Tobaksindustrien, (Tobacco Manufactures Association of Denmark)
TI
Foreningen blev grundlagt i 1875 .Medlemmer er virksomheder med dansk hovedsæde og produktion.
ID: 27567784437-46
Lobbying Activity
Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union) and Philip Morris International Inc. and
18 May 2022 · Videoconference - Stakeholder event to gather views on the upcoming revision of the tobacco taxation directive
Response to Evaluation of the excise duties applied on manufactured tobacco
6 Mar 2018
Tobaksindustrien represents tobacco manufacturers with headquarters in Denmark. The members of Tobaksindustrien produce niche products such as pipe tobacco, cigars and cigarillos as well as fine cut tobacco and smokeless tobacco and with an unbroken history going back to 1750.
Tobaksindustrien welcomes the opportunity to reflect on the Roadmap.
Tobaksindustrien acknowledges that taxation/excise and tobacco products have a long common history. History, however, including recent experiences shows that structure and level of excise may not only influence public revenue and other legitimate aims currently pursued but may also have an uneven and unintended impact on the various market players.
That is not least true in the current market situation with four big companies and some 230 smaller players predominantly outside the Factory Made Cigarette category.
We therefore welcome observations already made in the study prepared by Economisti Associati and published by the Commission which acknowledges this fact – e.g. by stating on page 189: ”Market impacts would fall disproportionately on smaller companies, including SME, which have a higher share of the FCT than the FMC market…” That is equally true for the other niche categories like pipe tobacco and cigars and cigarillos.
As smaller niche product manufacturers of OTP products, we therefore strongly encourage the Commission to take a profound look at possible disproportionate impacts like the above mentioned in its way forward with the evaluation/Fitness check of the excise directive.
Please do not hesitate to come back if we can be of any help.
Read full responseResponse to Implementing act under Article 16(2) of the Tobacco Products Directive 2014/40/EU
1 Oct 2017
“Tobaksindustrien” (TI) -EU transparency register ID: 27567784437-46- is a trade association for companies with Danish headquarters and production of tobacco products in Denmark. The members produce pipe tobacco, cigars/cigarillos, fine cut and smokeless tobacco - but not factory made cigarettes.
The European tobacco industry consist of around 230 tobacco manufacturers of which 4 manufacturers represent more than 85 % of the tobacco market. The Danish companies belongs to the group of the residual 226 others which in total share less than 15 pct. of the EU tobacco market.
No Danish company holds a market share of above 2%. of the total EU tobacco market and the smallest has less than 25 employees and a turnover of less than 5 million Euro.
We thank the Commission for the opportunity to submit observations to the drafts:
• The draft art 16 fails to accommodate the well-functioning of the internal market for tobacco products as it allows huge national variations and thereby hampering the free flow of goods across the borders.
. Required to have Security features with no less than three types of authentication elements (instead of five) (art 3, Technical Standards for Security Feature)
Read full responseResponse to Delegated act under Article 15(12) of the Tobacco Products Directive 2014/40/EU
1 Oct 2017
“Tobaksindustrien” (TI) -EU transparency register ID: 27567784437-46- is a trade association for companies with Danish headquarters and production of tobacco products in Denmark. The members produce pipe tobacco, cigars/cigarillos, fine cut and smokeless tobacco - but not factory made cigarettes.
The European tobacco industry consist of around 230 tobacco manufacturers of which 4 manufacturers represent more than 85 % of the tobacco market. The Danish companies belongs to the group of the residual 226 others which in total share less than 15 pct. of the EU tobacco market.
No Danish company holds a market share of above 2%. of the total EU tobacco market and the smallest has less than 25 employees and a turnover of less than 5 million Euro.
We thank the Commission for the opportunity to submit observations to the drafts:
we would like to voice our concern regarding the apparent lack of specific rules on interoperability in the drafts.
It is a prerequisite for the workability of the system that total interoperability is obtained and maintained on all levels between all economical operators as well as to/from and between the authorities. We see it as one of the main objectives for the Commission to ensure this timely in the drafts. We were therefore very disappointed when we learned that the Commission has handed this paramount important task over to a yet unknown third party - and with a timeline to March 2019 - and then only for testing purposes. The responsibility to set out standards which ensure interoperability between open standards must rest with the Commission.
Instead of one simple central system used by all stakeholders, the draft suggests a repository system containing both a primary and a secondary repository – the latter with a router. This more complicated set-up, which accommodates that some market players call for individual repositories, adds unnecessary to the costs for Exposed Manufacturers. Therefore, we suggest that they should be exempted from any direct or indirect payment for the formation and running of the secondary repository and router. (art 30.2)
Read full responseResponse to Implementing act under Article 15(11) of the Tobacco Products Directive 2014/40/EU
1 Oct 2017
“Tobaksindustrien” (TI) -EU transparency register ID: 27567784437-46- is a trade association for companies with Danish headquarters and production of tobacco products in Denmark. The members produce pipe tobacco, cigars/cigarillos, fine cut and smokeless tobacco - but not factory made cigarettes.
The European tobacco industry consist of around 230 tobacco manufacturers of which 4 manufacturers represent more than 85 % of the tobacco market. The Danish companies belongs to the group of the residual 226 others which in total share less than 15 pct. of the EU tobacco market.
No Danish company holds a market share of above 2%. of the total EU tobacco market and the smallest has less than 25 employees and a turnover of less than 5 million Euro.
We thank the Commission for the opportunity to submit observations to the drafts:
Please see the attached file .
Main points:
• Where the drafts deviate from a strict reading of art 15 and 16 of the Tobacco Products Directive (2014/40/EU),it should be changed and if not Exposed manufacturers (companies with an individual share of the total EU tobacco market of less than 1.5%) should be granted adequate exemptions. See below for details.
• The drafts fail to secure interoperability between all systems, equipment, economical operators and authorities. Instead, this paramount task is handed over to be dealt with by a yet unknown third party after the formal adoption procedure in the EU and the final issuing of the implementing acts.
• The draft art 16 fails to accommodate the well-functioning of the internal market for tobacco products as it allows huge national variations and thereby hampering the free flow of goods across the borders.
• TI notices with great concern that the drafts seem to introduce novelties and interpretations that go beyond a strict reading of art 15 and 16 of the directive. That includes even a partial implementation of the FCTC Illicit Trade Protocol – regardless of the fact that the Protocol has not even entered into force yet and may very well not do so for a long time.
• Despite the absence of an economic impact assessment for the various OTP sectors (cigars/cigarillos, pipe tobacco and smokeless tobacco), we foresee not only overwhelming costs on an annual basis but also huge one-off start-up costs. The latter not least being due to our high number of production lines where new equipment must be set up. This includes e.g. printers and scanners/readers and not to forget the latest novelty: anti- tampering devises.
• The fact that the Danish companies only produce niche products in smaller volumes illustrates the disproportional impact of the cost .The costs to be borne by the Danish companies can consequently only be spread out on an insignificant number of consumer units. Moreover, indeed an insignificant cost spreading possibility compared to the total “astronomic” number of consumer unites present on the EU market mainly produced by four manufacturers holding a total market share of 85% plus.
Read full response