IOGT-NTO
IOGT-NTO is one of Sweden's leading non-governmental organisations working to reduce alcohol consumption and related harm.
Lobbying Activity
Movendi Sweden urges tougher EU rules on influencer alcohol ads
8 Dec 2025
Message — The group wants influencers treated as media actors subject to strict advertising rules. They advocate for consistent safeguards across all platforms to protect minors from harmful content.12
Why — Stricter regulations would help these organizations achieve their mission of reducing consumption.3
Impact — Alcohol producers and digital influencers would face restricted access to young audiences.4
Meeting with Hanna Gedin (Member of the European Parliament)
16 Nov 2025 · Women and Addiction
Meeting with Alice Teodorescu Måwe (Member of the European Parliament)
28 Oct 2025 · Folkhälsa
IOGT-NTO urges EU to target alcohol in health plan
27 Aug 2025
Topic — The European Commission is developing a plan to combat cardiovascular diseases across the EU.
Message — The organization urges the EU to recognize alcohol as a major causal factor for cardiovascular diseases. They propose embedding WHO-recommended measures like taxation and marketing regulation while supporting mandatory labelling.123
Why — These measures would help the group achieve lasting change by reducing total alcohol consumption.4
Impact — Alcohol companies would face reduced sales and higher costs from stricter marketing and taxation.5
Meeting with Esther Herranz García (Member of the European Parliament, Rapporteur)
21 May 2025 · Wine Package
Meeting with Alice Teodorescu Måwe (Member of the European Parliament)
4 Oct 2024 · Folkhälsa
Meeting with Pär Holmgren (Member of the European Parliament)
2 Oct 2024 · Health and Alcohol policy
Meeting with Karin Karlsbro (Member of the European Parliament)
9 Sept 2024 · Prioriteringar inför ny mandatperiod
Meeting with Malin Björk (Member of the European Parliament)
9 Jan 2024 · Alcohol and Mental Health
Meeting with Malin Björk (Member of the European Parliament)
13 Oct 2023 · NCD- report
Meeting with Heléne Fritzon (Member of the European Parliament)
6 Sept 2023 · Möte med IOGT-NTO (APA level)
IOGT-NTO urges alcohol prevention focus in EU mental health strategy
15 Feb 2023
Message — IOGT-NTO calls for the EU to recognize the link between alcohol and mental illness. They advocate for implementing evidence-based alcohol policies and educating health services on alcohol as a risk factor.123
Why — A comprehensive EU strategy would advance their primary goal of reducing total alcohol consumption.4
Impact — Alcoholic beverage manufacturers could see declining profits from more restrictive marketing and pricing regulations.5
Meeting with Heléne Fritzon (Member of the European Parliament)
1 Dec 2022 · Möte med IOGT-NTO
Meeting with David Lega (Member of the European Parliament)
21 Jun 2022 · EU policy on health and alcohol
Meeting with Jytte Guteland (Member of the European Parliament)
20 Jun 2022 · Alkoholpolitik
Response to Revision of Food Information to Consumers for what concerns labelling rules on alcoholic beverages
9 Jul 2021
IOGT-NTO welcome the revision of rules on information provided to consumers for alcoholic beverages and hope that it can lead to more standardised and complete labelling requirements of alcoholic beverages in the EU.
Further IOGT-NTO welcome the Inception Impact Assessment and support the overarching objective of the revision - to strengthen informed choices among citizens and decrease alcohol-related harm.
IOGT-NTO generally support option 2 in the Inception Impact Assessment.
IOGT-NTO are critical of the current self-regulatory approach to labelling and believe that the labelling schemes presented by the industry both were highly unsatisfactory from a public health perspective as well as incoherent between beverages. IOGT-NTO hope that the revision will bring about new labelling requirements for alcoholic beverages that lives up the same high standard as the products regulated under the FIC regulation do.
IOGT-NTO therefore believe that the starting point for the revision should be to revoke the exemption from the FIC for alcoholic beverages as there are no justifiable reasons why alcoholic beverages are exempted from the FIC. The minimum ambition for the revision should be to implement the same labelling scheme for alcoholic beverages that exists for alcohol-free beverages today.
Additionally, IOGT-NTO are firmly against any revision that would allow for some information being declared off-label. Allowing for the industry to present information online rather than on the label is first in direct opposition of the overarching aim of the revision, namely to strengthen consumer information and public health. Secondly, by allowing the alcohol industry to provide information off-label would set a dangerous precedence among foodstuffs and beverages that many other sectors might want to follow, as has been pointed out by several actors before. Lastly, as earlier mentioned, there are no justifiable reasons, benefit or other added values for citizens, an off-label system would bring compared to the on-label requirements established in the FIC regulation for other foodstuff and beverages.
IOGT-NTO also note with concern the recent meetings and collaboration on labelling between the Commission and the brewing sector in the new Farm to fork Code of Conduct pledge project. It is adamant that current labelling efforts as well as potential new requirements for the industry are not presented as goodwill from the industry. The exemption the alcohol industry currently possesses in the FIC have led to less consumer information and choice and increased health risks for citizens. For this reason, it is highly inappropriate to celebrate the alcohol industry for moving towards the same standards as other foodstuff and beverages already adhere to.
Finally, IOGT-NTO want to highlight the importance that the revision process, and the upcoming impact assessment, is based on labelling best practices with a citizen and public health perspective in the forefront. Alcohol is no ordinary commodity, but rather a psychoactive substance that has a significant impact on the European health burden. Alcohol, according to the WHO, is the cause of 10 % of all deaths in Europe, 28 % due to alcohol-related cancers. Because of the negative effect alcohol has on public health, and the societal costs that the substance causes, alcoholic beverages should legally, be holistically held to higher standards and stricter requirements compared to other beverages. In labelling requirements, the opposite is unfortunately true today.
Better labelling requirements are likely to strengthen consumer knowledge and will, in the long term, benefit public health by reducing both alcohol-related harm as well as obesity. Therefore IOGT-NTO welcomes this revision and hope that it can correct the previous unwarranted exemption.
Read full responseResponse to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services
31 Mar 2021
The Digital Services Act, public health and prevention of alcohol-related harm
The digital era brings with itself both opportunities but also new challenges to the EU and its Member States. Therefore IOGT-NTO welcome the new Digital Services Act (DSA) and hope that it will set a new legislative standard for the digital landscape.
For IOGT-NTO it is central that the DSA ensure clear and effective legislation on illegal content. Having clear definitions of what illegal content is greatly improves the possibilities to swiftly enforce rules and remove illegal content. This is especially relevant in alcohol marketing were current rules, especially the ambiguities that exists in the origin-rules in the e-commerce Directive, hinders effective implementation.
Comments on the Commission proposal:
• IOGT-NTO welcome that the Commission proposes a quicker procedure for addressing illegal content, this should aid in addressing the problem of online alcohol marketing directed towards jurisdictions where this is not allowed. IOGT-NTO also wants to highlight the importance that these procedures are practically swift when they are implemented in practice. This is especially important to tackle illegal advertising which can have a short run-time.
• IOGT-NTO wants to stress the importance that the definition of illegal content remains irrespective of country of origin. This is key to address the issues arising from the unclear origin-rules in the e-commerce Directive.
Read full response9 Mar 2021
IOGT-NTO is the largest temperance organisation in Sweden. It is also one of the country's oldest NGOs with a long tradition of cultural, social and educational efforts in local communities. IOGT-NTO has long-standing expertise on questions of reducing alcohol-related harm.
IOGT-NTO welcomes the review and hope that it will be an important step to ensure that the future of agricultural promotion policy is aligned with overall EU priorities, such as the Health in all policies and the Farm to Fork strategy, and that the policy is used to endorse and strengthen the general transition towards healthier diets.
Generally, it is essential that the EU, in its internal and external agricultural promotion policies, take into account and assess the public health effects the promoted products causes, and that this public health perspective encompasses all fields of agricultural promotion policy.
In light of recent policy developments in the EU, especially the Europe´s Beating Cancer Plan, IOGT-NTO acknowledges that the current promotion policy of agricultural products needs modernisation since it is not in line with present EU priorities. This is specifically true in the field of alcohol and alcoholic beverages.
Firstly, it sends a contradicting message to subsidise the marketing of alcoholic beverages in the promotion programme on the one hand, and have an overarching goal to promote a healthier way of life on the other. Both the Europe’s Beating Cancer Plan, the European Code Against Cancer and the UN SDG’s acknowledges the hurdle alcohol poses for a healthier and more sustainable future. As such, they all stress the need to reduce alcohol consumption to reach these goals.
Secondly, the inclusion of alcohol in the promotion schemes are in direct opposition to the “WHO Best Buys” on effective measures against alcohol-related harm. The best buys state that restricting advertisement is one of the most effective measures to reduce alcohol consumption and alcohol-related harm. Further, the wine industry, worryingly, uses the promotional funds to advertise through social media channels, a medium that do not differentiate between adolescents and adults, exposing children and youth to alcohol advertisement. As proven, the earlier you start consuming alcohol, the worse the long-term health effects are.
Lastly, barring the public health perspective, audits done by the European Court of Auditors has criticized the efficiency of the wine promotion schemes in both the CAP and the promotion programme and has stated that the programmes lack demonstrable results.
In conclusion, with the significant and widespread negative public health effects alcohol has, it is unjustifiable from a health perspective to use the EU promotional funds to promote alcoholic beverages. IOGT-NTO therefore wants to see all alcoholic beverages exempted from the promotional funds.
IOGT-NTO calls for:
1. An exemption of all alcoholic beverages from the promotion programme because of their far-reaching negative effects on public health.
2. That products with a geographical indication (GI) no longer should be considered priority products.
Read full responseResponse to Cross-border acquisitions of excise goods by private individuals
3 Jan 2021
IOGT-NTO welcomes the timely review of the tax arrangements for travellers' purchases of alcohol and tobacco. The issues associated with the current rules are well known, not least in Sweden, and have been given additional relevance by the pandemic.
The revision of tax arrangements for cross-border purchases of alcohol and tobacco represent a key action needed to ensure that European legislation is fit-for-purpose. There is room to more effectively combat alcohol and tobacco tax evasion and avoidance and to better support Member States seeking a high level of public health protection. These objectives have been given additional relevance by the pandemic, highlighting the dual to need reduce pressure on healthcare services and fund crisis measures.
IOGT-NTO believes the Inception Impact Assessment (IIA) correctly identifies the main problems with the current excise duty rules. Distortion of public revenue, excise fraud and negative pressure on excise duties all contribute to worsening public health outcomes. Revising these rules is therefore a win-win-win situation for the European Union: It will improve health outcomes, strengthen many national budgets and help combat organised crime and fraud.
Comments on the inception impact assessment:
• IOGT-NTO notes that the COVID-19 pandemic has brought attention to the fiscal and health distortion caused by cross-border purchases of alcohol and tobacco. Sweden, during the period of closed borders, noted a sharp increase in excise duty income for spirits (1) , the beverage type with the largest share of cross-border purchasing, whilst consumption data indicates that total consumption of alcohol has fallen overall (2). Similar patterns, for tobacco, have been noted in France (3).
• IOGT-NTO welcomes that the initiative connects to Europe's Beating Cancer Plan. Alcohol and tobacco taxation are some of the most effective policy instruments for reducing alcohol/tobacco consumption and thereby the prevalence of alcohol/tobacco related cancers.
• IOGT-NTO further notes the importance of directly including health perspectives in the review given that it concerns a tax issue with a direct impact on health outcomes.
• IOGT-NTO notes that the IIA correctly recognises that quantitative limits are already in place for cross-border purchases of fuels (mineral oils). That system appears as both proportional, generally well-functioning and easy for citizens to understand. Many countries have also expressed a desire for similar rules to apply to alcohol and tobacco.
Comments on the policy options
• IOGT-NTO support the main policy changes identified in the IIA and believe that these pose a suitable starting point for the process going forward.
• IOGT-NTO stresses the importance that a change of guide levels to concrete and easily enforceable quantitative limits is included within the scope of the policy option “revised and adjust the guide levels”.
• IOGT-NTO highlights the importance that different combinations of the identified policy options are considered. This because the issues with the current rules are multi-layered and challenges differ slightly between countries. As such, the best final policy option is most likely a combination of different policy changes.
• IOGT-NTO emphasises the need to take enforcement into account when looking into the proportionality of policy options. Easily enforceable rules contribute to adherence, reduced legal fragmentation and reduced administrative burdens. It is therefore possible for restrictive rules to be more proportional than targeted ones, if the targeted rules are difficult to enforce.
(1) https://www.esv.se/statens-ekonomi/prognos-och-utfall/utfall-for-statens-budget/manadsutfallet-i-excel/
(2) https://www.can.se/app/uploads/2020/06/effekter-av-coronapandemin-preliminara-uppgifter.pdf
(3) https://www.ofdt.fr/publications/collections/periodiques/lettre-tendances/les-addictions-en-france-au-temps-du-confinement/
Read full responseResponse to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services
30 Jun 2020
IOGT-NTO is the largest temperance organisation in Sweden. It is also one of the country's oldest NGOs with a long tradition of cultural, social and educational efforts in local communities. IOGT-NTO has long-standing expertise on questions of alcohol marketing.
IOGT-NTO's detailed feedback to the Roadmap/IIA attached.
Summary of main points:
- IOGT-NTO notes the right of countries to adopt public health-based legislation in the field of advertising, and stresses the fact that many Member States actively use this right. For alcohol advertising, countries as diverse as Sweden, Lithuania, France, Finland, Poland, Slovenia and Estonia have chosen to restrict alcohol advertising online in different ways or forms. More Member States are working to bring alcohol advertising regulation for new media (online) in line with that applicable to traditional media (cinema, TV, newspapers, etc.).
- IOGT-NTO notes that public health outcomes are as dependent on the measures adopted as on the ability of authorities to effectively enforce those measures. The importance of enforcement is also acknowledged by the Council conclusions on cross-border aspects in alcohol policy — tackling the harmful use of alcohol (2017/C 441/04).
- IOGT-NTO notes the important role the DSA could play in creating an effective online governance regime for cross-border advertising in general, and alcohol advertising in particular.
- IOGT-NTO highlights the uncertainties surrounding the application of the e-commerce Directive to online advertising, brought to the fore by a number of ongoing court cases in Sweden. At the core lies the question of which rules apply for digital marketing: The rules in the company’s home country or those of the country whose territory is targeted by the company’s ad?
- IOGT-NTO would like to stress that this uncertainty is harmful to public health and risks fragmentation of the Single Market:
targets.
- IOGT-NTO notes that the question of jurisdiction of advertising, and current uncertainties surrounding it, would risk undermining the effectiveness of new enforcement systems implemented for dealing with, for example, illegal content online.
- IOGT-NTO stresses that self-regulation cannot be relied upon to solve this issue, as self-regulation in the field of alcohol marketing has consistently proven inadequate in achieving an acceptable level of protection for children, young people and other vulnerable populations.
- In view of the above, IOGT-NTO believes the Roadmap/IIA and ultimately the DSA, when it comes to enforcement of advertising legislation, need to address the uncertainties stemming from the e-commerce Directive.
- IOGT-NTO is certain that it is possible to find a solution that combines all Member States’ legitimate desire to afford the best protection possible for their citizens, according to national and cultural needs, with the Commission’s continued desire to apply the country of origin principle as a general rule in the Directive.
o At the core such a solution should seek to ensure that Member States can uphold and effectively enforce national public health measures on advertising targeting their territory.
- IOGT-NTO would also stress the general need for the Directive to prioritise policy options that ensure robust oversight and enforcement mechanisms, transparency of online advertising, as well as strengthening cooperation with consumer organisation and other civil society organisations involved in monitoring and enforcement of rules online.
Read full responseResponse to Europe’s Beating Cancer Plan
2 Mar 2020
IOGT-NTO is the largest temperance organisation in Sweden. It is also one of the country’s oldest NGOs with a long tradition of cultural, social and educational efforts in local communities. IOGT-NTO has extensive experience of working on alcohol policy questions, which includes awareness-raising about the connection between alcohol and fatal cancers.
IOGT-NTO notes the strong international evidence supporting the causal link between the consumption of alcohol and several types of cancer. As the second largest risk factor for cancer in the EU overall, and the largest risk factor for specific cancers such as breast cancer, it is clear that alcohol needs to be clearly addressed in Europe’s Beating Cancer Plan. Alcohol is a commodity that is directly impacted by many existing EU Directives and Regulations, further increasing the need to address alcohol in Europe’s Beating Cancer Plan.
Comments on context and problem definition (Part A):
- IOGT-NTO strongly supports the statement in the background section of roadmap: “prevention is the easiest and most effective way of reducing cancer”. The focus developing Beating Cancer Plan and the end-product should reflect this unambiguous insight.
- IOGT-NTO encourages the Commission to adopt a population-level approach to risk factors of cancer such as alcohol, tobacco and unhealthy foods. Population-level approaches are also those recognised as most effective by the World Health Organisation (1)
Comments on what the initiative aims to achieve and how (Part B)
- IOGT-NTO strongly supports the recognition, as part of the objectives, of the need to reduce alcohol consumption in order to prevent alcohol-related cancers.
- IOGT-NTO fully support taxation being recognised as a key instrument to cancer prevention.
- IOGT-NTO would like to specifically highlight EU taxation arrangements for cross-border movements of alcohol and tobacco by travellers. There is strong evidence that current EU rules undermine the effectiveness of taxation as a national policy instrument in preventing cancer and raising funds for cancer treatment.
- IOGT-NTO would like to highlight that EU-level rules do not allow for national alcohol excise duties for several categories of alcoholic beverages to be determined by alcohol content. This is incongruent with a cancer prevention perspective as the alcohol content is directly correlated with risk.
- IOGT-NTO would like to point out that, other than pricing, the two most effective instruments (2) for reducing alcohol and tobacco attributable cancers are missing: action on marketing and availability of alcohol. Cross-border marketing of alcohol, both on TV and online, is directly impacted by EU legislation.
- IOGT-NTO would also like to see action on increasing the general knowledge about the connection between alcohol and cancer, for example through the allocation of funding for national awareness-raising campaigns.
Comments on Better Regulation (Part C)
- IOGT-NTO greatly welcomes the consultation process launched by the Commission.
- IOGT-NTO would like to stress the need to consider the obligations of the EU under the FCTC should actors linked to the tobacco industry try and participate in the consultation process. There are also strong grounds to adopt a similar approach when it comes to the alcohol industry. There are examples of actors linked with the alcohol industry trying to undermine, delay or prevent initiatives seeking to reduce the prevalence of alcohol attributable cancers.
- IOGT-NTO would like to stress the need to include organisations from the broad public health community in the targeted stakeholder consultations. This should include European and national actors with expertise on the main modifiable risk factors of cancer, such as tobacco and alcohol.
(1) (2) The WHO ‘best buys’ contain a collection of evidence-based, ‘best practice’ policies to tackle the main risk factors for NCDs through the creation of health-enabling living environments.
Read full responseResponse to More efficient law-making in taxation: a move to QMV
17 Jan 2019
IOGT-NTO appreciates the possibility to provide feedback to this Roadmap.
IOGT-NTO is not taking a position on the larger question of opening up for Quality Majority Voting (QMV) on certain tax matters, but wants to point out potential implications this might have for national public health policy-making, notably alcohol excise policy.
Some Member States have opted for a high level of human health protection through high excise duty levels on for example alcohol and tobacco. Excise duties both serve to reduce harm by reducing consumption of health harmful goods and by providing funding for healthcare and public health interventions. With excise duty thus functioning as a health instrument, public health becomes affected by a move to QMV.
The Commission Communication on the topic released on 15 January mentions very low alcohol and tobacco excise rates as a problem that a move away from unanimity could help alleviate. It also mentions increasing the efficiency of public health oriented tax policy-making. However, IOGT-NTO would also like to point towards risks arising from a move to QMV.
For example, there is a risk that a move from unanimity to QMV means Member States could find themselves having to implement rules that undermine their power to maintain high-excise duty levels and thus a high level of public health protection. A proxy for such a situation can be found in the rules on cross-border purchases of alcohol and tobacco. Public health in a number of high-excise Member States is undermined by these rules, which are not suitable for their national circumstances and were adopted before the Member States’ entry in the EU.
IOGT-NTO hopes the Commission will take the above matter into consideration in the analysis of the effects of an introduction of QMV in taxation. Any future proposal should be able to respond to how the power of front-runner Member States to implement and maintain ambitious public health oriented taxation policies will be safeguarded, even if there is a qualified majority seeking to undermine that power.
Read full responseResponse to Evaluation of the CAP measures applicable to the wine sector
7 Dec 2017
IOGT-NTO is the largest temperance organisation in Sweden. It is also one of the country's oldest NGOs with a long tradition of cultural, social and educational efforts in local communities.
IOGT-NTO welcomes the review of the CAP measures applicable to the wine sector and appreciates the possibility to give feedback on the evaluation and fitness check roadmap.
IOGT-NTO would like to stress that wine, as an alcoholic beverage, is not an ordinary commodity. This sets wine apart from other products covered by the CAP. This is because of alcohol’s negative impact on individual health and risk of premature death, Member States’ budgets through increased judicial and health expenditure as well as children and relatives who suffer from the alcohol consumption of people close to them. For example, alcohol is the biggest risk factor – above smoking – in the overall burden of disease for people aged 15 to 49 and the WHO has concluded that there are no safe levels of alcohol consumption with regard to health.
The EU Treaty for the functioning of the EU requires that “A high level of human health protection shall be ensured in the definition and implementation of all Union policies and activities.” Likewise, the Sustainable Development Goals require the EU to take active measures to improve health, and specifically, take action to reduce alcohol related harm. It is therefore vital that health concerns figure prominently in the evaluation at hand.
With regard to this, IOGT-NTO would like to echo the points raised by EPHA and Eurocare in their feedback.
Purpose and scope:
– The evaluation should analyse the use of public funds that have been spent under the Common Market Organisation article 39 and to what extent this funding, in particular for vineyard restructuring and wine promotion, is consistent with the aims pursued under Article 168 TFEU.
– Following the 2014 European Court of Auditors warning that CAP support to the wine sector leads to administrative burdens and that the promotional element often constitutes a hidden operational subsidy for wine [ECA, 2014, http://bit.ly/2n1QSPP], it is important to evaluate the impact and the market orientation of funds for wine. Specifically, the evaluation should include a detailed assessment of the usage of promotional funds.
– In evaluating the added value of the measures, the Commission should include a consideration of the external costs of increased or subsidised alcohol production i.e. including the consumption part of the product chain, e.g. healthcare costs related to alcohol use and alcohol harm, rather than simply the impacts upon production.
– As part of the fitness check, the relationship between the national allocation of CAP promotion funds for wine outside the EU and consumption trends in those countries should be investigated. The links between this funding and alcohol harm and the incidence of non-communicable diseases (NCDs) related to alcohol consumption in these countries should also be analysed.
– Lastly, the scope should include the evaluation of hypothetical measures to support farmers to diversify their production away from wine in order to tackle oversupply. The evaluation should cover the impacts this would have on farmer’s income, productivity, product quality and public health, in comparison with current measures.
Consultation:
– As part of the consultation, public health actors should be directly consulted, as well as being included via Civil Dialogue Groups and an online public consultation.
– The Commission’s online consultation should include questions on how the CAP’s wine sector measures have contributed to EU health goals, including the Sustainable Development Goals and the fulfilment of EU treaty provisions (e.g. SDG 3 and art.168)
– Finally, the public consultation should include questions on the public health effects of the relevant measures and not focus only on practical experiences of their implementation.
Read full responseResponse to General arrangements for excise duty – harmonisation and simplification
12 Apr 2017
IOGT-NTO welcomes the review of Directive 2008/118/EC and the opportunity to provide feedback to this Inception Impact Assessment (IIA). You will find our comments below and references (a, b, c) in the attached annex.
Comments on context and problem definition (Part A):
1. IOGT-NTO welcomes that cross-border movement through private acquisition (article 32 of the Directive) is brought up in the problem definition part of the IIA but regrets 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 example, the entry into force of the quotas in Finland 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 instance, following the entry into force of the quotas in Sweden in 2004, a report on organised crime by the Swedish police’s intelligence agency KUT in 2005 (d) concludes 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-NTO thus encourages the EC 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):
2. IOGT-NTO 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 contributes to lower prices of goods harmful to health across Europe. It also has a specific public health concern in member states and associated countries with alcohol retail monopolies. Alcohol retail monopolies are justified under EU law (Franzén C-189/95) but favourable conditions for cross-border B2C online alcohol sales would undermine the monopolies’ legal legitimacy (see reasoning in Sjöberg & Gerdin C-447/08) through establishing online B2C as a new retail channel.
Comments on expected impacts (Part C):
3. IOGT-NTO finds it highly unlikely that there will be no social impacts of the policy changes evaluated, especially as the IIA identifies reduced costs for economic operators as a likely economic impact of policy change. A likely social impact of the automation of the movements of excise goods is thus increased consumption of harmful products. This would come about through lower prices and increased accessibility of such goods across Europe, and specifically in the Nordic countries if alcohol retail monopolies are undermined.
Comments on the data collection and consultation strategy (Part D):
4. IOGT-NTO stresses that there is already enough evidence to motivate the analysis of the impact on tax evasion, fraud, organised crime and public health of the import quotas in the rules concerning private acquisition by individuals (article 32).
5. IOGT-NTO welcomes point (i) and (ii) in the IIA on the need to respect different institutional setups for excisable goods and looking at potential unintentional effect on public health of policy changes. IOGT-NTO finds it crucial that these considerations are present throughout the EC’s work on the Directive.
6. We regret that no public health stakeholder was consulted in the 2015 evaluations laying the foundation for this IIA (e, f). Although IOGT-NTO welcomes that the consultation now also includes public health authorities, we regret that the EC still has not identified ‘NGOs active in the health area’ as a relevant stakeholder. This is already done in the IIA concerning Directive 92/83/EEC and we see no reason for why the stakeholders of these Directives should differ. IOGT-NTO thereby hopes that this omission will be rectified moving forward.
Read full responseResponse to General arrangements for excise duty – adaptation to the Union Customs Code
28 Mar 2017
IOGT-NTO welcomes the review of Directive 2008/118/EC and the opportunity to provide feedback to the EC roadmap. Whilst our feedback for the specific process on adapting the Directive to the Union Customs Code is sparse, we nonetheless have some comments on the content and context of the roadmap at large.
General comments:
1. Excise duty is a key tool for member states to influence the price of goods detrimental to public health, such as alcohol or tobacco. Higher costs mean higher prices and higher prices mean lower consumption. Reductions in consumption and consequently improved public health is correlated with much larger fiscal gains for society than the up-front excise duty receipts indicate. With regard to this roadmap, it is important that the administrative/compliance costs arising from excise duty payments are not considered as unintended externalities, but as effects with a positive public health impact in that they serve to make harmful goods more expensive.
2. Seeing that a representative of the tobacco industry has provided feedback on this roadmap, IOGT-NTO would like to remind the Commission of article 5(3) in the WHO Framework Convention on Tobacco Control: “Parties shall act to protect these [public health] policies from commercial and other vested interests of the tobacco industry”. Excise duty arrangements are public health policy, as highlighted in the point above. The same reasoning can be applied to producers of alcoholic beverages, a product comparable to tobacco in terms of social harm (Anderson, P. & Baumberg, B. (2006) Alcohol in Europe. London: Institute of Alcohol Studies. Page 2). IOGT-NTO would thus encourage the Commission, when analysing the feedback, to not disregard the fact that the economic operators have an undisputable monetary interest in increasing their product sales despite detrimental effects on public health.
Comments concerning the announcement of a “profound review of the Directive” due end 2017:
3. The application of the indicative levels of alcohol that can be taken across border without paying excise duty (article 32 in the concerned Directive) to Sweden in 2004 had profound effects on enabling fraud and abuse. As noted in a report on organised crime by the Swedish police’s intelligence agency KUT in 2005 “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”. Members of the Nordic Council have already called on these levels to be reduced and made absolute (as opposed to indicative). IOGT-NTO thereby strongly recommends that the profound review considers revising article 32 of the Directive in this way.
4. IOGT-NTO recommends the EC to take the specific public health concerns in member states and associated countries with alcohol monopolies into account in the profound review of Directive 2008/118/EC, particularly when reviewing “administrative burdens” and “process efficiency” in the context of cross-border B2C sales. Alcohol retail monopolies are justified under EU law (Franzén C-189/95) but favourable conditions for cross-border B2C online alcohol sales would reduce the monopolies market share by establishing a new retail channel. This would undermine the monopolies’ legal legitimacy (see reasoning in Sjöberg & Gerdin C-447/08) and consequently severely affect public health in the countries concerned.
5. There is a lack of public health considerations in the 2015 evaluations laying the foundation of this roadmap. The main stakeholders consulted in the evaluations are limited to tax authorities, consumer organisations and economic operators. IOGT-NTO would thus urge the Commission to consider the impacts on public health and further consult public health NGOs and government public health authorities when formulating the profound review’s proposals.
Read full response