Mr. Commissioner for Economic and Financial Affairs, Taxation and Customs CC: Dr. Vytenis Andriukaitis Commissioner for Public Health and Food Safety B - 1049 Brussels

Brussels, 4 September 2018

Dear Commissioner Moscovici,

Re: Request for a meeting regarding the future revision of Directive 2011/64/EU on the structure and rates of excise duty applied to manufactured tobacco

We are writing on behalf of the SFP Coalition, representing over 40 organisations working in tobacco control and public health at EU and national level, to request a meeting with you to discuss how we could best support you with respect to the on-going revision of the Tobacco Tax Directive 2011/64/EU on the structure and rates of excise duty applied to manufactured tobacco.

First, we would like to take this opportunity to congratulate you on your decades-long commitment to serve the public interest. Because of this, we are confident that you will be a strong advocate for the implementation of the Framework Convention on tobacco control (FCTC) and specifically for Article 6 (tobacco taxation) and its guidelines, which were developed to help Parties to reduce the demand for tobacco.

We welcome the public consultation on the possible revision of the Tobacco Tax Directive and its renewed focus on evaluating the excise duty rates. The tobacco control community has long recognised that increasing tobacco excise duties is crucial to reducing smoking levels, particularly amongst young people. Price policies are known to be the single most effective means for reducing the demand and consumption of tobacco products particularly amongst young people, as part of a comprehensive tobacco-control strategy. 1 As the overwhelming majority of smokers start smoking before they become adults we would like you to put health at the centre of the revision of this Directive because making tobacco less affordable is the most effective measure in preventing young people from taking up smoking. Furthermore, research clearly demonstrates that the most price-sensitive demographic for tobacco use is young people because they tend to have less disposable income.

Firstly, we strongly support the introduction of an objective to reduce tobacco prevalence in the legislative proposal for a revision of the Directive. This has been endorsed and promoted by DG TAXUD in the past. Council Directive 2010/12 foresaw a gradual increase in the EU minimum taxation levels on cigarettes and fine cut tobacco up to 2014 and 2018 respectively, specifically stating that “in order to achieve greater convergence and to reduce consumption, the minimum levels of taxation in the Union for cigarettes and fine-cut tobacco intended for the rolling of cigarettes should therefore be increased”. We believe that this objective is important and that the public health objective of reducing tobacco consumption should remain central in a review of the Directive.

Secondly, we emphasise the importance of a gradual upwards convergence in the levels of minimum specific (per quantity) taxation applicable to tobacco products across the EU. Minimum specific taxes establish a threshold for retail prices. Their application results in an increase of the prices of low cost tobacco brands. SFP supports the reinforcement of these taxes as a key public health instrument, with positive budgetary consequences for Member States.

Thirdly, we would like to stress the importance of removing the gap between tax rates applying to roll-your-own tobacco and manufactured cigarettes. Official European Commission data show that between 2006 and 2014 the sales of cigarettes decreased by 32% over the EU25, while the sales of roll-your-own tobacco increased by 45%. The different fiscal treatment of roll-your-own tobacco compared to cigarettes gives it a price advantage, making it affordable to young people and perpetuating health inequalities.

Please find enclosed position paper submitted by the Smoke Free Partnership to the consultation on 3 September. We hope that you will be able and available to meet a small delegation of tobacco control experts in the near future. We will contact your office in the coming days to assess your availability and to find a mutually convenient time for a meeting.

Yours sincerely,

Anca Toma Friedlaender

Director, Smoke Free Partnership

24 Rue de l’Industrie | B-1040 Brussels, Belgium | T: +32 (0)2 430 73 56| www.smokefreepartnership.eu

Signatory organisations, members of the SFP Coalition:

EU: International association of mutual benefit societies EU: CPME: Standing Committee of European Doctors EU: ECL: Association of European Cancer Leagues EU: EHN: European Heart Network Belgium: Belgian Foundation against Cancer Belgium: Kom Op Tegen Kanker Bosnia and Herzegovina: PROI: Progressive Reinforcement of Organizations and Individuals Bulgaria: Smoke Free Life Coalition Bulgaria Czech Republic: Česko Bez Kouře Finland: Suomen ASH: Finland’s Action on Smoking and Health : CNCT: Comité National Contre Le Tabagisme France: La Ligue contre le cancer Germany: ABNR: Aktionsbündnis Nichtrauchen Germany: Unfairtobacco Ireland: ASH Ireland Ireland: Irish Cancer Society Italy: SITAB: Società Italiana di Tabaccologia Kosovo: Kosovo Advocacy and Development Center : NTAKK: Lithuanian National Tobacco and Alcohol Control Coalition Montenegro: Juventas Norway: Norwegian Cancer Society Poland: MANKO Association Portugal: CATR: Centro de Apoio, Tratamento e Recuperação Romania: ARPS: Asociatia Romana pentru Promovarea Sanatatii Serbia: Association „Health Mission“ Serbia: Serbian Society for the Fight Against Cancer Slovenia: No Excuse Slovenia Slovenia: Slovenian Coalition for Public Health, Environment and Tobacco Control Spain: IDEPP: Grupo de I+D en Economía, Políticas Públicas y Salud Spain: XQNS! Sweden: Tobaksfakta - Independent Think Tank The Netherlands: Alliantie Nederland Rookvrij! The Netherlands: Dutch Cancer Society The Netherlands/EU: INWAT: International Network of Women against Tobacco Europe Turkey: Turkish National Coalition on Tobacco or Health UK: ASH (UK) UK: Cancer Research UK UK: UKCTAS: UK Centre for Tobacco and Alcohol Studies UK: FRESH Ukraine: Life: Regional Advocacy Center

24 Rue de l’Industrie | B-1040 Brussels, Belgium | T: +32 (0)2 430 73 56| www.smokefreepartnership.eu