CSS kontaktar ministrar i tobaksfrågan

Dear…

On behalf of Convenience Stores Sweden, representing Retailers as a National Association for convenience stores, we are writing to express our urgent concerns regarding the ongoing negotiations of the European Union’s position for the upcoming session of the Conference of the Parties to the WHO Framework Convention on Tobacco Control (WHO FCTC), scheduled for 17–22 November in Geneva.

We understand that Member States have begun negotiating the EU’s position based on a draft prepared by the European Commission. Of particular concern are two items on the published agenda : the FCTC documents titled Forward-looking tobacco control measuresand Protection 1 2 of the environment and the health of persons.The current position as reported in the media 3 seems to be extremely concerning since major regulatory restrictions are still endorsed.

If adopted, the proposals outlined in these documents would have devastating consequences for retailers, local economies, and the EU’s overall competitiveness.

Among the measures under discussion are:

• The elimination of commercial tobacco sales

• A compulsory in retail outlets selling tobacco products

• A ban on incentives to retailers

• The introduction of generational sales bans of tobacco products

• A ban on cigarettes with filters (in practice a de-facto ban of traditional cigarettes)

• A ban on safer nicotine pouches and new nicotine products

These proposals are radical, legally questionable, and economically disconnected from reality. They threaten the survival of thousands of small and medium-sized retail businesses across Europe, putting jobs and livelihoods at serious risk. Retailers are already under pressure from inflation, rising operational costs, and the growing threat of illicit trade. These measures would exacerbate these challenges, driving consumers toward illicit markets run by criminals and undermining public revenues.

We are deeply concerned that these proposals—despite directly targeting the retail sector— have not been subject to any consultation with our representatives, nor have their impacts been properly assessed. In the EU, we rely on sound policymaking principles that include transparency, stakeholder engagement, public consultations, impact assessments, and a robust evidence base. In this case, the retail sector has been completely excluded from the process, raising serious questions about whether the interests of EU Member States and the broader economic implications have been adequately considered.

Furthermore, most of these measures have never been implemented in a real-world setting, while the trade-offs they would entail in economic harm and dislocation are ignored. These policies risk undermining public health and doing the very opposite of what is intended – pushing products into criminal and unregulated markets, where youth access actually increases, consumer safeguards disappear, law-abiding retailers lose out, and tax revenues reduce.

As these proposals are currently being discussed within the Working Party on Public Health to shape the EU’s position for COP11, we urge the EU to reject this approach in full during the EU negotiations and to firmly maintain this position at the COP11 It is essential that any decisions be preceded by proper policymaking, including a thorough assessment of all economic, fiscal, legal, employment, and social consequences.

Retail associations across Europe stand ready to provide further information and evidence on the real-world implications of these proposals. We respectfully ask for your leadership in ensuring that the voices of EU stakeholders—and the livelihoods of thousands of retailers—are not overlooked in Brussels and in Geneva.

We kindly ask that you reflect our position in your considerations. We would be pleased to explain our concerns in more detail at a meeting at your convenience.

Thank you for your attention to this critical matter.

Warm regards,

Bengt Hedlund

CEO

Convenience Stores Sweden

Artillerigatan 6 114 51 Stockholm

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