Introduction

Title
Bill amending the Act on the ban on tobacco advertising etc., Act on tobacco products etc., Act on electronic cigarettes etc. and various other acts (Implementation of the national action plan against smoking by children and young people)

Products Concerned
S00S – HEALTH, MEDICAL EQUIPMENT

Notification Under Another Act
– Directive 2014/40/EU of the European Parliament and of the Council of 3 April 2014 on the approximation of the laws, regulations and administrative provisions of the Member States concerning the manufacture, presentation and sale of tobacco and related products and repealing Directive 2001/37/EC – Article 24(2) and (3)

Main Content
– Display ban:
tobacco products, tobacco substitutes and electronic cigarettes are not to be visible to consumers at points of sale, including on the Internet, until a customer specifically requests them. This does not however apply to:
physical shops that specialise in the sale of cigars, pipes and pipe tobacco respectively, and the sale of electronic cigarettes:
– Stricter ban on advertising and sponsorship:
all forms of direct and indirect advertising and sponsorship are banned and, as an additional element, tobacco substitutes and herbal products for smoking are also covered by the ban.
– Standardised packaging:
all tobacco products, herbal products for smoking and electronic cigarettes must have a uniform appearance. This does not however apply to cigars, pipe tobacco and pipes. The standardisation means, among other things, that the manufacturer and product name must appear in a standardised way, that logos must not stand out and that the colour etc. of the packaging must be standardised. Standardisation can limit the advertising effect of the packaging.
– Smoke-free school time:
to avoid school pupils being confronted with smoking etc. during school hours, it is proposed that school time should be smoke-free in all primary schools, boarding schools, continuation schools and upper secondary education facilities.
– Smoke-free properties:
upper secondary education facilities including children and young people under 18 years of age and not covered by the current requirements for smoke-free properties are proposed to be included.
– Ban on the sale of tobacco, tobacco substitutes, herbal products for smoking and electronic cigarettes and refill containers with and without nicotine in primary schools, boarding schools, continuation schools and upper secondary education facilities.
– Ban on flavourings in tobacco products and electronic cigarettes:
the sale of electronic cigarettes etc. with characteristic flavours other than the taste of tobacco and menthol is banned. The same is proposed for those tobacco products that are not already covered by the ban on characteristic flavours, although not for pipe tobacco and cigars or herbal products for smoking.
– Regulation of tobacco substitutes (nicotine products):
not previously regulated in Danish law, but proposed to be covered by the same regulation as tobacco products with respect to, for example, advertising regulations, age limits, etc. Requirements are also proposed on health warnings on the packaging in line with the current regulations for electronic cigarettes.
– Age control system and stricter penalty levels:
requirements are laid down for all retailers marketing over the Internet to ensure a system that effectively verifies the age of the purchaser, and the penalty of breaching the age limit is proposed to be made stricter.
– Registration scheme for retailers of electronic cigarettes and refill containers with and without nicotine, registration scheme for tobacco substitutes and refill containers without nicotine.
– Stricter penalties for breaches of the Act on smoke-free environments.
– Easier access for municipalities to provide free smoking cessation medication.

Response:

Introduction

Digitalisation is transforming the European financial system and the provision of financial services to Europe’s businesses and citizens. In the past years, the EU and the Commission embraced digitalisation and innovation in the financial sector through a combination of horizontal policies mainly implemented under the umbrella of the Digital Single Market Strategy, the Cyber Strategy and the Data economy and sectoral initiatives such as the revised Payment Services Directive, the recent political agreement on the crowdfunding regulation and the FinTech Action Plan. The initiatives set out in the FinTech Action Plan aimed in particular at supporting the scaling up of innovative services and businesses across the EU, for example through enhanced supervisory convergence to promote the uptake of new technologies by the financial industry (e.g. cloud computing) but also to enhance the security and resilience of the financial sector. All actions in the Plan have been completed.

The financial ecosystem is continuously evolving, with technologies moving from experimentation to pilot testing and deployment stage (e.g. blockchain; artificial intelligence; Internet of Things) and new market players entering the financial sector either directly or through partnering with the incumbent financial institutions. In this fast-moving environment, the Commission should ensure that European consumers and the financial industry can reap the potential of the digital transformation while mitigating the new risks digital finance may bring. The expert group on Regulatory Obstacles to Financial Innovation, established under the 2018 FinTech Action Plan, highlight these challenges in its report published in December 2019.

The Commission’s immediate political focus is on the task of fighting the coronavirus health emergency, including its economic and social consequences. On the economic side, the European financial sector has to cope with this unprecedented crisis, providing liquidity to businesses, workers and consumers impacted by a sudden drop of activity and revenues. Banks must be able to reschedule credits rapidly, through rapid and effective processes carried out fully remotely. Other financial services providers will have to play their role in the same way in the coming weeks.

Digital finance can contribute in a number of ways to tackle the COVID-19 outbreak and its consequences for citizens, businesses, and the economy at large. Indeed, digitalisation of the financial sector can be expected to accelerate as a consequence of the pandemic. The coronavirus emergency has underscored the importance of innovations in digital financial products services, including for those who are not digital native, as during the lockdown everybody is obliged to rely on remote services. At the same time, as people have access to their bank accounts and other financial services remotely, and as financial sector employees work remotely, the digital operational resilience of the financial sector has becoming even more important.

As set out in the Commission Work Programme, given the broad and fundamental nature of the challenges ahead for the financial sector, the Commission will propose in Q3 2020 a new Digital Finance Strategy/FinTech Action Plan that sets out a number of areas that public policy should focus on in the coming five years. It will also include policy measures organised under these priorities. The Commission may also add other measures in light of market developments and in coordination with other horizontal Commission initiatives already announced to further support the digital transformation of the European economy, including new policies and strategies on data, artificial intelligence, platforms and cybersecurity.

Response

Introduction

Global warming is happening and affecting citizens while threatening our long-term sustainability on this planet. The average temperature of our planet has already increased by 1°C and the world is currently not on track to achieve the Paris Agreement objective of limiting temperature change below 2°C, let alone 1.5° C. The 2018 special report of the Intergovernmental Panel on Climate Change on 1.5°C indicated that already at 2°C the world would see dramatic and potentially irreversible impacts due to climate change. Science is also clear on the close link and interdependence of climate change and biodiversity loss.

The EU has taken global leadership in tackling climate change and actively pursues policies to cut its greenhouse gas emissions and to decouple these from economic growth. This allows the EU to modernise its economy and energy system, making them sustainable in the long term and to improve energy security and the health of its citizens by reduced air pollution.

The EU has already adopted climate and energy legislation to reduce greenhouse gas emissions by at least 40% by 2030 compared to 1990 levels. Furthermore, it adopted ambitious energy efficiency and renewable energy legislation, whose full implementation is estimated to reduce greenhouse gas emissions beyond the existing target – by around 45% by 2030. As part of this legislation, Member States develop National Energy and Climate Plans to ensure that common EU objectives will be met. Unless complemented by further policies, the agreed legislation is expected to lead to around 60% greenhouse gas emissions reductions by 2050. In 2018, the Commission proposed for the EU to become climate compensating any remaining GHG emissions by absorptions. The European Parliament neutral by 2050 and the European Council endorsed this objective in 2019. The Commission has proposed to enshrine this objective in the European Climate Law.

According to the latest Eurobarometer survey, 93% of EU citizens see climate change as a serious problem and a significant majority of the EU population wants to see increased action on climate change. As a reflection of this and due to the urgency of the climate and linked ecological challenges, the European Commission has proposed in December 2019 a as one of its priorities including a list European Green Deal of forthcoming proposals to deliver it. The Green Deal aims, among others, to align all EU policies with the 2050 climate neutrality objective, sending an early and predictable signal to all sectors and actors to plan
2 for the transformation.

As part of the Green Deal, the Commission intends to propose to increase the EU’s 2030 target for greenhouse gas emission reductions to at least -50% and towards -55% compared to 1990 levels, in a responsible way. The Commission will thoroughly assess the feasibility and the social, economic and environmental impacts of increasing the 2030 target. This assessment will look into how to increase ambition in a way that enhances EU competitiveness, ensures social fairness and access to secure, affordable and sustainable energy and other material resources, benefits citizens and reverses biodiversity loss and environmental degradation. The Commission intends to present a comprehensive plan to increase the EU 2030 climate target in the third quarter of 2020.

Building on the existing 2030 legislation and the upcoming comprehensive plan, the Commission will review and propose to revise, where necessary, the key relevant energy and climate legislation by June 2021. This will include a coherent set of changes to the existing 2030 climate, energy and transport framework, notably related to the EU Emissions Trading System Directive, the Effort Sharing Regulation and the Land Use, Land Use Change and Forestry Regulation, CO Emissions Performance Standards for Cars and Vans 2 and, as appropriate, the Renewable Energy Directive and the Energy Efficiency Directive.

This public consultation invites citizens and organisations to contribute to the assessment of how to increase the EU 2030 emission reduction ambition in a responsible way. Please note that relevant questions and topics may also be covered under other public consultations such as for instance the Strategy on Sustainable and Smart Mobility, the EU Adaptation Strategy, the “Farm to Fork” Strategy, the Action Plan to implement the European Pillar of Social Rights, the Targeted Consultation for the Evaluation of the Guidelines on State aid for Environmental protection and Energy 2014-2020.

Response:

About this initiative

Summary

New business models such as the digital economy create challenges for national tax authorities in terms of tackling tax fraud and evasion.
This initiative aims to strengthen the framework so tax authorities can better exchange information on taxpayers working in the digital economy. This will help ensure they report what they earn and pay adequate tax.
It will also create a more efficient tax environment so compliant businesses can benefit from the single market and sustain economic growth.

Topic: Taxation
Type of act: Proposal for a directive
Digital platforms

The phenomenon of digital platforms facilitating peer-to-peer sale of goods or services between users – including the “collaborative economy” or so-called “sharing” and “gig” economy – is growing rapidly.

Many different services can be accessed through digital platforms. Some examples include:

• accommodation services ( such as renting an apartment when going on holidays);
• transportation services (such as car sharing);
• food-related services (such as home delivery);
• household services (such as gardening or babysitting);
• professional services (such as accounting or legal services);
• collaborative finance services (such as crowd-funding).

While the emergence of these digital platforms can have strong positive effects on the economy, they also raise a number of issues, including making sure that participants selling goods or services via those platforms (platform sellers) are aware of and fully comply with their tax obligations.

Given the nature of these platforms – highly mobile, operating internationally and often with no real physical presence – it can be challenging for tax administrations to gain timely access or even detect relevant information on transactions carried out or income obtained through digital platforms. These developments present risks of distorting competition with traditional businesses and leading to taxable income not being reported, and having the potential of becoming a vehicle for the shadow economy.

There are concerns that some income obtained by platform sellers is not declared to the relevant tax authorities. A number of EU countries (e.g. Italy, France, Denmark or Estonia) have already introduced unilateral reporting measures requiring platforms to communicate to the tax authorities revenues received by platform sellers, while others are planning to introduce similar measures in the near future. However, it is also recognised that unilateral measures are inefficient, as enforcement of the rules proves difficult – if not impossible – in a flexible and remotely operated business model. Additionally, each (unilateral) approach may include different registration and compliance requirements. This may lead to different regulatory models between EU countries and Single Market fragmentation, with an inherent administrative burden for both platforms and users.

Evaluation of EU marketing standards (contained in the Common Market Organisation (CMO) regulation, the “breakfast directives” and CMO secondary legislation)

17. Are you familiar with any EU marketing standards in any of the following product sectors? (CCC Responses are in Green)

18. In your opinion, to what extent have the EU marketing standards, in the product sectors you are familiar with, contributed to supplying the market with products of a standardised and satisfactory quality ?

19. In your opinion, to what extent have the EU marketing standards, in the product sectors you are familiar with, contributed to improving the conditions for production and marketing and creating a level-playing field in these sectors ?

20. In your opinion, to what extent have the EU marketing standards, in the product sectors you are familiar with, contributed to providing adequate and transparent information to consumers ?

21. In your opinion, to what extent have the EU marketing standards, in the product sectors you are familiar with, contributed to providing the purchaser with value for money ?

22. In your opinion, to what extent could efficiency be improved by harmonising the control and reporting requirements of the different marketing standards ?

23. In your opinion, what could be simplified, and how, in order to improve the management and implementation of the EU marketing standards ?

24. In your opinion, to what extent are the EU marketing standards, in the product sectors you are familiar with, consistent to other EU policy interventions in these sectors?

Please specify:

25. In your opinion, to what extent are the EU marketing standards, in the product sectors you are familiar with, consistent with international marketing standards and with private marketing standards?

26. In your opinion, has the implementation of the EU marketing standards caused any unexpected or unintended effects in terms of food waste ?

27. In your opinion, has the implementation of the EU marketing standards caused any unexpected or unintended effects in terms of animal welfare ?

28. In your opinion, has the implementation of the EU marketing standards caused any potential of abuse by market actors ?

29. In your opinion, to what extent do the EU marketing standards, in the product sectors you are familiar with, fit with the needs of the supply chain in these sectors (i.e. producers, processors, traders, retailers) ?

30. In your opinion, to what extent do the EU marketing standards, in the product sectors you are familiar with, fit with the needs of consumers ?

31. In your opinion, to what extent do the EU marketing standards, in the product sectors you are familiar with, fit with the needs of Member States administrations ?

32. In your opinion, what are the most essential benefits of the EU marketing standards that cannot be achieved by the Member States/sectors acting on their own ?

33. Do you have any suggestions on how EU marketing standards could further improve product quality and production/marketing conditions in these sectors ?

34. In your opinion, has the implementation of the EU marketing standards caused any unexpected or unintended effects in regard to the sustainability of the food chain ?

35. Please feel free to upload a concise document, such as a position paper. The maximum file size is 1MB.

Please note that the uploaded document will be published alongside your response to the questionnaire which is the essential input to this public consultation. The document is optional and serves as additional background reading to better understand your position. 

The Tobacco Advertising and Promotion (Display) (England) Regulations 2010

These regulations apply to the display of tobacco products in small and large shops (display ban) and came into force on 6 April 2012 in larger shops and 6 April 2015 for all other outlets. The regulations prohibit the display of tobacco products in small and large shops, allowing trading to continue but preventing them from being used as promotional tools. All retailers are required to cover up cigarettes and hide all tobacco products from public view.

The full Tobacco Advertising and Promotion (Display) (England) Regulations 2010 are published on Legislation.gov.uk

1. Do you think the display ban of tobacco in small and large shops has helped to reduce the number of children and young people smoking?

Answer: I don’t know if it has or not.

Current scientific evidence points to the fact that smoking susceptibility amongst young people has dropped following the introduction of the display ban on tobacco in small and large shops. 

A decrease in smoking susceptibility does not necessarily equate to a decline in smoking rates, since this decrease also correlates with a number of other factors, on both the regulatory and the educational side, as well as innovations such as harm-reducing products. A negative side-effect of a display ban can be that smoking is perceived as an ominous and secretive act, which encourages certain youth to pick it up. In a comparable fashion, illicit narcotic substances are also purchased in large numbers by youths, without any advertising or display. We know through evidence in countries that have legalised or decriminalised these substances (particularly in the case of cannabis) that youth consumption rates normalise as the handling of the substance reaches social acceptance.

It would be ill-advised for the government to recreate the bad side-effects of prohibition in the case of tobacco. 

2. Do you think the tobacco display ban has encouraged and supported adult smokers to quit?

Answer: I don’t know if it has or not.

Scientific evidence presented by the World Health Organization (WHO) points to the example of New Zealand, where a display ban coincided with a decrease in smoking prevalence from 9% to 7%.

Correlation does not mean causation. The measure also has overlap with both the regulatory and educational measures, as well as innovations such as harm-reducing products. Further scientific research in the United Kingdom would be necessary to determine whether a decline in adult smoking cessation can be related to display bans.

3. What impact do you think the display ban has had on:

(a) general population

(b) retailers

(c) manufacturers

(d) other stakeholders

For consumers, the implementation of a display ban reduces the amount of information available for tobacco. Cigarettes are a legal product in the United Kingdom, yet consumers are now unable to identify differences between brands and are unexposed to new upcoming products. Added to that, a display ban creates uncertainty on the legal market, as the practice of selling cigarettes “under the counter” is equally present in the case of retailers engaging in the sales of illicit cigarettes.

Some of our members have reported to us to have received counterfeit products when purchasing cigarettes in UK corner stores. The display ban might make it easier for vendors of counterfeit cigarettes to hide their illicit products from consumers and law enforcement until the moment of sale.

4. Is the display ban an effective way to protect children and young people from taking up smoking and supporting those who wish to quit?

Answer: No, I don’t think it is.

Given the insufficient amount of evidence on the question of effectiveness and the clear risks that the Consumer Choice Center has listed in an answer on the impact of the display ban, we do not believe that the measures constitute an effective way to protect children and young people from taking up smoking and supporting those who wish to quit.

We believe that harm-reducing products such as e-cigarettes represent an innovative way towards smoking cessation. The UK’s permissive approach to e-cigarettes has shown a positive impact. According to the NHS, between 2011 and 2017, the number of UK smokers fell from 19.8% to 14.9%. At the same time, the number of e-cigarette users rose: almost half of these consumers use e-cigarettes as a means of quitting smoking.

5. Were there any economic losses or gains (for individuals, businesses and wider society) associated with implementing the display ban on tobacco products?

Answer: Yes, I think there were some economic losses or gains.

With a loss in brand awareness and the creation of consumer uncertainty on the legal market, the Consumer Choice Center believes that a loss in consumer choice has been created by the display ban. We also think that this has fuelled the shadow economy and allowed vendors with bad intentions to sell more illegal cigarettes to consumers.

The Tobacco and Advertising (Specialist Tobacconists) (England) Regulations 2010

These regulations apply to the display of tobacco products in Specialist Tobacconists and came into force on 6th April 2015.

These regulations provide exemptions for specialist tobacconists to the general prohibition of the display of tobacco products. They allow tobacco products to be displayed within specialist tobacconists as long as they are not visible from outside the shops. Additionally, the legislation permits tobacco advertising provided it is in, or fixed to the outside of premises of a specialist tobacconist and complies with prescribed conditions.

The full Tobacco and Advertising (Specialist Tobacconists) (England) Regulations 2010 are published on Legilsation.gov.uk.

1. Do you think the display ban of tobacco in specialist tobacconists has helped to reduce the number of children and young people smoking?

Answer: I don’t know if it has or has not.

Current scientific evidence has analysed the situation in regular commercial establishments. The purpose of a specialist tobacconist shop is to sell tobacco, with other items for sale being proportionally secondary. Evidence would need to be gathered in order to make concrete statements on the effect of the display ban in this instance.

2. Do you think the display ban in specialist tobacconists has encouraged and supported adult smokers to quit?

Answer: I don’t know if it has or has not.

Current scientific evidence has analysed the situation in regular commercial establishments. The purpose of a specialist tobacconist shop is to sell tobacco, with other items for sale being proportionally secondary. Evidence would need to be gathered in order to make concrete statements on the effect of the display ban in this instance.

3. Has the display ban within specialist tobacconists had any further impacts not covered in the questions above?

Answer: I don’t know if it has or has not.

Provided the exemptions in the current law surrounding display bans, the case of specialist tobacconists is different from regular retailers and needs to be examined separately.

4. Is the display ban in specialist tobacconists an effective way to protect children and young people from taking up smoking and supporting those who wish to quit?

Answer: I don’t know whether it is or it is not effective.

Provided the exemptions in the current law surrounding display bans, the case of specialist tobacconists is different from regular retailers and needs to be examined separately.

We believe that harm-reducing products such as e-cigarettes represent an innovative way towards smoking cessation. The UK’s permissive approach to e-cigarettes has shown a positive impact. According to the NHS, between 2011 and 2017, the number of UK smokers fell from 19.8% to 14.9%. At the same time, the number of e-cigarette users rose: almost half of these consumers use e-cigarettes as a means of quitting smoking.

5. Were there any economic losses or gains (for individuals, businesses and wider society) associated with carrying out this regulation in the community?

Answer: I don’t know if there were or not economic losses or gains.

Given the insufficient amount of evidence on the question of effectiveness, and the clear risks that the Consumer Choice Center has listed in an answer on the impact of the display ban, we do not believe that the measures constitute an effective way to protect children and young people from taking up smoking and supporting those who wish to quit.

We believe that harm-reducing products such as e-cigarettes represent an innovative way towards smoking cessation. The UK’s permissive approach to e-cigarettes has shown a positive impact. According to the NHS, between 2011 and 2017, the number of UK smokers fell from 19.8% to 14.9%. At the same time, the number of e-cigarette users rose: almost half of these consumers use e-cigarettes as a means of quitting smoking.

The Tobacco and Advertising (Display of Prices) (England) Regulations 2010

These regulations impose requirements on the display of prices of tobacco products in small and large shops and came into force on 6th April 2015.

The regulations permit only three types of tobacco price displays within retailers:

1. Poster style lists (up to A3 in size) which can be permanently on show but must not exceed 1,250sq centimetres in size
2. A list including pictures of products, which must not be left on permanent show, but can be shown to any customer aged 18 or over who asks for information on tobacco products sold; and
3. Price labels, which can be placed on shelving, storage units or tobacco jars. One price label is permitted for each product either on the covered shelf where the product is stored or on the front of the storage unit.

The full Tobacco and Advertising (Display of Prices) (England) Regulations 2010 are published on Legislation.gov.uk

1. Have the restrictions on the display of prices of tobacco products helped reduce the number of children and young people smoking?

Answer: I don’t know if they have or have not.

Current scientific evidence on this matter is scarce. Existing evidence suggests that price display bans can reduce smoking prevalence. However, the same research also suggests that price policies need to be accompanied by certain minimum price rules. Therefore, the immediate effectiveness of price display bans in themselves are questionable and cannot be proven with existing evidence.

2. Have the restrictions on the display of prices of tobacco products helped encourage and support adult smokers to quit?

Answer: I don’t know if they have or have not.

Current scientific evidence on this matter is scarce. Existing evidence suggests that price display bans can reduce smoking prevalence. However, the same research also suggests that price policies need to be accompanied by certain minimum price rules. Therefore, the immediate effectiveness of price display bans in themselves are questionable and cannot be proven with existing evidence.

3. What impact do you think the restriction of display of prices of tobacco products has had on the following:

(a) general population

(b) retailers

(c) manufacturers

(d) other stakeholders (please specify)

Please give reason(s) and evidence for your answers.

Restricting price indications at retail deprives consumers of information about tobacco, a product which can be purchased legally with some restrictions in the United Kingdom. Consumers are vulnerable to be misled by retailers about the product they are buying, and are not afforded the necessary transparency to make an informed purchase.

4. Is restricting the display of prices of tobacco products an effective way to protect children and young people from taking up smoking and support those who wish to quit?

Answer: I don’t know if it is or is not effective.

Current scientific evidence on this matter is scarce. Existing evidence suggests that price display bans can reduce smoking prevalence. However, the same research also suggests that price policies need to be accompanied by certain minimum price rules. Therefore, the immediate effectiveness of price display bans in themselves are questionable and cannot be proven with existing evidence.

We believe that harm-reducing products such as e-cigarettes represent an innovative way towards smoking cessation. The UK’s permissive approach to e-cigarettes has shown a positive impact. According to the NHS, between 2011 and 2017, the number of UK smokers fell from 19.8% to 14.9%. At the same time, the number of e-cigarette users rose: almost half of these consumers use e-cigarettes as a means of quitting smoking.

5. Were there any economic losses or gains (for individuals, businesses and wider society) associated with carrying out this regulation in the community?

Answer: I don’t know if there were economic losses or gains.

Restricting price indications at retail deprives consumers of information about tobacco, a product which can be purchased legally with some restrictions in the United Kingdom. Consumers are vulnerable to be misled by retailers about the product they are buying, and are not afforded the necessary transparency to make an informed purchase.

The Smoke-free (Private Vehicles) Regulations 2015

The regulations came into force as of 1st October 2015 and apply in England. Regulation 5; penalties and discounted amount also applies in Wales.  These regulations make it an offence for:

• A person to smoke in a private vehicle when someone under the age of 18 is present
•  A driver not to stop a person smoking when someone under the age of 18 is present.

The regulations are thought to have minimal impact in business. Police Authorities are the designated enforcement offices, with the power to issue Fixed Penalty Notices (FPN) to anyone found to be non-compliant with the law.

The full Smoke-free (Private Vehicles) Regulations 2015 are published on Legislation.gov.uk.

1. Have the Smoke-free (Private Vehicles) Regulations helped prevent people from smoking in vehicles with children?

Answer: No, I don’t think they have.

There is no sufficient amount of evidence in England that would allow for a thorough conclusion on this matter. Existing evidence from Portugal showed that despite widespread support for the regulation, “high smoking prevalence and poor enforcement contribute to low compliance”.

2. What impact do you think Smoke free (Private Vehicles) Regulations have had on: general public, retailers, manufacturers, other stakeholders (please specify)

The Consumer Choice Center believes that though the intent of the legislation is commendable, the costs involved with enforcing the measure thoroughly far exceed the benefits. Law enforcement work on lifestyle matters should be focused on preventing sales of tobacco to young people, and combating illicit trade.

3. Do you believe prohibiting smoking in private vehicles is an effective way to protect children and young people from harms of tobacco and second-hand smoke?

Answer: I don’t know if it is or if is not.

There is no sufficient amount of evidence in England that would allow for a thorough conclusion on this matter. The question is not whether smoking in private vehicles is unhealthy to children and young people from a health perspective, but whether legislation is the correct approach to solving this issue. A prohibition on this matter can also lead to complicated law enforcement situations. A family car that smells of tobacco because the parent smoked in the vehicle prior to picking up children could offset a fine, even though the driver did not break the law.

We believe that education through the schooling system is the correct way to pursue public health objectives.

4. Were there any economic losses or gains (for individuals, businesses and wider society) associated with carrying out this regulation in the community?

Answer: I don’t know if there were economic losses or gains.

There is no sufficient amount of evidence in England that would allow for a thorough conclusion on this matter. Existing evidence from Portugal showed that despite widespread support for the regulation, “high smoking prevalence and poor enforcement contribute to low compliance”.

Increased law enforcement in this area would increase costs for taxpayers.

Objective of the consultation:

The aim of this public consultation is to collect information, views and opinions on the effectiveness, efficiency, coherence and relevance of the EU-Mediterranean Association Agreements’ trade chapters with Algeria, Egypt, Jordan, Lebanon, Morocco and Tunisia. The results of the consultation serve as input for the evaluation of the impacts of these Agreements, a project jointly conducted by Ecorys, CASE and FEMISE on behalf of the European Commission. For more background information on the project please consult the following website. The consultation will be open for 12 weeks.

1. Were you aware of an FTA between the EU and the Southern Mediterranean region prior to hearing about this evaluation?

Yes

2. To what extent do you believe that the FTAs have met the following objectives related to the bilateral relations between the EU and the Southern Mediterranean region?

3. Please provide an explanation of how the FTAs have led to this impact:

4. To what extent do you believe the FTAs have met the following objectives related to regional cooperation?

5. Please provide an explanation of how the FTAs have led to this impact:

6. To what extent are the FTAs between the EU and Southern Mediterranean region coherent with the following policies? (Click on the name of the policy for more information.)

70. What are the most positive aspects of the FTAs between the EU and the Southern Mediterranean region?