Ref. Ares(2020)3968922 - 28/07/2020
From:
<
@svenskhandel.se>
Sent: Friday, April 24, 2020 3:48 PM
To:
(GROW) <
@ec.europa.eu>;
(GROW)
<
@ec.europa.eu>
Subject: VB: Swedish services notification - THE SWEDISH CONSUMER AGENCY'S GENERAL ADVICE
(KOVFS 2019:3)
Dear
and
,
I am contacting you regarding the possibility to provide some comments to the Swedish services
notification KOVFS 2019:3 mentioned below.
I received your contact details from
, as I could not find any contact details on the
Commission website. There is only this note ”You can submit comments to COM (DG GROW E1)”
He informed the Swedish Trade Federation about this issue.
FYI - I sent the attached document, from one of our members, to the Swedish National Board of
Trade.
The Swedish Trade Federation has several times sent questions about the formal requirements of
non-discrimination, necessity and proportionality to the Swedish Consumer Agency without
receiving any clear answers.
By issuing the general advice, the Swedish Consumer Agency can be considered to have introduced a
ban on the marketing of tobacco products on the Internet that is not supported by law.
KOVFS 2019:3, does not fulfil the formal requirements of non-discrimination, necessity and
proportionality provided in the Services Directive. In addition, the adoption and, in particular, the
application of the general advice means that the competition in the market is distorted and that the
free movement of both goods and services is hindered.
Due to this, KOVFS 2019:3 should not be accepted as a technical regulation.
You are welcome to contact me if you have any questions.
Wish you a nice weekend.
Best regards,
Swedish Trade Federation
Regeringsgatan 60
103 29 Stockholm
+46
(direkt)
+46
(mobil)
+46 10-47 18 500 (växel)
Svensk Handel behandlar dina personuppgifter i enlighet med GDPR.
Här kan du läsa mer om vår behandling och dina rättigheter. Fo
r info: https://ec.europa.eu/internal_market/imi-net/repositories/services-directive-
notifications/index_en.htm. You can submit comments to COM (DG GROW E1)
Sweden
Service sectors
Status of
Notification
Requirement
concerned
the act
Date
National
Further
Applicability
reference
Information
number
Business services, Retail, Another obligation imposed on cross border service
Final
07/01/2020
Other providers
Both establishment and cross-
KOVFS
Further
border provision of services
2019:3
Information
| EuroCommerce
, Single Market, Digital and Consumer Policy
T : +32 2
- M : +32
- www.eurocommerce.eu
Check our latest ideas to improve the Single Market