European Public Health Alliance

AISBL· Rue de Trèves 49-51 • 1040 Brussels • BELGIUM VAT - BE 0451133736 | Transparency Register Number: 18941013532-08 +32 (0) 2 230 30 56 | www.epha.org | [email protected] | twitter: @EPHA_EU EPHA response - Excise duty on alcohol and alcoholic beverages – evaluation of excise duty rates and tax structures 4 July 2022 The European Public Health Alliance (EPHA) is a leading European civil society alliance in Brussels, made up of 80 public health NGOs, patient groups, health professionals and disease groups, working to improve health and strengthen the voice of public health in Europe. EPHA welcomes the European Commission's evaluation of excise duty rates and tax structures on alcoholic beverages. It is timely and health of the European citizens should be part of the review of the upcoming exercise, as per the mandate of the EU.

…health of the European citizens should be part of the review of the upcoming exercise, as per the mandate of the EU. From EPHA’s perspective, it is essential to comprehensively fight alcohol-related harms to achieve the United Nations Sustainable Development Goals (SDGs)target to reduce by at least 10% the harmful use of alcohol by 2025. Referring to the Mission letter from Ursula von der Leyen to Commissioner for Health and Safety, December 2019, each Commissioner will ensure the delivery of the UN SDGs within their policy area as this responsibility is carried by the Commission as guardian for all EU. Affordability is one of the key factors that impact alcohol consumption. Any type of measures implemented to control or affect the prices and affordability of alcohol can reduce alcohol consumption and therefore harm.

…to control or affect the prices and affordability of alcohol can reduce alcohol consumption and therefore harm. In the context of a competitive market, alcohol consumption is negatively correlated with price, meaning that as price increases, consumers will reduce their consumptioni. The overall price elasticity of alcohol demand has an average value of approximately −0.5, which means that a 1% increase in alcohol prices will yield a 0.5% reduction in its consumption. All countries in the EU levy taxes on alcohol in one form or another, although there are many that de facto do not have a tax on wine. A growing body of research demonstrates that alcohol affordability has generally been increasing in the EU because population income has increased while the relative prices of alcoholic beverages have remained generally stable or fallen.

…income has increased while the relative prices of alcoholic beverages have remained generally stable or fallen. These low prices are supported not only by the relatively low alcohol excise rates, but also by the long- lasting financial support of the EU to wine producersii. EPHA in alignment with its members emphasises that the main priority of the ongoing evaluation should be to implement a tax structure that promotes and protects public health and facilitates Member States’ abilities to implement the most efficient tax structure to reduce alcohol consumption and alcohol-related harm. Ref.

…abilities to implement the most efficient tax structure to reduce alcohol consumption and alcohol-related harm. Ref. Ares(2022)4877425 - 04/07/2022 AISBL· Rue de Trèves 49-51 • 1040 Brussels • BELGIUM VAT - BE 0451133736 | Transparency Register Number: 18941013532-08 +32 (0) 2 230 30 56 | www.epha.org | [email protected] | twitter: @EPHA_EU EPHA would like to call upon the Commission to the following:  Ensure that all alcohol products are taxed based on alcoholic strength and therefore depart from the current tax structure on wine and fermented beverages that is based on volume of finished product.  Raise the EU minimum tax levels on all alcoholic beverages but especially for beverages where the current minimum levels are 0 (for example wine and fermented beverages).  Index the minimum tax levels to match price developments and ensure that the minimum tax levels stay relevant over time.

…the minimum tax levels to match price developments and ensure that the minimum tax levels stay relevant over time. To conclude, as guided by WHO evidence, alcohol pricing policies and alcohol taxation are among the most effective and cost–effective measures to reduce alcohol consumption and harms, but they are also the most underutilised. Alcohol taxation is applied in most EU countries to set pricing policy, yet these taxes are often not implemented in a way that can improve the public health impact. EPHA supports the responses of its members, the European Alcohol Policy Alliance (Eurocare), European Heart Network and IOGT-NTO. EPHA calls upon the Commission to act upon its duty and review the evidence presented by EPHA and its members. References iThe affordability of alcoholic beverages in the European Union Understanding the link between alcohol affordability, consumption and harms.

…alcoholic beverages in the European Union Understanding the link between alcohol affordability, consumption and harms. Lila Rabinovich, Philipp-Bastian Brutscher, Han de Vries, Jan Tiessen, Jack Clift, Anais Reding on behalf of RAND Europe for DG SANCO, December 2009. https://ec.europa.eu/health/ph_determinants/life_style/alcohol/documents/alcohol_rand_en.pdf ii Alcohol pricing in the WHO European Region. Update Report on the Evidence and Recommended Policy Action. World Health Organization, Regional Office for Europe, Copenhagen, Denmark, 2020. https://apps.who.int/iris/bitstream/handle/10665/336159/WHO-EURO-2020-1239-40989-55614- eng.pdf?sequence=1&isAllowed=y

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