The EESC supports the proposal and intends to comment on some aspects as a contribution to the discussions that will follow.
A dual procedure (as regards the date of entry into force) would be confusing and expensive both for the authorities and for traders. However, the alternative, i.e. to launch EMCS only when everyone is ready, would similarly penalise traders and those who are already ready now. An interim solution, which is hardly satisfactory and would be likely to delay EMCS in Europe indefinitely, might consist in using EMCS only for internal transactions within those Member States able to adopt the electronic procedure.
With regard to the movement of goods under suspension of excise duty, the EESC supports the various innovations, aside from a few clarifications and proposals that are mainly to do with the concept, which is now more clearly defined, of "irretrievable loss" of goods. With regard to distance selling, the wording of the proposal could give rise to doubts of interpretation of a legal nature concerning the country in which excise duty is to be collected.
The EESC also proposes that a clause be inserted into the new directive specifying the quantitative and value limits up to which purchases made by a member of the public in another Member State are considered to have been made by that person as a "private individual".