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Taxation Task Force update – September 2021


The European Commission published its Energy Taxation Directive (ETD) this summer. In the European Commission’s proposal:

  • lubricants are out of the scope (we asked to include lubricants in the scope with the aim to have a level playing field);
  • 2710 and 3403 are added to the EMCS article when moved in bulk, while we wanted EMCS only for light lubricants when moved in bulk;
  • 3811 are also added to the EMCS with no limitation to bulk.

UEIL will now lobby the EU Member States and the Members of the European Parliament to positively influence the draft ETD proposal of the European Commission.

Related to UEIL’s objective to prevent the inclusion of lubes under the Excise Movement and Control System (EMCS), certain EU Member States are concerned about increased fraud with lubes across Europe and are once again increasing the pressure to include lubes under EMCS. UEIL will continue its outreach to EU Member States in the coming weeks to express its concern and will discuss with the European Commission the option of a definition of ‘light lubes’ that might be included under EMCS in the near future.

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