Ref. Ares(2020)3968922 - 28/07/2020
Friday, April 24, 2020 3:48 PM To:
VB: Swedish services notification - THE SWEDISH CONSUMER AGENCY'S GENERAL ADVICE
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
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.
Swedish Trade Federation
103 29 Stockholm
+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.
For info: https://ec.europa.eu/internal_market/imi-net/repositories/services-directive-
u can submit comments to COM (DG GROW E1)
Business services, Retail,
Another obligation imposed on cross border service
Both establishment and cross-
border provision of services
, Single Market, Digital and Consumer Policy
T : +32 2
- M : +32
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