European Chronic Disease Alliance (ECDA)

ECDA’s response - Public consultation “Evaluation of the rates and structures of excise duty on alcohol and alcoholic beverages” The European Chronic Disease Alliance (ECDA) welcomes the opportunity to provide input on the evaluation of the rules governing excise duty on alcohol and alcoholic beverages. These have not been updated in the past 30 years (since 1992) despite market evolutions, consumption changes and continuously growing evidence on the negative impact of alcohol consumption on people’s health. It is therefore high time to consider the effectiveness of the current system and ways to improve it, with a view to pursue public health efforts in Europe – including prevention of major non-communicable diseases, which share alcohol consumption as a common, detrimental risk factor1.

…prevention of major non-communicable diseases, which share alcohol consumption as a common, detrimental risk factor1. There is strong evidence on the benefits and value of raising alcohol taxation, part of the “best buys” (cost-effective interventions) recommended by WHO to lower alcohol consumption levels and address one of the major public health challenges of the EU. Taxation allows to decrease affordability of alcohol. Yet, it remains one of the least implemented measures. Recent studies have shown that alcohol remains very affordable in Europe, and that alcohol taxes have been under-utilized as a public health measure2. They have also concluded that implementing a minimum tax share would yield significant health benefits3.

…measure2. They have also concluded that implementing a minimum tax share would yield significant health benefits3. In light of the evidence and detrimental effects of alcohol consumption on health and the economy, the EU should increase minimum excise duties to the highest possible, setting up a harmonized level of tax across Europe for all types of alcoholic beverages. A recent study4 led by the NCD Advisory Council under the new WHO signature initiative has calculated how alcohol tax increase will impact mortality in the WHO European region and provided recommended minimum levels for such a tax. Further, we would like to stress the following points:  The Court of Justice of the European Union judged Minimum Unit Pricing (MUP) to be more effective than comparable measures as it was highly targeted at harmful and extreme drinks and was likely to reduce health inequality.

…comparable measures as it was highly targeted at harmful and extreme drinks and was likely to reduce health inequality. This decision should prompt the EU to be more active in supporting implementation of this tax across Europe, in accordance with WHO recommendations.  The EU should support regular monitoring of the share of excise taxes on the price of alcohol beverages in member states and provide guidance to promote reforms that increase tax share.  Alongside alcohol taxation to increase the price of alcohol products, the EU should stimulate implementation of other alcohol control measures recommended by the WHO as part of the “best-buys”, in particular restricting alcohol availability and banning advertising. In these areas, action needs to be taken urgently in particular to protect Europe’s younger generations. 1 European Commission.

…areas, action needs to be taken urgently in particular to protect Europe’s younger generations. 1 European Commission. Health Promotion and Disease Prevention Knowledge Gateway. Alcohol consumption: effects on health. https://knowledge4policy.ec.europa.eu/health-promotion-knowledge-gateway/alcoholic-beverages_en 2 Neufeld, M., Rovira, P., Ferreira-Borges, C., Kilian, C., Sassi, F., Veryga, A. and Rehm, J., 2022. Impact of introducing a minimum alcohol tax share in retail prices on alcohol-attributable mortality in the WHO European Region: A modelling study. The Lancet Regional Health - Europe, p.100325 3 Idem 4 Idem Deadline: 4 July 2022 Open form Character limit: 4000 More information here Ref.

- Europe, p.100325 3 Idem 4 Idem Deadline: 4 July 2022 Open form Character limit: 4000 More information here Ref. Ares(2022)4848956 - 02/07/2022 Raising alcohol taxes should be seen as a major step to save lives and prevent the harm caused by alcohol consumption, which affects multiple age groups and which no member state has been spared from. KEY FACTS - Approximately 268,000 deaths and almost 8 million Disability-Adjusted Life Years (years of life lost) attributable to alcohol consumption in the EU in 2019 are related to non-communicable diseases5. Better prevention and control of alcohol consumption would bring significant health, economic and societal benefits; and is integral to managing and reducing the prevalence of major NCDs. - Annually, introducing a minimum tax share of 25% could prevent 40,033 deaths in the WHO European Region.

…major NCDs. - Annually, introducing a minimum tax share of 25% could prevent 40,033 deaths in the WHO European Region. For reference, this level accounts for one third of the WHO-recommended tax share of cigarettes. A 15% tax share with equalization could prevent 132,906 deaths6. 5 European Commission. Health Promotion and Disease Prevention Knowledge Gateway. Alcohol consumption: effects on health. https://knowledge4policy.ec.europa.eu/health-promotion-knowledge-gateway/alcoholic-beverages_en 6 Neufeld, M., Rovira, P., Ferreira-Borges, C., Kilian, C., Sassi, F., Veryga, A. and Rehm, J., 2022. Impact of introducing a minimum alcohol tax share in retail prices on alcohol-attributable mortality in the WHO European Region: A modelling study. The Lancet Regional Health - Europe, p.100325

originalus šaltinis (PDF) ↗

ECDA’s response - Public consultation “Evaluation of the rates and structures of excise duty on alcohol and alcoholic beverages” The European Chronic Disease Alliance (ECDA) welcomes the opportunity to provide input on the evaluation of the rules governing excise duty on alcohol and alcoholic beverages. These have not been updated in the past 30 years (since 1992) despite market evolutions, consumption changes and continuously growing evidence on the negative impact of alcohol consumption on people’s health. It is therefore high time to consider the effectiveness of the current system and ways to improve it, with a view to pursue public health efforts in Europe – including prevention of major non-communicable diseases, which share alcohol consumption as a common, detrimental risk factor1.

…prevention of major non-communicable diseases, which share alcohol consumption as a common, detrimental risk factor1. There is strong evidence on the benefits and value of raising alcohol taxation, part of the “best buys” (cost-effective interventions) recommended by WHO to lower alcohol consumption levels and address one of the major public health challenges of the EU. Taxation allows to decrease affordability of alcohol. Yet, it remains one of the least implemented measures. Recent studies have shown that alcohol remains very affordable in Europe, and that alcohol taxes have been under-utilized as a public health measure2. They have also concluded that implementing a minimum tax share would yield significant health benefits3.

…measure2. They have also concluded that implementing a minimum tax share would yield significant health benefits3. In light of the evidence and detrimental effects of alcohol consumption on health and the economy, the EU should increase minimum excise duties to the highest possible, setting up a harmonized level of tax across Europe for all types of alcoholic beverages. A recent study4 led by the NCD Advisory Council under the new WHO signature initiative has calculated how alcohol tax increase will impact mortality in the WHO European region and provided recommended minimum levels for such a tax. Further, we would like to stress the following points:  The Court of Justice of the European Union judged Minimum Unit Pricing (MUP) to be more effective than comparable measures as it was highly targeted at harmful and extreme drinks and was likely to reduce health inequality.

…comparable measures as it was highly targeted at harmful and extreme drinks and was likely to reduce health inequality. This decision should prompt the EU to be more active in supporting implementation of this tax across Europe, in accordance with WHO recommendations.  The EU should support regular monitoring of the share of excise taxes on the price of alcohol beverages in member states and provide guidance to promote reforms that increase tax share.  Alongside alcohol taxation to increase the price of alcohol products, the EU should stimulate implementation of other alcohol control measures recommended by the WHO as part of the “best-buys”, in particular restricting alcohol availability and banning advertising. In these areas, action needs to be taken urgently in particular to protect Europe’s younger generations. 1 European Commission.

…areas, action needs to be taken urgently in particular to protect Europe’s younger generations. 1 European Commission. Health Promotion and Disease Prevention Knowledge Gateway. Alcohol consumption: effects on health. https://knowledge4policy.ec.europa.eu/health-promotion-knowledge-gateway/alcoholic-beverages_en 2 Neufeld, M., Rovira, P., Ferreira-Borges, C., Kilian, C., Sassi, F., Veryga, A. and Rehm, J., 2022. Impact of introducing a minimum alcohol tax share in retail prices on alcohol-attributable mortality in the WHO European Region: A modelling study. The Lancet Regional Health - Europe, p.100325 3 Idem 4 Idem Ref. Ares(2022)4825603 - 01/07/2022 Raising alcohol taxes should be seen as a major step to save lives and prevent the harm caused by alcohol consumption, which affects multiple age groups and which no member state has been spared from.

…harm caused by alcohol consumption, which affects multiple age groups and which no member state has been spared from. KEY FACTS - Approximately 268,000 deaths and almost 8 million Disability-Adjusted Life Years (years of life lost) attributable to alcohol consumption in the EU in 2019 are related to non-communicable diseases5. Better prevention and control of alcohol consumption would bring significant health, economic and societal benefits; and is integral to managing and reducing the prevalence of major NCDs. - Annually, introducing a minimum tax share of 25% could prevent 40,033 deaths in the WHO European Region. For reference, this level accounts for one third of the WHO-recommended tax share of cigarettes. A 15% tax share with equalization could prevent 132,906 deaths6. 5 European Commission. Health Promotion and Disease Prevention Knowledge Gateway.

…could prevent 132,906 deaths6. 5 European Commission. Health Promotion and Disease Prevention Knowledge Gateway. Alcohol consumption: effects on health. https://knowledge4policy.ec.europa.eu/health-promotion-knowledge-gateway/alcoholic-beverages_en 6 Neufeld, M., Rovira, P., Ferreira-Borges, C., Kilian, C., Sassi, F., Veryga, A. and Rehm, J., 2022. Impact of introducing a minimum alcohol tax share in retail prices on alcohol-attributable mortality in the WHO European Region: A modelling study. The Lancet Regional Health - Europe, p.100325

originalus šaltinis (PDF) ↗