IOGT-NTO welcomes the review of Directive 92/83/EEC and the opportunity to provide feedback to the Inception Impact Assessment (IIA). IOGT-NTO has several comments regarding the EC’s understanding of the problems linked with the Directive as well as the objectives and policy options to be examined.
The EC’s understanding of the problem (Part A):
1. The IIA identifies several problems linked to the product categories as defined by the Directive, but forgets the public health aspect. The division into product categories allows member states to set excise duties that to some extent progressively follow actual alcohol content between product categories (and thereby also follow harm to public health). However, the Directive is very constraining within specifically the ‘wine’ category, where the vast majority of wine produced is taxed by hectolitre and not hectolitre/degree of alcohol. This problem is not captured by the existing formulations in the IIA regarding reduced rates for alcoholic beverages below a certain alcoholic strength. This problem was also raised by member state authorities, consumers and medical professional associations in the EC’s evaluation of the Directive (pages 120-121).
2. The IIA should make clear in the problem section that the reason for which alcohol is denatured is to prevent recreational consumption. One of the public health issues under current arrangements is thus that many denaturing formulas co-exist and not all of them provide an adequate protection against reconversion to potable alcohol.
3. With regard to the potential to offer reduced rates for small producers, the IIA raises that some countries want to extend this to also cover wine producers. IOGT-NTO would like to add that from public health point of view, even the existing possibilities for reduction for breweries and distilleries are an issue. These reductions may contribute to lowering the price of alcoholic beverages and consequently increase consumption to the detriment of public health. The pertinence of this issue is reinforced by the market trend towards small producers as raised in the IIA. In addition to the public health perspective, today’s exemptions and reductions creates additional levels of bureaucracy and result in a patchwork of different rules across the single market.
EC’s objectives and policy options (Part B):
4. IOGT-NTO welcomes that the EC lists public health (Article 168 TFEU) as an overarching objective in the IIA. However, it needs to be highlighted that the critique made on public health grounds from member state authorities, consumers and medical associations in the evaluation of the Directive (pages 120-121) is not adequately addressed in this document. The option of leaving the product category approach in favour of an excise system based on the progressive taxation of alcohol content is not brought up. Not even the possibility of linking excise duties more closely with alcohol content within the wine category is considered. IOGT-NTO stresses the need to consider these two policy options.
5. IOGT-NTO is critical towards the fact that the only policy option considered with regards to reduced rates for small producers is a revision across all sectors. It would be wiser to assess the policy option of removing reduced rates from all sectors and producers currently covered. This would be in line with the responses from member state authorities in the evaluation of the Directive (pages 120-121) and the stated objective to ensure a high level of human health protection. In addition to the positive public health effects, such an option would simplify existing legislation and improve enforcement.
IOGT-NTO welcomes the fact that public health authorities and NGOs will be consulted further and looks forward to participating in the forthcoming consultation.
The views and opinions expressed here are entirely those of the author(s) and do not reflect the official opinion of the European Commission. The Commission cannot guarantee the accuracy of the information contained in them. Neither the Commission, nor any person acting on the Commission’s behalf, may be held responsible for the content or the information posted here. Views and opinions that violate the Commission’s feedback rules will be removed from the site.