Back in June, the European Tobacco Harm Reduction Associates (ETHRA) called for both a zero minimum and a maximum tax rate in its submission to the public consultation (1).
Part of the submission stated:
- Non-combustion - low or zero tax to incentivise switching. Because they are much less risky and substitute for combustion products to create a health benefit, the vaping and other non-combustible products should attract a much lower or zero rate of excise duty. At the very least, this pro-public health option should not be prevented by a revised directive by permitting a zero minimum tax rate for all non-combustible products.
- Maximum smoke-free tax threshold. As well as setting a minimum level for non-combustibles at zero and encouraging a steep fiscal gradient between smoked and smoke-free products, there should be some protection of this gradient across the EU by setting a maximum tax level for the four classes of non-combustibles at a level equivalent to half [or other fraction] of the lowest level set combustible products.
The summary report (2) of the contributions to the Tobacco Tax Directive consultation has now been published and ETHRA says, “interestingly, the majority of stakeholders were in favour of differential taxation.”
The report states: “The prevailing view among all categories of stakeholders was that an EU minima for heated tobacco products should be set at the same level as fine cut tobacco and that e-cigarettes should be taxed at the lower proposed levels (EUR 0.10 per ml) or according to consumers themselves at a zero minimum rate.”
For those interested, ETHRA adds: “The raw data from the consultation is also available. An excel file is available to download which contains all the responses to the questionnaire, the file is named ‘Revision tobacco directive- results clean 9-9-21’. ETHRA's contribution [can be found on] line 175 in the excel sheet, this entry has a code a related code in column AV (1c6f155b-2dd9-411b-8a39-bcbf51472321). To access any attachments associated with a contribution you must look for a folder with the corresponding code in the Zip file, which is named ‘Position paper-tobacco products2021-TTD’.”
Most of the responses to the consultation came from France (26%). Greece contributed 23% of the responses with the rest shared out among 25 other member nations and non-EU countries.
Of the responses:
- 55% were submitted by businesses
- 10% were submitted by trade organisations
- 8% were submitted by academic organisations
- 7% were submitted by NGOs
- 2% were submitted by consumer groups
The report concludes: “The current EU rules are being reviewed to ensure that they remain fit for purpose to ensure the proper functioning of the internal market and at the same time a high-level of health protection.
“This is particularly important in the context of the EU’s beating cancer plan, as taxation plays a pivotal role in reducing tobacco consumption, in particular in deterring youth from smoking.”
- ETHRA’s submission to the Public Consultation on Tobacco Taxation - https://ethra.co/images/ETHRA_Tobacco_Tax_consultation_submission.pdf
- The Summary Report - https://circabc.europa.eu/ui/group/fc89cf69-90c4-4f4a-8e2f-e08d0aae768d/library/54208786-ea50-4d46-a265-3786bd7dc471/details