Tobacco Europe AISBL

Tobacco Europe AISBL Avenue de Cortenbergh, 120 - B- 1000 Brussels EU Transparency Register: 1496873833-97 To: Michele Perolat Head of Unit, Customs policy (TAXUD.A.1) Rue Joseph II 79 B- 1000 Brussels Lina Papamichalopoulou Head of Unit, Customs legislation (TAXUD.A.2) 16 September 2022 A Collaborative Approach to Targeting Illicit Trade in Cross-border e-Commerce CALL FOR EVIDENCE-REFORM OF THE UNION CUSTOMS LEGISLATION Dear Mrs Perolat, dear Mrs Papamichalopoulou, Tobacco Europe AISBL1 represents the common views of British American Tobacco (BAT), Imperial Brands (IMB), and Japan Tobacco International (JTI). We appreciate the initiative of the European Commission with respect to the reform of the union customs legislation. We would like to contribute to this initiative by proposing clarifications on certain issues which are of concern for our members if not addressed appropriately…

…between the private and public sector (EU customs and law enforcement authorities). Our recommendations are: 1. Decrease of the customs duty ‘de Minimis’ threshold: e-commerce has created new distribution channels for illicit and counterfeit traded goods. A decrease of the customs duty ‘de Minimis threshold’ can contribute to the reduction of the illicit trade supply chains. We therefore welcome the Wise Persons Group recommendation to remove the EU ‘de-minimis’ threshold and we call on the EU Commission to implement this recommendation as soon as possible. 2. The EU Commission in collaboration with the private sector should evaluate and determine whether new and emerging technologies can support the customs union in controlling the safety and security risks associated with e-commerce. These new and emerging technologies may include blockchain and artificial intelligence (AI) solutions.

…with e-commerce. These new and emerging technologies may include blockchain and artificial intelligence (AI) solutions. The following sections provide further details regarding the current challenges and proposed solutions. We would welcome the opportunity to meet at your convenience in order to outline in more detail our recommendations. Should you need any additional information or clarification in the meantime, please do not hesitate to contact us. We hope that the content provided in this submission contributes to the ongoing work of the EU Commission. Kind Regards, Nathalie Darge 1 https://www.tobacco-europe.eu/ Ref. Ares(2022)6409538 - 16/09/2022 Tobacco Europe AISBL Avenue de Cortenbergh, 120 - B- 1000 Brussels EU Transparency Register: 1496873833-97 Director Tobacco Europe The Challenges of Cross-Border E-Commerce 1.1.

Brussels EU Transparency Register: 1496873833-97 Director Tobacco Europe The Challenges of Cross-Border E-Commerce 1.1. The Growth of E-Commerce in Europe Global Retail e-commerce has grown significantly over the past years as consumers increasingly choose to shop online for the greater choice and value for money. E-commerce has created new opportunities for the global economy, creating new consumption behaviours, jobs, and methods of trade. In the wake of the COVID-19 pandemic, consumers’ reliance on e-commerce has surged following the global lockdown measures. Particularly in Europe, cross-border e-commerce has doubled in value between 2019 and 2021 from €108 billion to over €220 billion1. EU companies generate around 20% of their revenues from e- commerce and European cross-border transactions are predicted to grow at twice the rate of domestic e- commerce2.

…e- commerce and European cross-border transactions are predicted to grow at twice the rate of domestic e- commerce2. The Accenture Growth Analytics engine estimates a five-year growth rate of over 110% for all Consumer Packaged Goods (CPG) sold online in the EU from 2019 to 2024. The fastest growing CPG categories are packaged food, soft drinks, and excisable goods such as tobacco, with compound annual growth rates of 19.4%, 19.2% and 18.4%, respectively. The changing trade environment due to the rapid expansion of cross-border e-commerce is impacting all EU Member States and a more inclusive, proactive and innovative collaboration between the public and private sectors is required to overcome the various challenges that go along with it. 1.2.

…between the public and private sectors is required to overcome the various challenges that go along with it. 1.2. Supply Chain Challenges in The Cross-Border Trade of CPGs The proliferation of CPGs via e-commerce, coupled with the lockdown measures introduced by the EU Member States, have led to serious supply chain challenges. As EU customs authorities and national postal operators still rely on labour-intensive manual clearance of packages3, they have been struggling to cope with the increasing frequency of shipments and temporary unavailability of staff. The current, largely manual, real-time clearing process is both inefficient and prone to human error, which makes it impossible for customs authorities to check every single consignment.

…and prone to human error, which makes it impossible for customs authorities to check every single consignment. In addition, newly added complexities in regulations, such as the prioritisation of essential goods (i.e., COVID-19 vaccines and personal protective equipment (PPE)) over non-essential goods (such as CPGs), have put added pressure on EU customs authorities and postal operators. This is compounded by an inadequate integration between electronic customs declaration systems and postal services, which leads to significant delays and inefficiencies, effectively turning them into bottlenecks for cross-border trade. The small, low-value consignments delivered by post or express courier are the most difficult for customs to monitor as the declarations currently rely on the sender to fill in the correct information.

…difficult for customs to monitor as the declarations currently rely on the sender to fill in the correct information. Poor quality of information, inaccurate data (due to misdeclarations) and the lack of adequate monitoring technologies in place have made the CPG trade, and particularly the trade in excisable goods, a target for fraud, counterfeiting and illicit trade. Private entities, such as express couriers, have also been a target for fraud. According to the OECD, law enforcement agencies have indicated a significant growth in the use of both postal and courier streams by criminal networks as a delivery method for illicit trade4. A lack of information sharing with customs authorities leads criminal networks to exploit these weaknesses and use express couriers to move counterfeit goods. 1.3.

…criminal networks to exploit these weaknesses and use express couriers to move counterfeit goods. 1.3. Challenges for Excisable Goods Companies and Governments Companies trading in goods with high excise duties, such as tobacco, vapour products, nicotine pouches, alcohol, and energy, are a major target for illicit trade. Illicit trade can come from both the smuggling of products across borders without the payment of taxes (contraband) and the illegal manufacturing of such products, often with Tobacco Europe AISBL Avenue de Cortenbergh, 120 - B- 1000 Brussels EU Transparency Register: 1496873833-97 illegally produced trademarks (counterfeit). The anti-competitive practices posed by the influx of contrabands and counterfeits (whether produced domestically or smuggled) lead to losses of excise, VAT, and import tax revenues for EU Member States as well as losses in profits for businesses.

…to losses of excise, VAT, and import tax revenues for EU Member States as well as losses in profits for businesses. EU authorities and the industry have been taking steps to collaboratively address this challenge. In 2010 for instance, EU law enforcement agencies have coupled their efforts with policies and technologies provided by the tobacco industry to reduce the number of cigarettes illegally entering the EU 5. However, the reduction of smuggled cigarettes across EU borders was replaced by a growth in the illegal manufacturing of counterfeit cigarettes, possibly manufactured within the EU itself. In many cases consumers are tricked into buying identical looking but non-genuine products online.

…the EU itself. In many cases consumers are tricked into buying identical looking but non-genuine products online. The KPMG ‘Project Stella’ Report, 2021 results, June 2022, shows that the majority of illicit cigarettes consumed within the EU do not conform to EU regulations, either through the health warnings printed, legal format or regulations. 58% of cigarettes were either counterfeit, or illicit whites. Counterfeits, manufactured in clandestine factories conform to no regulatory standards, whilst illicit whites are mainly manufactured in countries with weaker regulations. This trend is thought to have been exacerbated by the COVID-19 pandemic, which reduced the opportunity for consumers to cross borders and buy cheaper products, therefore increasing demand for illegal locally manufactured cigarettes and those sent in smaller packages.

…products, therefore increasing demand for illegal locally manufactured cigarettes and those sent in smaller packages. The Royal United Services Institute (RUSI) has revealed that criminal networks are increasingly adopting a low- volume, high-frequency approach to smuggling counterfeits, thereby minimising financial losses incurred in the event of a seizure7. As these products were not subject to the same (if any) level of quality or regulatory scrutiny during their manufacturing process, they pose significant health and safety threats to consumers. In addition, it puts EU businesses at a competitive disadvantage with a loss of market share and revenues, and makes governments lose out on custom duties and tax revenues.

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…09.10.2023 Tobacco Europe – TE Avenue de Cortenbergh, 120 - B- 1000 Brussels EU Transparency Register: 1496873833-97 Registered number: 089 438 919 Tobacco Europe position on the Customs Reform Tobacco Europe AISBL1 represents the common views of major European–based tobacco and nicotine products manufacturers which includes British American Tobacco (BAT), Imperial Brands (IMB), and Japan Tobacco International (JTI). We welcome the customs reform and would like to present our position that follows the guiding principles of a collaborative mindset across jurisdictions and organisational siloes, common standards, interoperability between systems, a data-driven culture, and flexibility to learn and adapt. The proposed near-term solutions are fully in line with the conclusions of the Wise Persons Group report and the EU Commission proposal.

…solutions are fully in line with the conclusions of the Wise Persons Group report and the EU Commission proposal. We also believe that a greater collaboration between the private and public sector (EU customs and law enforcement authorities) can benefit the process for reforming the Union customs legislation and drafting the revised Delegated and Implementing Acts of the modernised Union Customs Code. Our Key Points • Removal of the customs duty ‘de Minimis’ threshold: e-commerce has created new distribution channels for illicit and counterfeit traded goods. A decrease of the customs duty ‘de Minimis threshold’ can contribute to the reduction of the illicit trade supply chains. We therefore welcome the EU Commission proposal to remove the EU ‘de-minimis’ threshold and we call on the EU Member States and the EU Commission to implement this recommendation as soon as possible.

…and we call on the EU Member States and the EU Commission to implement this recommendation as soon as possible. The EU Customs Reform proposal also introduces a simplified customs tariff for business to consumer (B2C) online transactions. We support the exclusion of tobacco products subject to harmonized excise duty. However, Chapter 24 of the CN contains products which are either tobacco raw materials (not subject to excise duty, but with a high risk from an illicit trade perspective) or products subject to non-harmonized excise duty in various EU Member States. The reference to Chapter 24 in the Bucket E of Annex I, Part One, Section II “Special Provisions” seems to indicate that raw materials for tobacco products and products subject to non-harmonized excise duty from Chapter 24 of the CN can be imported into the EU using the B2C simplified tariff.

…to non-harmonized excise duty from Chapter 24 of the CN can be imported into the EU using the B2C simplified tariff. We would have preferred that the entire chapter is kept out of the simplifications mechanism put forward by the Commission for B2C ecommerce transactions, but at the same time we acknowledge this may be solved if an updated Tobacco Excise Directive will come into place and which will very likely include most products from chapter 24. The removal of the “de minimis” threshold for e-commerce is also in line with the conclusions from OECD’s study on E-Commerce Challenges in Illicit Trade in Fakes2 where one of the suggested approaches is for “the need for economies to apply the WTO-TRIPS Article 60 de minimis exemption only to goods accompanying incoming passengers and not to mail importations and small parcels “.

…de minimis exemption only to goods accompanying incoming passengers and not to mail importations and small parcels “. 1 https://www.tobacco-europe.eu/ 2 E-Commerce challenges in Illicit Trade in Fakes. Governance Frameworks and Best Practices, 2021 Ref.

E-Commerce challenges in Illicit Trade in Fakes. Governance Frameworks and Best Practices, 2021 Ref. Ares(2023)7127032 - 19/10/2023 09.10.2023 Tobacco Europe – TE Avenue de Cortenbergh, 120 - B- 1000 Brussels EU Transparency Register: 1496873833-97 Registered number: 089 438 919 In addition, OECD’s study on “Misuse of Small Parcels for Trade in Counterfeit Goods3” identified that the attractiveness of small shipments as a vehicle for illicit trade is also affected by the special treatment that many countries have established for low value shipments The Commission’s proposal to reform the customs code is consistent with the EU’s Free Trade Agreements, OECD recommendations and the WTO agreements, including the WTO Trade Facilitation Agreement (WTO TFA). The technical arguments are further elaborated below in Annex 1. • Creation of the EU customs data hub and customs digitalization.

…arguments are further elaborated below in Annex 1. • Creation of the EU customs data hub and customs digitalization. The centralised EU Customs Data Hub is an ambitious move towards streamlining customs processes. At the same time, it is essential to approach this transformation with careful consideration of potential risks. The complete replacement of the current EU-27 IT systems with the Hub raises several concerns, particularly in the realms of data security and system reliability. There are many questions e.g. what measures will be implemented to ensure continued functionality in the event of system downtime or failure? How will competitive information be safeguarded to prevent unauthorised access or leaks?

…of system downtime or failure? How will competitive information be safeguarded to prevent unauthorised access or leaks? In addition, given that Trust & Check Traders will need to give real-time access to their electronic records, it is paramount to establish robust security nets to protect both company- specific and personal information. Ensuring data privacy and protection, and building robust defences against potential hacks or errors, should be at the forefront of this transition. While the overall concept aligns with existing authorisations and frameworks, the real-time access requirement introduces new vulnerabilities that must be meticulously addressed to preserve the integrity, trust and smooth functioning of the customs system.

…that must be meticulously addressed to preserve the integrity, trust and smooth functioning of the customs system. Therefore, as the EU moves forward with these innovations, we welcome a detailed risk assessment, along with the implementation of strong security protocols that are integral to the development process, ensuring that the advancements in customs enhance efficiency without compromising security and privacy. We believe the creation of the EU customs data hub is a huge step forward and look forward to the Commission’s proposal on smooth transition and collaboration with the industry players to achieve this objective. The EU Commission in collaboration with the EU Member States and the private sector should evaluate and determine the new and emerging technologies which support the customs union in controlling the safety and security risks associated with e-commerce.

…technologies which support the customs union in controlling the safety and security risks associated with e-commerce. These new and emerging technologies may include blockchain and artificial intelligence (AI) solutions. In addition, a solution to connect existing EU IT systems (such as track & trace) to the EU customs data hub should be put in place. • Trust & Check Trader and Trusted Supply Chains: the introduction of the 'Trust & Check Trader' status a promising development. It will benefit the EU companies and provide further simplifications from customs formalities. The concept of “self-assessment” and the change of EU customs approach from “transaction-based” to a “process-oriented” system can benefit EU companies. Although self-assessment concept is provided under UCC, this has not been fully implemented across the EU.

Although self-assessment concept is provided under UCC, this has not been fully implemented across the EU. Therefore, we believe that the Trust & Check Traders should be able to benefit of ‘self-assessment’ as soon as possible and not later than 2028. The customs 3 Misuse of Small Parcels for Trade in Counterfeit Goods 09.10.2023 Tobacco Europe – TE Avenue de Cortenbergh, 120 - B- 1000 Brussels EU Transparency Register: 1496873833-97 Registered number: 089 438 919 simplifications such as centralised clearance should be made available for Trust & Check Trader and Trusted Supply Chains dealing with excisable goods. • Timeline – acknowledging past challenges and looking at the future: the Commission should consider the need of implementing the outstanding measures under the UCC Work Programme4, before embarking on new, expansive measures.

…of implementing the outstanding measures under the UCC Work Programme4, before embarking on new, expansive measures. Failure to first deliver by 2025 on its existing commitments raises concerns over the practical feasibility of the new proposed measures. Whereas the long-term vision of the proposal and its aim to modernise the Union customs system is welcomed, it should be aligned with an understanding of the present reality, where many essential initiatives under the Work Programme have yet to be completed or even started. Therefore, a balanced approach that prioritises the implementation of the current legislation is essential, as this approach would ensure that the system is not over-burdened and progress is made in a responsible, gradual and systematic manner.

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Tobacco Europe AISBL Avenue de Cortenbergh, 120 – B – 1000 Brussels EU Transparency Register;1496873833-97 – Registered number: 089 438 919 Page | 1 Tobacco Europe position on the EU Commission Proposal for a Regulation on Packaging and Packaging Waste In Brief Tobacco Europe (TE)1 is fully committed to the EU Green Deal objectives and the respective efforts striving for the reduction of waste in general and packaging waste in particular. We welcome the choice of a Regulation as a legal instrument, as we believe that to fully achieve a sustainable circular economy, a higher level of harmonisation of EU waste and packaging legislation across EU Member States is needed. We also support the choice of an internal market legal basis as the right step towards boosting packaging circularity across the EU.

…the choice of an internal market legal basis as the right step towards boosting packaging circularity across the EU. However, we remain concerned that certain provisions included in the Commission’s proposal could still allow Member States to introduce diverging national requirements. Tobacco Europe is the umbrella organisation representing major European-based tobacco and nicotine products manufacturers. We take notice of the feedback period on the adopted act being opened and would like to provide comments accordingly. General Observations • Tobacco Europe would like to express its concerns for certain elements of the Commission’s proposal that would weaken the harmonisation attempts as certain provisions included in the Commission’s proposal still allow Member States to introduce diverging national requirements.

…included in the Commission’s proposal still allow Member States to introduce diverging national requirements. This is the case of labelling, as Member States can introduce further labelling for the purpose of identifying EPR schemes, (Art. 4 (4) and 4(5) and Art. 11(8)) or for sustainability purposes (Art. 11(7)). • Providing clarity and clear guidance for the industry around key provisions is crucial for successful implementation. It is of essence that the industry is given enough certainty and time to adapt to the new requirements. This clarity should also pertain to the adoption of related secondary legislation. The numerous Delegated and Implementing Acts foreseen by the proposal should be adopted with clear deadlines to ensure legal certainty for all operators.

Acts foreseen by the proposal should be adopted with clear deadlines to ensure legal certainty for all operators. • The proposed application date of 12 months after entry into force of the Regulation, is already very ambitious considering the extent and complexity of its provisions. Moreover, we noticed the lack of a specific exemption for products that have already been packaged before the entry into force of the requirements (e.g., transitional periods and rules on exhaustion of stocks). • We consider such an inclusion to be of crucial importance to provide clarity to all the operators and avoid any disruption in production and distribution processes.

…importance to provide clarity to all the operators and avoid any disruption in production and distribution processes. Remarks on some key provisions • Article 6 Recyclable packaging: We welcome the introduction of an EU-wide and clear definition of ‘recyclable packaging’ and the proposal to assess packaging recyclability against Design for Recycling (DfR) criteria. While food safety should not be in conflict with recycled content in Article 7, recyclability should not be in conflict with product sustainability (shelf-life, function & quality): barrier materials are needed for certain applications, however their recycling is barely possible as recycling technologies are not yet available. In addition, we believe that having aligned recycling infrastructures in all Member States is vital.

…not yet available. In addition, we believe that having aligned recycling infrastructures in all Member States is vital. We hope that the Delegated Act related to DfR will be issued timely and that economic operators will be involved in preparatory discussions to bring their views and expertise. 1 Tobacco Europe is the European association representing three of Europe’s largest producers of cigarettes, e-cigarettes, tobacco heated products and modern oral products. Our aim is to put forward the industry’s common views on regulation and policy and promote scientific and evidence-based policies that respects the choice of consumers. Ref.

…on regulation and policy and promote scientific and evidence-based policies that respects the choice of consumers. Ref. Ares(2023)2841710 - 21/04/2023 Tobacco Europe AISBL Avenue de Cortenbergh, 120 – B – 1000 Brussels EU Transparency Register;1496873833-97 – Registered number: 089 438 919 Page | 2 • Article 7 Recycled content: TE believes that this is a key to improve circularity, however targets for recycled content in plastic packaging should not be set on the individual plastic packaging units but rather as an average of all plastic packaging placed on the market by an economic operator. Moreover, due consideration should be given to the safety of consumers, particularly to existing limitations in relation to the use of recycled plastics in contact-sensitive applications.

…particularly to existing limitations in relation to the use of recycled plastics in contact-sensitive applications. To use recycled content coming from post-consumer waste, there are European Food Safety Authority (EFSA) approved recycling processes needed to ensure safety of consumer. In this regard, it is important to highlight that that food approved post-consumer recyclates (PCR) for plastic packaging are currently very limited on the market and this makes the reaching of the targets prescribed by the proposal very difficult. Therefore, we encourage EFSA to consider further recycled materials and relevant recycling technologies for food contact application, as well as further chemical recycling processes, in particular, the mass balance approach in accordance with International Sustainability & Carbon Certification (ISCC) should be considered.

…balance approach in accordance with International Sustainability & Carbon Certification (ISCC) should be considered. • Article 26 Refill and reuse targets: TE believes that reuse and refill targets should be assessed considering several elements, such as the preparation of the packaging for reuse, hygiene requirements, required infrastructure and logistics and the benefits of current alternatives. Reuse and refill targets should only be considered when it makes environmental and ecological sense. For instance, if the cleaning, transportation, and other parts of the process create higher Co2 footprint than recycling and manufacturing new packaging, then reuse would generate an environmental disadvantage.

Co2 footprint than recycling and manufacturing new packaging, then reuse would generate an environmental disadvantage. Considerations on provisions specifically impacting the tobacco sector • Article 11 Labelling: As stated above, TE welcomes the strengthened harmonisation of this regulation as it will help, among others, to put an end to the proliferation of national marking obligations that have created diverging legal requirements within the Union market, and we, therefore, believe that Member States should not be allowed to introduce further labelling requirements.

…and we, therefore, believe that Member States should not be allowed to introduce further labelling requirements. For the tobacco industry, the topic of labelling has a particular importance as our products are already subject to very strict and unique labelling requirements under the Directive 2014/40/EU2 which imposes the presence on our packaging of health warnings, combined health warnings (text and image), general warnings, cessation messages, a unique identifier aimed at granting the traceability of products and a security feature to ensure the integrity of the product. All dimensions and specifications related to the above elements are defined and mandated by the concerned Directive.

All dimensions and specifications related to the above elements are defined and mandated by the concerned Directive. In addition to the above, in several Members States our products are also subject to National health related and/or commercial related marking and labelling requirements that complicates the overall scenario. Moreover, tobacco products with filters are also subject to the Single-Use Plastic marking under the Directive 2019/904/EU3 aimed at indicating the presence of plastic in the filter. As a result, the remaining space on our packaging is already almost non-existent, and it would be impossible to place other markings on almost the entirety of our primary packaging.

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CECCM – Confederation of European Community Cigarette Manufacturers Avenue Louise, 375 B- 1050 Brussels [email protected] - Registered number 089 438 919 Brussels, 20 July 2018 CECCM position paper on the recast of the Council the Directive 2008/118/EC concerning the general arrangements for excise duty CECCM position reflects the views of its member companies, namely British American Tobacco (BAT), Japan Tobacco International (JTI) and Imperial Brands (IMB).

…member companies, namely British American Tobacco (BAT), Japan Tobacco International (JTI) and Imperial Brands (IMB). CECCM welcomes the proposal for the recast of the Council Directive 2008/118/EC concerning the general arrangements for excise duty (hereinafter referred to as “Horizontal Directive”) made by the Commission, starting with the alignment between the terminology used by the Excise Directive and the Union Customs Code (UCC) as well as the solutions put forward to further harmonize excise and customs procedures (both on the import and export sides) among which: • Automated interface between EMCS (Excise Movement and Control System) and AES (Automated Export System); • Automated data cross-check between electronic excise and customs systems; • Common list of alternative proofs of exit; • Common requirements for duty exemptions at import.

…and customs systems; • Common list of alternative proofs of exit; • Common requirements for duty exemptions at import. On excise and customs interactions topic, we concur with Commission’s view that export followed by external transit should be allowed for excise goods. Interactions between excise and customs could also be covering deliveries of excise goods to special fiscal territories (e.g. Canary Islands), which are considered part of the customs territory of the EU, but which are currently not in scope of the Horizontal Directive. On duty paid Business to Business procedures, CECCM welcomes the extension of EMCS to cover cross border duty paid movements. About exceptional situations such as shortages, excesses, rejections or interruptions, CECCM regrets the Commission’s decision not to suggest a common approach in the proposal, but to leave this to a delegated act.

…the Commission’s decision not to suggest a common approach in the proposal, but to leave this to a delegated act. If this would remain the case, CECCM believes the delegated act should be proportionate and designed in consultation with relevant stakeholders. Furthermore, with regards to the right to be heard for economic operators, CECCM also regrets no harmonized approach has been proposed. However, CECCM supports the usage of EMCS data as input to recovery instruments. Together with its members, CECCM considers that the revised Directive 2008/118/EC should contain new provisions that would allow the Member State of dispatch to reimburse or remit excise where there is evidence that the relevant goods, involved in a discrepancy, are held in an excise warehouse in the Member State of destination or have left the territory of the European Union.

…are held in an excise warehouse in the Member State of destination or have left the territory of the European Union. Regarding guarantees, CECCM believes that the EU Commission has missed the opportunity to improve and simplify the legal framework, more precisely to allow for alternative instruments in lieu of traditional means of guarantees (e.g. promissory note) and for taking into consideration the internal market aspects (e.g. by ensuring mutual recognition of guarantees to be provided by a financial institution in any EU country). Ref. Ares(2018)3931552 - 24/07/2018 CECCM – Confederation of European Community Cigarette Manufacturers Avenue Louise, 375 B- 1050 Brussels [email protected] - Registered number 089 438 919 Also, in case guarantees are required for tax stamps, tolerance should be permitted allowing tax stamps to exceed the guarantee.

…case guarantees are required for tax stamps, tolerance should be permitted allowing tax stamps to exceed the guarantee. Finally, on excise refund, CECCM considers that mutual recognition of tax stamps destruction by government officials should be promoted at EU level to reduce the administrative burden for economic operators. Refund procedure should exist for excise goods which are returned / withdrawn from the market after their release for consumption due to quality issues. Importantly, tax stamps that have not been used in production should not trigger excise liability given that the excise goods have not been released for consumption. Last but not least, CECCM would welcome a specific clause in the revised Directive on a refund procedure for excise goods in case those goods are withdrawn (or returned) from the market after having been released for consumption.

…in case those goods are withdrawn (or returned) from the market after having been released for consumption. We are looking forward to a continued fruitful collaboration and in the meantime, we remain at your disposal for any further clarification you may need.

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