European Federation for Transport &
Environment (T&E)
Bd. De Waterloo 34
1000 Brussels
European
Environmental Bureau (EEB)
Bd. De Waterloo 34
1000 Brussels
Response from Non Governmental Organisations on the
Commission proposal for a Council Directive amending Directive
92/81/EEC and Directive 92/82/EEC to introduce special tax arrangements for
diesel fuel used for commercial purposes and align the excise duties on petrol
and diesel fuel
T&E and EEB generally welcome this initiative, because
there is no economical, fiscal, social or environmental justification, for the
huge tax breaks diesel fuel currently enjoys. The fact that diesel vehicles are
more fuel-efficient than petrol ones implies that it will be cheaper to run
diesel vehicles. Furthermore, diesel
produces at least three times more harmful particulates and NOx than petrol
engines. Additionally, there is
increasing scientific evidence that particulates from diesel actually
contribute more to global warming than greenhouse gases from petrol-fuelled
vehicles[1].
Moreover, a recent study by Apheis[2]
shows that even a marginal decrease in harmful particulates emitted from diesel
vehicles could save thousands of lives from premature death throughout Europe.
For these reasons, petrol and diesel vehicles do not
have significantly different external costs. It is therefore environmentally
unsound, socially unjust and economically inefficient that the drivers of
petrol vehicles, which constitute one segment of road users, should pay significantly
more than the other segment, namely drivers of diesel vehicles.
Therefore, we believe that harmonisation is very
much needed and should be upwards, as seems to be the case with the current
proposal, particularly in the case of price indexation. A harmonised rate would
make the introduction of EU energy/CO2 taxes easier. Furthermore, a
harmonised rate on professional diesel would help in avoiding environmentally
harmful traffic detours, fuel tourism and market distortions. The present
proposal is therefore to be welcomed.
However, T&E and EEB also have serious reservations on
some points and make the following policy recommendations:
·
The proposal should contain
a link with road pricing instead of merely making recommendations to
governments to have recourse to road charges in order to compensate for loss of
revenue. Therefore we call on the Commission to
accelerate the publication of its expected transport infrastructure charging
proposal. This is particularly needed in the case of some member states,
like the UK, that have higher fuel tax rates than the new proposal and would
therefore need to reduce them. If infrastructure pricing were introduced
according to the user pays principle, heavy vehicles would contribute more
towards road maintenance and external costs. Such a user pays system, which
included environmental costs, could also help in compensating those populations
of rural or peripheral areas that are more dependant on road transport than
others. For policy coherence, this
diesel tax proposal may be reviewed in light of the transport infrastructure
charging directive.
·
The harmonised rate on
diesel should apply to all commercial
vehicles, not just those over 16 tonnes. The choice of the 16 tonnes threshold seems
arbitrary and may result in fleet changes (i.e. transport companies buying
lorries according to the rates applicable under or above 16 tonnes). In the
longer term, diesel tax differentiation between commercial and non-commercial
vehicles must be abolished, in line with the Commission’s own stated objective[3].
·
The objective should be to
have higher rates for diesel and petrol vehicles in order to better
internalise environmental costs and limit the growth of road transport. Higher rates are also
essential to push for more innovation into cleaner engines and vehicles.
According to the original 1997 energy taxation directive the proposal should
have a rate of at least 450 euros as a target for 2010.[4]
·
In the short to medium term
it should become mandatory for member states
to align their diesel and petrol rates on the national level. With regard to
non-commercial diesel fuel, the alignment of the diesel rate to that of petrol
is to be welcomed. However, the proposal would concern only the EU minimum
rates, coupled with recommendations to governments to align the rates at
national level too. Although aligning EU minimum rates would be a good signal,
we know that most Member States in practice apply higher rates than the
minimum, and differentiate between diesel and petrol.
·
Diesel tax differentiation
between commercial and non-commercial vehicles should be abolished. According to the proposal
the price of non-commercial and commercial diesel will continue differing,
which leads to “cheating” at the pump with the result that some motorists are
not paying the full excise duties. Reinstating a refund mechanisms to transport
companies, as proposed, can help to avoid some of these problems. But there are
serious concerns that the proposed refunding mechanisms will not be able to
avoid this behaviour on a mass scale, especially in some of the new Member
States after enlargement takes place.
·
The proposal should contain
recommendations for the introduction of an EU-wide CO2 tax. Although petrol is better
than diesel in terms of harmful particulates emissions, it produces more CO2 per kilometre driven.
·
The proposal should include
a recommendation for governments to implement tax increases in a
revenue-neutral way, e.g. shifting from labour taxes to taxing the use of resources. This
will have the advantage of generating greater public acceptance.
For further information, please contact
Markus Liechti, T&E,
markus.liechti@t-e.nu , phone +32-(0)2-502 99 09
Sylvain Chevassus, EEB, sylvain.chevassus@eeb.org , phone +32-(0)2-289 13 02
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