet increased centralisation or integration is not always desirable because the EU lacks a layer of democratic control to ensure transparency and accountability. This feature highlights the need to better understand and assess the EU’s actions during the pandemic. This paper aims to assess the effectiveness of the EU Vaccines Strategy and contributes to the wider debate on the centralisation of power at Union level. The joint procurement of COVID-19 vaccines is considered a success, as it avoided a “vaccine scramble” by the EU Member States. However, the fact that the Member States were obliged to purchase more than they needed and the lack of transparency in the negotiations with companies on the procurement of vaccines have raised questions about the integrity of the Commission’s exercise of executive power.

The response to the COVID-19 crisis implied an unprecedented involvement of the European Union (EU) executive in public health matters. In June 2020, the Member States agreed upon a joint EU Vaccines Strategy, whereby the European Commission was enabled to negotiate, support and allocate vaccine doses on their behalf. Entailing political and redistributive choices, the Commission’s centralised procurement presents some innovative patterns when compared to traditional EU executive action. This paper will focus on the institutionalisation of such patterns within the legal framework of the Health Emergency Preparedness and Response Authority (HERA). Did EU administrative law offer appropriate tools for this process? Or did the EU merely formalise the procedural and organisational schemes set up during the crisis? Answers to these questions will contribute to a fuller understanding of the administrative dimension of the new European Health Union and shed light on some recent evolutions of the EU administrative system.