Customer footfall, local service, a functioning e-commerce sector and access to legal products even outside major cities. These are some of the recurring themes that emerge when Swedish trade organisations and retailers respond to the European Commission’s consultation on the forthcoming Tobacco Products Directive, TPD3.
Sales of tobacco and nicotine products account for a significant proportion of the turnover of Swedish convenience stores and service stations. This is stated by Convenience Stores Sweden and the Swedish Service Stations Organisation (OSS) in their responses to the European Commission’s consultation ahead of a review of the Tobacco Products Directive.
The e-commerce company Snuset.se and the campaign group Smoke Free Sweden also raise the issue of access to products outside the major cities.
– “For our members, the sale of tobacco and nicotine products is a key part of their business, not only in terms of direct revenue but also in terms of the customer footfall that underpins profitability in other parts of the business,” writes OSS.
An important part of the shops’ finances
Convenience Stores Sweden represents just over 3,000 Swedish convenience stores with around 10,000 employees. The organisation describes tobacco products as a significant part of its member companies’ sales.
– “The tobacco sector is very important to our members’ finances,” the organisation writes.
OSS represents around 700 petrol stations and service stations. According to the organisation, sales also have an impact on other areas of the business, as customers who come to buy tobacco and nicotine products also purchase other goods and services at the same time.
– “These products generate customer traffic that is crucial to the long-term sustainability of the business, particularly for many smaller companies,” writes OSS.
The organisation pays particular attention to proposals that affect the availability, visibility and range of products.
– Restrictions that affect accessibility, visibility or product range risk reducing customer footfall and thereby impacting the entire business.
Several rules can have a cumulative effect
OSS wants the European Commission to analyse product regulations, taxes and administrative requirements as a whole, rather than as individual measures.
– “Stricter product regulations, combined with higher taxes and increased administrative burdens, risk having a cumulative effect that significantly undermines the profitability of the retail sector,” writes OSS.
The organisation also states that the rules must be practicable in day-to-day shop operations.
– The rules must be practicable in the retail sector without creating disproportionate administrative burdens or uncertainty as to how the requirements are to be met.
Would like to see a broader basis
In its consultation response, Convenience Stores Sweden addresses the issue of the illegal import of tobacco products.
– Our members believe it is important to comply with the law, but we are concerned about the illegal import of tobacco products. We believe that further regulation will lead to more illegal imports.
The organisation would like the Commission to set aside more time for this work and to draw on a broader range of evidence when taking future decisions.
– The process needs more time and should be based on factual evidence.
Online shopping is important outside the major cities
The e-commerce company Snuset.se is highlighting the rules governing distance selling and is calling for common requirements for age verification across the EU.
The company states that the customer’s age is already checked both when the order is placed and when the goods are handed over.
– The buyer’s identity and age should be verified when the order is placed, and delivery should be made to an identified adult recipient. Similar requirements should apply to all businesses selling to consumers within the EU, the company states.
Philip Weyde, a representative of the campaign group Smoke Free Sweden, writes that restrictions on e-commerce would have particular consequences in Sweden.
– Sweden is a large country. Forcing people who live outside the major cities to buy these products exclusively in high-street shops presents major practical problems.
He describes online sales as a way of being able to buy legal products even where the range in physical shops is limited.
– Online shopping is essential for accessibility, not a luxury, writes Philip Weyde.
Would like to see the implications for trade set out in the supporting documentation
OSS is also calling for impact assessments covering employment, business costs and access to services in different parts of Sweden.
The organisation states that it can provide data from its member companies.
– We are prepared to provide data and specific examples from Swedish service stations to ensure that future legislation is effective, proportionate and fit for purpose.
Convenience Stores Sweden would similarly like future decisions to be based on evidence of how the legal retail sector is affected.
– “It is important that the Commission takes into account the economic consequences for small businesses and the risk of sales being channelled into illegal markets,” the organisation writes.
