European Alcohol Policy Alliance

…17 Rue Archimede I 1000 Brussels I Belgium I Tel +32 (0)2 732 67 82 [email protected] I www.eurocare.org Comments on the Inception Impact Assessment for Directive 2008/118/EC April 2017 Ref. Ares(2017)1932603 - 11/04/2017 1 | P a g e The European Alcohol Policy Alliance (EUROCARE) The European Alcohol Policy Alliance (EUROCARE) is an alliance of non-governmental and public health organisations with around 60 member organisations across 25 European countries advocating the prevention and reduction of alcohol related harm in Europe. Member organisations are involved in advocacy and research, as well as in the provision of information and training on alcohol issues and the service for people whose lives are affected by alcohol problems. The mission of Eurocare is to promote policies to prevent and reduce alcohol related harm.

…by alcohol problems. The mission of Eurocare is to promote policies to prevent and reduce alcohol related harm. The message, in regard to alcohol consumption is “less is better”. Eurocare input to the Inception Impact Assessment for Directive 2008/118/EC European Alcohol Policy Alliance (Eurocare) welcomes the revision of the Directive 2008/118/EC and would like to draw the European Commission’s attention to some elements in its Inception Impact Assessment. Apart from the issues identified in the Evaluation report (Evaluation of current arrangements of the holding and moving of excise good under excise suspension) we would like to urge European Commission in the REFIT to address the issue of private acquisition of alcoholic beverages (Art 32). The general objectives list safeguarding revenue of Member States. Collection of excise duties is a major source of revenue for the Member States.

…safeguarding revenue of Member States. Collection of excise duties is a major source of revenue for the Member States. Nevertheless almost 99% of all intra-EU movements of excise duties goods take place under suspension of excise duty, amounting to associated excise duty of EUR 90 billion. If some of that suspension was lifted it can be argued that this would allow Member States to collect higher excise duties. From the public health perspective price and availability of alcohol are key policy areas recommended by World Health Organisation to reduce alcohol related harm. Currently, European region is the heaviest drinking region in the world. Hence, we would like to encourage the European Commission to revise the quotas, also to ensure policy coherence of the European Institutions.

…the European Commission to revise the quotas, also to ensure policy coherence of the European Institutions. Taking public health perspective into account could allow for the revised Directive to even better met the general objective of safeguarding the budgetary interests of the Member States by increasing income from excise duties on alcoholic beverages. Furthermore, we find it surprising that the European Commission did not identify any likely social impacts in the Inception Impact Assessment (point C, page 3). The World Health Organization points to affordability and availability of alcohol as one of the main factors influencing alcohol consumption. The REFIT aims to harmonise and simply provisions for the export, import and transit of excise duties. It can be assumed that these changes will consequently have an impact on the availability and price of alcohol.

…duties. It can be assumed that these changes will consequently have an impact on the availability and price of alcohol. This in return is highly likely to have an impact on health and other social aspects. As a case in point, 2 | P a g e in 2004 Finland reduced its excise duties by a third on average, in an effort to prevent people travelling to Estonia to purchase alcohol. This led to an increase in alcohol consumption and a substantial increase in deaths from alcohol attributable diseases. Deaths from liver disease rose by 46%, rates of hospitalization, alcohol poisoning and alcohol dependence were also higher as a result of the change. To ensure the proper functioning of the internal market and also to allow Members States to use fiscal policy tools for public health outcomes, the personal quotas should be addressed in the REFIT.

States to use fiscal policy tools for public health outcomes, the personal quotas should be addressed in the REFIT. Furthermore, there is a strong potential for cross-border movement through private acquisitions to contribute to tax evasion and this point should be consulted upon. Finally, we strongly agree with the objective to strengthen the fight against fraud and tax evasion, and would suggest that REFIT places more emphasis on the issue of denatured alcohol and coherence with Directive 92/83/ECC, Art 27 (1)(a). The REFIT should result in clarification of terms and harmonisation of the categorisation of the denatured alcohol, in alliance with 92/83/ECC. Contact details For more information please contact: Mariann Skar Secretary General Eurocare Rue Archimede 17 1000 Brussels, Belgium Tel +32 (0)2 732 67 82 GSM +32 (0)47 4830041 E-mail: [email protected]

originalus šaltinis (PDF) ↗