We welcome the opportunity to discuss and provide evidence for the amendments to the Tobacco Taxation Directive (2011/64/EU) and the Council Directive on general arrangements for excise duty (2020/262/EU).
At the same time, we are concerned by the combination of the first and second objectives driving the proposed changes: 1) “Increasing the minimum tax rates to reduce disparity in rates applied by Member States” and 2) “Extending the scope of the directive to new products (e-cigarettes, heated tobacco, and nicotine pouches). These products will be covered with new minimum taxes”.


