Comité Européen des Entreprises Vins

The wine sector proudly ensures economic sustainability and maintains high level of employment in many EU rural regions, in particular in some marginal ones where there would be no sustainable alternative to vine growing. An excessive taxation of wine products would jeopardise, inter alia, the ability of the sector to help maintain the socio-economic sustainability of EU rural areas. The wine sector is a major contributor to national income. Taxes deriving from vine-growing and wine production - including agricultural taxes, personal income taxes, corporate taxes, tax on subsidiary sectors - go far beyond excise duties and represent a significant contribution to national fiscal and welfare incomes, especially in wine producing countries.

…represent a significant contribution to national fiscal and welfare incomes, especially in wine producing countries. Moreover, the full economic cycle of wine production and marketing involves many direct and indirect actors operating and interacting all along the wine chain, contributing significantly to the national fiscal income. With a minimum excise duty equal to zero, the EU ensures the implementation of a fair taxation system that takes into account the bigger and paramount role played by wine production in maintaining activities and jobs in rural areas compared to other alcoholic beverages production and helps addressing the structural economic competitiveness. With an overwhelming majority of small producers, a zero excise duty is justified by the huge investments our sector requires in terms of infrastructures and land.

…a zero excise duty is justified by the huge investments our sector requires in terms of infrastructures and land. Also, grape growing and the processing of grape- fermented beverages generally have higher production costs compared to other alcoholic beverages (non-grape based). Despite recent unwelcomed modifications to Directive 92/83/EEC opening the possibility to discriminate operators, the existing regime fulfils quite well its purpose. WINE & EU TAXATION POLICY Taxing wine is taxing agriculture APRIL 2021 PAGE 1/4 Wine deserves a fair taxation system including a specific excise duty rate 3.2 MILLION HECTARES VINEYARD 2.5 3 THE EU WINE SECTOR MILLION WINE HOLDINGS MILLION FULLTIME JOBS Ref.

…rate 3.2 MILLION HECTARES VINEYARD 2.5 3 THE EU WINE SECTOR MILLION WINE HOLDINGS MILLION FULLTIME JOBS Ref. Ares(2022)4408766 - 15/06/2022 No discriminatory taxation of wine products based on their specific composition Behavioural taxes linked to the specific composition of products are often based on subjective and weak argumentation and tend to determine a fast decrease in the presence of the concerned products on the market, resulting in consumers orientating themselves towards other products. Those specific taxes increase legislative complexity and hinder the Single Market’s smooth functioning. URGENT NEED TO IMPROVE THE DISTANCE SELLING REGIME An improvement of the current distance selling framework is particularly important for the wine sector to allow economic operators to fully enjoy the Single Market.

…framework is particularly important for the wine sector to allow economic operators to fully enjoy the Single Market. The potential of cross-border e-commerce remains untapped while this channel of distribution has been booming at domestic level in the last years. A better functioning of the distance selling framework would allow the sector to partially compensate losses linked to the COVID-19 crisis. No taxation by degree of alcohol A taxation system purely based on the alcoholic strength of the product would disrupt the competition within the wine and aromatised wine sector. In addition, the final alcohol content of wine is not directly controlled by the producer but is influenced by parameters such as climate conditions and vine varieties. Taxation should therefore be based on volume to avoid discrimination between different areas of production.

…varieties. Taxation should therefore be based on volume to avoid discrimination between different areas of production. No discrimination for sparkling wines Arguments to apply a specific excise duty to still wine are also valid for the application of the same excise duty to sparkling wines. Excise tax rates are specific taxation, not ad valorem, so they should not be based on quality and price of wine products. Applying higher excise duties to sparkling wines does not seem justified within the wine category and does not exist for other alcoholic beverages categories. No discrimination by size of companies Reduced rates for small producers would disrupt the normal functioning of the complex structure of the wine sector, limit Members States' capacity to collect excise duties and increase the complexity of administrative procedures, thus increasing the risk of fraud.

…to collect excise duties and increase the complexity of administrative procedures, thus increasing the risk of fraud. No discrimination for intermediate products - liqueur wines Intermediate products are still agricultural products part of the wine family that also need higher investments and have higher production costs. Liqueur wines are crucial for the socio-economic sustainability of some of the most remote and marginal rural areas in Europe. They are generally consumed in moderation, with a specific serving size, and should not be subject to higher taxes because of their higher alcohol degree.

…with a specific serving size, and should not be subject to higher taxes because of their higher alcohol degree. PAGE 2/4 PRINCIPLES FOR A FAIR AND ADAPTED EXCISE DUTY REGIME FOR WINE PRODUCTS Taxation is not the silver bullet against harmful alcohol consumption – it discriminates moderate wine consumers primarily Excessive taxation nurtures illicit market PAGE 3/4 Taxation does not seem to be an effective tool to tackle harmful use of alcohol and it penalises the vast majority of consumers drinking in moderation. It wrongly targets per capita consumption instead of harmful consumption. As a matter of fact, excessive drinkers including young people, seem to be least price responsive.

…consumption. As a matter of fact, excessive drinkers including young people, seem to be least price responsive. Empirical evidence suggests that broader social, demographic, and economic factors may play a more significant role in shaping drinking patterns than regulatory measures, including taxation and pricing policies. A significant number of critical factors such as consumer preferences and choice, changes in income, alternative sources of alcohol in the country or in neighbouring countries, and the presence or absence of other alcohol policy measures may influence the effectiveness of pricing policies. Disproportionate taxes and other pricing policies or alcohol availability restrictions/bans may lead to tax evasion, corruption and illicit trade.

…other pricing policies or alcohol availability restrictions/bans may lead to tax evasion, corruption and illicit trade. The unintended outcomes include government revenue losses instead of gains, upsurge in illicit markets and criminal activity, and potential health effects due to unrecorded alcohol consumption. It also undermines legitimate businesses and formal job opportunities. TAX INCREASES AND PREDICTING MODELS Earlier work around the impact of taxation relies largely on aggregate consumption measures, such as per capita consumption and population- based indicators, obscuring the variations in impact within populations and across drinking patterns. Much of the evidence for taxation as a health policy tool is based on predictive models and projections of outcomes, and less often on empirical evidence.

…a health policy tool is based on predictive models and projections of outcomes, and less often on empirical evidence. Assessments of consumers’ responses to taxation depend on the methodology used and are influenced by additional factors. ABOUT CROSS-BORDER SHOPPING There is no indication that alcohol purchased cross-border during, for example, an oeno- gastronomic holiday will be consumed in excess of what national drinking guidelines recommend. Wine is not a perishable product therefore any comparison between the quantity purchased and the annual consumption is not relevant. A better enforcement of the current cross-border legislation would help reducing the risk of fraud and continue to contribute to the proper functioning of the internal market.

…would help reducing the risk of fraud and continue to contribute to the proper functioning of the internal market. About the EU Wine sector PAGE 4/4 Comité Européen des Entreprises Vins (CEEV) represents the European Union wine companies in the industry and trade (still wines, aromatised wines, sparkling wines, liqueur wines and other vine products). It brings together 23 national organisations from 11 EU Member States, plus Switzerland, UK and Ukraine, as well as a consortium of 4 leading European wine companies. The companies represented by CEEV, mainly SMEs, produce and market most quality European wines, both with and without a geographical indication, and account for over 90% of European wine exports. If you would like to learn more about CEEV or about this factsheet, please visit www.ceev.eu.

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originalus šaltinis (PDF) ↗

…1 Brussels, 23 March 2023 The Comité Européen des Entreprises Vins (CEEV – www.ceev.eu) represents the wine companies in the industry and trade in the European Union: still wines, aromatised wines, sparkling wines, liqueur wines and other vine products. It brings together 25 national organisations from 13 EU Member States, plus Switzerland, the United Kingdom and Ukraine, as well as a consortium of 4 leading European wine companies. Its members produce and market the vast majority of quality European wines, with and without a geographical indication, and account for over 90% of European wine exports. CEEV supports efforts to tackle packaging waste, plastic pollution and to reduce the environmental impact of packaging across the EU.

…efforts to tackle packaging waste, plastic pollution and to reduce the environmental impact of packaging across the EU. We welcome the choice of the regulatory instrument – Regulation rather than a Directive – allowing for better harmonisation and preventing circularity obstacles for the wine industry within the EU market. However, several requirements introduced by the legislative proposal of regulation on packaging and packaging waste, notably on reuse and packaging minimisation, fail to recognize the specificities of our sector and the efforts carried out over the years.

…packaging minimisation, fail to recognize the specificities of our sector and the efforts carried out over the years. Namely that:  The collection for recycling rate of glass packaging is best in class with 80% on average across the EU1  We are an export-oriented sector: in 2021, the wine market internationalisation index was at 47%, meaning that on average in 2021, for every two bottles of wine consumed in the world about one has crossed (at least) one border2  We are making progress together with glass producers to reduce our packaging footprint: A couple of years ago a wine bottle would weight 547 g on average. Today, most wine bottles weight around 415 grammes, sometimes 375 grammes when technically feasible.  Digital tools exist to provide relevant and tailored packaging and recycling information to consumers in their own language using geolocalisation.

…relevant and tailored packaging and recycling information to consumers in their own language using geolocalisation. The case of Italy where QR codes are now used on wine and spirits bottles should be considered at EU level. CEEV therefore calls for: 1. Recognition that glass is a very circular material that can be reused and infinitely recycled; 2. Support towards the wine industry efforts over the years for bottles lightweighting while guaranteeing specific protection for GI and trademark bottles; 3. Exempting wine bottles from the mandatory reuse targets and instead greater support and incentives for voluntary initiatives which make sense economically and environmentally; 4. Support for digital labelling solutions as an effective means to provide product-specific packaging and recycling information to consumers.

…labelling solutions as an effective means to provide product-specific packaging and recycling information to consumers. 1 Container glass collection for recycling in Europe 2020 – map can be found at https://closetheglassloop.eu/wp- content/uploads/2022/06/2020-Map-FINAL-080922.jpg 2 State of the World Vine and Wine Sector - April 2022 https://www.oiv.int/js/lib/pdfjs/web/viewer.html?file=/public/medias/8773/pptpress-conf-2022-4-def.pdf CEEV POSITION ON PACKAGING AND PACKAGING WASTE (PPW) PROPOSAL OF REGULATION ( ) Ref. Ares(2023)2882676 - 24/04/2023 2 I. GLASS, A UNIQUE MATERIAL RESPONDING BOTH THE SPECIFICITIES OF THE WINE INDUSTRY AND ENVIRONMENTAL CONCERNS Glass has long been leading the way in circularity.

THE SPECIFICITIES OF THE WINE INDUSTRY AND ENVIRONMENTAL CONCERNS Glass has long been leading the way in circularity. It is 100% recyclable, inert and preserves like no other material the quality of the wines it contains, in a safe way for the consumer, for years, thus being adapted to wines with no use-by date. In the last 20 years the weight of glass bottles has been reduced by 20% on average3. With a collection for recycling rate at nearly 80% in the EU, glass is way ahead of any other packaging material4. Glass retains its intrinsic properties, no matter how many times it is recycled. This means it can be endlessly recycled. The EU wine sector is partnering with the glass packaging value chain to achieve the ambitious target of collecting at least 90% of all glass packaging placed on the EU market, for recycling in a bottle-to-bottle closed loop, by 20305.

…at least 90% of all glass packaging placed on the EU market, for recycling in a bottle-to-bottle closed loop, by 20305. The life cycle assessment studies for the comparison of recycling vs. reuse solutions for glass bottles also need to include the specificities of the sector (e.g. reality of large companies vs. small producers, geographical distances…). Decarbonization efforts made by suppliers including innovative projects for new electric or hybrid ovens should be further supported and promoted. Distinctive, innovative glass packaging creates brand differentiation gives a premium look and feel to products. The glass packaging contributes crucially and directly to a product’s appeal to the consumer and the value added.  The new legal framework should be built on the proven success of the glass containers being an important asset for wine sector and its circularity. II.

…built on the proven success of the glass containers being an important asset for wine sector and its circularity. II. THE WINE INDUSTRY SHOULD BE ENCOURAGED TO PURSUING ITS EFFORTS TOWARDS PACKAGING MINIMISATION CEEV welcomes the reference to the material that the packaging is made of, as well as to the packaging functionality, when establishing an obligation of weight & volume reduction in the Regulation. Indeed, arbitrary weight restriction would have ignored the wine industry specificities. Considerable efforts have already been made by wine professionals throughout the supply chain to reduce over- packaging and weight. Besides, light-weighting is an area of interest to reduce costs (e.g., packaging costs, EPR fees…), especially for an export-driven industry like ours. A couple of years ago a wine bottle would weight 547 g on average.

…especially for an export-driven industry like ours. A couple of years ago a wine bottle would weight 547 g on average. Today, most of the bottles weight around 415 grammes, sometimes 375 grammes when very- lightweight bottles can be used. Such reduction however encounters technical limits for some products and is not always possible. For instance, sparkling wines require a pressure-resistant material, preventing the use of light weight bottles for safety reasons. More generally, above a certain threshold of weight reduction, the increased risk of breakage and the related safety concerns for the consumer must be considered.

…weight reduction, the increased risk of breakage and the related safety concerns for the consumer must be considered. Glass packaging also require protection to avoid 3 https://feve.org/the-sustainable-development-goals-our-future-is-glass/ 4 Container glass collection for recycling in Europe 2020 – map can be found at https://closetheglassloop.eu/wp- content/uploads/2022/06/2020-Map-FINAL-080922.jpg Detailed figures per Member States on glass collection recycling rates are available at https://closetheglassloop.eu/europes-glass-value-chain-reaches-major-milestone/ 5 Multi-stakeholder Partnership initiated by the EU Federation of Glass Containers (FEVE) that brings together glass manufacturers, glass recyclers, food & beverage producers, extended producer responsibility schemes, and local and regional authorities to achieve a 90% average EU collection rate of used glass packaging by…

…to achieve a 90% average EU collection rate of used glass packaging by 2030 and improve the quality of recycled glass. See more on https://closetheglassloop.eu/ https://www.ceev.eu/newsletter/close-the-glass-loop-and-the-european-wine-sector-cheer-to-their-partnership/ 3 breakage during the transport. This should be considered as characteristics justifying additional protective packaging, and not be considered as empty space or over-packaging. CEEV also regrets the fact that, while acknowledging the need to consider GI products specifications, as well as the fact that marketing and consumer acceptance remain relevant for packaging design6, the latter were excluded from the list of performance criteria justifying packaging weight and volume.

…design6, the latter were excluded from the list of performance criteria justifying packaging weight and volume. Such exclusion seems to ignore the cultural heritage attached to EU wine, the role of packaging in supporting GI and/or brand identification, elevation and premiumisation, that is integral part of EU wines success. This is especially true abroad, where bottle designs have a huge economic impact. Last but not least, such omission could question the use of specific – and often protected – bottles / packaging attached to a brand, sometimes for years, in favour of a standardization, therefore challenging the legal certainty for companies that invested a lot in building a brand identity.  The recognition of packaging design and consumer acceptance as integral to the packaging functionality shall be included in the performance criteria listed in Annex IV.

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originalus šaltinis (PDF) ↗

The wine sector proudly ensures economic sustainability and maintains high level of employment in many EU rural regions, in particular in some marginal ones where there would be no sustainable alternative to vine growing. An excessive taxation of wine products would jeopardise, inter alia, the ability of the sector to help maintain the socio-economic sustainability of EU rural areas. The wine sector is a major contributor to national income. Taxes deriving from vine-growing and wine production - including agricultural taxes, personal income taxes, corporate taxes, tax on subsidiary sectors - go far beyond excise duties and represent a significant contribution to national fiscal and welfare incomes, especially in wine producing countries.

…represent a significant contribution to national fiscal and welfare incomes, especially in wine producing countries. Moreover, the full economic cycle of wine production and marketing involves many direct and indirect actors operating and interacting all along the wine chain, contributing significantly to the national fiscal income. With a minimum excise duty equal to zero, the EU ensures the implementation of a fair taxation system that takes into account the bigger and paramount role played by wine production in maintaining activities and jobs in rural areas compared to other alcoholic beverages production and helps addressing the structural economic competitiveness. With an overwhelming majority of small producers, a zero excise duty is justified by the huge investments our sector requires in terms of infrastructures and land.

…a zero excise duty is justified by the huge investments our sector requires in terms of infrastructures and land. Also, grape growing and the processing of grape- fermented beverages generally have higher production costs compared to other alcoholic beverages (non-grape based). Despite recent unwelcomed modifications to Directive 92/83/EEC opening the possibility to discriminate operators, the existing regime fulfils quite well its purpose. WINE & EU TAXATION POLICY Taxing wine is taxing agriculture APRIL 2021 PAGE 1/4 Wine deserves a fair taxation system including a specific excise duty rate 3.2 MILLION HECTARES VINEYARD 2.5 3 THE EU WINE SECTOR MILLION WINE HOLDINGS MILLION FULLTIME JOBS Ref.

…rate 3.2 MILLION HECTARES VINEYARD 2.5 3 THE EU WINE SECTOR MILLION WINE HOLDINGS MILLION FULLTIME JOBS Ref. Ares(2022)4442072 - 16/06/2022 No discriminatory taxation of wine products based on their specific composition Behavioural taxes linked to the specific composition of products are often based on subjective and weak argumentation and tend to determine a fast decrease in the presence of the concerned products on the market, resulting in consumers orientating themselves towards other products. Those specific taxes increase legislative complexity and hinder the Single Market’s smooth functioning. URGENT NEED TO IMPROVE THE DISTANCE SELLING REGIME An improvement of the current distance selling framework is particularly important for the wine sector to allow economic operators to fully enjoy the Single Market.

…framework is particularly important for the wine sector to allow economic operators to fully enjoy the Single Market. The potential of cross-border e-commerce remains untapped while this channel of distribution has been booming at domestic level in the last years. A better functioning of the distance selling framework would allow the sector to partially compensate losses linked to the COVID-19 crisis. No taxation by degree of alcohol A taxation system purely based on the alcoholic strength of the product would disrupt the competition within the wine and aromatised wine sector. In addition, the final alcohol content of wine is not directly controlled by the producer but is influenced by parameters such as climate conditions and vine varieties. Taxation should therefore be based on volume to avoid discrimination between different areas of production.

…varieties. Taxation should therefore be based on volume to avoid discrimination between different areas of production. No discrimination for sparkling wines Arguments to apply a specific excise duty to still wine are also valid for the application of the same excise duty to sparkling wines. Excise tax rates are specific taxation, not ad valorem, so they should not be based on quality and price of wine products. Applying higher excise duties to sparkling wines does not seem justified within the wine category and does not exist for other alcoholic beverages categories. No discrimination by size of companies Reduced rates for small producers would disrupt the normal functioning of the complex structure of the wine sector, limit Members States' capacity to collect excise duties and increase the complexity of administrative procedures, thus increasing the risk of fraud.

…to collect excise duties and increase the complexity of administrative procedures, thus increasing the risk of fraud. No discrimination for intermediate products - liqueur wines Intermediate products are still agricultural products part of the wine family that also need higher investments and have higher production costs. Liqueur wines are crucial for the socio-economic sustainability of some of the most remote and marginal rural areas in Europe. They are generally consumed in moderation, with a specific serving size, and should not be subject to higher taxes because of their higher alcohol degree.

…with a specific serving size, and should not be subject to higher taxes because of their higher alcohol degree. PAGE 2/4 PRINCIPLES FOR A FAIR AND ADAPTED EXCISE DUTY REGIME FOR WINE PRODUCTS Taxation is not the silver bullet against harmful alcohol consumption – it discriminates moderate wine consumers primarily Excessive taxation nurtures illicit market PAGE 3/4 Taxation does not seem to be an effective tool to tackle harmful use of alcohol and it penalises the vast majority of consumers drinking in moderation. It wrongly targets per capita consumption instead of harmful consumption. As a matter of fact, excessive drinkers including young people, seem to be least price responsive.

…consumption. As a matter of fact, excessive drinkers including young people, seem to be least price responsive. Empirical evidence suggests that broader social, demographic, and economic factors may play a more significant role in shaping drinking patterns than regulatory measures, including taxation and pricing policies. A significant number of critical factors such as consumer preferences and choice, changes in income, alternative sources of alcohol in the country or in neighbouring countries, and the presence or absence of other alcohol policy measures may influence the effectiveness of pricing policies. Disproportionate taxes and other pricing policies or alcohol availability restrictions/bans may lead to tax evasion, corruption and illicit trade.

…other pricing policies or alcohol availability restrictions/bans may lead to tax evasion, corruption and illicit trade. The unintended outcomes include government revenue losses instead of gains, upsurge in illicit markets and criminal activity, and potential health effects due to unrecorded alcohol consumption. It also undermines legitimate businesses and formal job opportunities. TAX INCREASES AND PREDICTING MODELS Earlier work around the impact of taxation relies largely on aggregate consumption measures, such as per capita consumption and population- based indicators, obscuring the variations in impact within populations and across drinking patterns. Much of the evidence for taxation as a health policy tool is based on predictive models and projections of outcomes, and less often on empirical evidence.

…a health policy tool is based on predictive models and projections of outcomes, and less often on empirical evidence. Assessments of consumers’ responses to taxation depend on the methodology used and are influenced by additional factors. ABOUT CROSS-BORDER SHOPPING There is no indication that alcohol purchased cross-border during, for example, an oeno- gastronomic holiday will be consumed in excess of what national drinking guidelines recommend. Wine is not a perishable product therefore any comparison between the quantity purchased and the annual consumption is not relevant. A better enforcement of the current cross-border legislation would help reducing the risk of fraud and continue to contribute to the proper functioning of the internal market.

…would help reducing the risk of fraud and continue to contribute to the proper functioning of the internal market. About the EU Wine sector PAGE 4/4 Comité Européen des Entreprises Vins (CEEV) represents the European Union wine companies in the industry and trade (still wines, aromatised wines, sparkling wines, liqueur wines and other vine products). It brings together 23 national organisations from 11 EU Member States, plus Switzerland, UK and Ukraine, as well as a consortium of 4 leading European wine companies. The companies represented by CEEV, mainly SMEs, produce and market most quality European wines, both with and without a geographical indication, and account for over 90% of European wine exports. If you would like to learn more about CEEV or about this factsheet, please visit www.ceev.eu.

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originalus šaltinis (PDF) ↗