IOGT International
IOGT International
Our vision is a life for all human beings free to live up to their fullest potential, and free from harm caused by alcohol and other drugs.
ID: 480526426704-18
Lobbying Activity
Response to Evaluation of the CAP measures applicable to the wine sector
7 Dec 2017
As a general comment IOGT International would like to highlight that a public health perspective is missing from the proposed objectives and scope of the evaluation.
SDG 3.5 requires the European Union to strengthen the prevention and treatment of substance abuse, including narcotic drug abuse and harmful use of alcohol.
Obviously, wine is an alcoholic product and thus any CAP measures applicable to the wine sector must show how the EU is made more sustainable as their consequence and how each measure helps promote sustainable development and public health and well-being.
Evidence shows that alcohol is a cross-cutting risk factor, adversely impacting numerous policy areas. For instance, alcohol adversely affects 13 of 17 SDGs .
Therefore any policy that contributes to alcohol harm, directly or indirectly, is counterproductive to the goals of those affected policy areas.
Article 168 of the Treaty for the functioning of the EU states “A high level of human health protection shall be ensured in the definition and implementation of all Union policies and activities.”
In this context, this CAP evaluation relating to the wine sector provides an important opportunity to fulfil the TFEU Article 168 obligation and assess the coherence between public health and CAP wine measures. It is particularly crucial that the public health impact of wine sector measures should be considered in this evaluation because, as an alcoholic product, wine is a health sensitive product.
The CAP is intervening in the wine market, with taxpayers subsidizing alcohol production, this way stimulating overproduction. The EU produces around 158 million hl of wine annually but the average annual consumption is only 124 million hl. The resulting imbalance between demand and supply, facilitates expansion into international markets and consequently alcohol promotion.
Any measures linked to promoting wine is also driving alcohol use and is thus incompatible with the notion of public funds for public goods. This includes promotion activities to “inform consumers about the responsible consumption of wine”. Per European Court of Auditors, promotional measures often constitute hidden operational subsidies to the wine sector, as they replace the alcohol industry’s own promotional activities.
The way and extent to which the CAP is geared to increase wine production, promotion and consequently consumption is fueling a risk factor for human and planetary health, as well as for social and economic development.
For instance the water footprint of wine production is terrible. To get one liter of wine, 870 liters of water are needed. It means that one glass of wine (125ml) costs 110 liters of water . For instance, Garnett showed: "the contribution made by the alcohol sector to the UK’s greenhouse gases is significant at nearly 1.5% of the UK’s emissions total."
In light of all this evidence, IOGT International Key recommendations based on the above rational:
• Reduce overproduction
• Phase-out expensive market intervention measures
• End preferential treatment for the wine sector
• Phase out support for investments, innovations, harvest insurance, mutual funds and by-product distillation
• Stop alcohol promotion
• Include and consult public health and social welfare stakeholders
• Assess the sustainable development (including sustainable consumption, production and health for all) impact of CAP wine sector measures
The specificity of the wine sector should be abolished. Wine is evidently harmful to human and planetary health. European wine producers should not receive preferential treatment and the EU should discontinue the protection of the wine sector. Agricultural policy should be oriented towards supporting the uptake of sustainable healthy diets and lifestyles. Health-harmful subsidies should be removed.
Read full responseResponse to General arrangements for excise duty – harmonisation and simplification
17 Apr 2017
Alcohol harm in Europe
Europe is the heaviest alcohol consuming region in the world. Harms related to the high levels of alcohol use are a heavy burden on public health, social welfare and economic productivity in the European Union. For example, alcohol harm costs €155.8 in the EU every year.
Alcohol harm is pervasive and a heavy burden in Europe:
• Alcohol is the 3rd leading risk factor in Europe for ill health and Noncommunicable diseases (NCDs) such as cancer, diabetes or heart disease.
• 12 million people in the EU are alcohol dependent.
• Around 9 million children in the EU are growing up in homes with parental alcohol problems.
• 1 of 4 road fatalities in EU are alcohol related. In 2010 nearly 31,000 Europeans were killed on the roads of which 25% of deaths were related to alcohol.
• Alcohol is the leading risk factor for ill-health and premature death for the core of the working age population (25 to 59 years of age).
• Alcohol is responsible for 1 in 7 male deaths and 1 in 13 female deaths in the age group of 15 to 64 years, resulting in approximately 120 000 premature deaths.
Alcohol Policy works
Evidence shows that there are alcohol policy best buys that are cost-effective and high-impact in their effects on consumption levels, patterns and associated harm. Especially policy measures decreasing the availability of alcohol and increasing the affordability of alcohol are effective.
Alcohol taxation has been proven to be highly impactful and cost-effective. For instance, when excise duties were reduced in Finland in 2004 this resulted in an increase in alcohol consumption and a substantial increase in deaths from alcohol attributable diseases. Or when the German government introduced a tax on alcopops – lemonade-like sugar-sweetened alcoholic beverages targeting youth – consumption went down, as prices went up.
Comments on context and problem definition (Part A):
IOGT International welcomes that cross-border movement through private acquisition (article 32 of the Directive) is addressed in the problem definition part of the IIA. However, we do regret the tentative approach.
The high and indicative import quotas prevent member states from using their taxation competency to set excise duties according to public health need (a, b). For instance, the application of the high and indicative import quotas to Finland in the mid 2000’s led to excise duty cuts with severe effects on public health (c). There is also a clear link with tax evasion and organised crime. For example, following the application of the article 32 quotas to Sweden in 2004, a report on organised crime by the Swedish police’s intelligence agency KUT in 2005 (d) concluded that “instead of smuggling in large quantities of alcohol, thousands of litres, the criminal groups are now on a large scale bringing in legal travel rations and store these in depots”.
IOGT International therefore strongly recommends the European Commission to include the high indicative levels in article 32 as an already defined problem in part A of the Impact Assessment.
Comments on objectives and policy options (Part B)
Article 168 of the TFEU mandates the European Commission that “A high level of human health protection shall be ensured in the definition and implementation of all Union policies and activities.” Therefore, IOGT International calls for an evaluation of the effects on public health of any proposed measures under this revision. Particular assessment is required for any measure that may lead to a reduction in the market price of alcohol, and with it to an increase of alcohol consumption and related harms.
IOGT International recommends the EC to extend public health considerations to apply to all objectives identified and not only to the “fight against fraud and tax evasion”.
This is specifically the case for the objective to “reduce administrative burden and costs for economic operators”. Reducing the administrative burden and costs...
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