Joint EBF and FEP Contribution to the European Commission Consultation on the future EU Culture Programme

The European Booksellers Federation (EBF) and the Federation of European Publishers (FEP) have sent a common answer in reply to the European Commission’s consultation on a new EU Culture Programme after 2013.

In their joint paper, EBF and FEP underline the importance of a healthy European book chain and suggest the creation of a European Book Office (“EBO”). EBO’s role would be to facilitate access to information on the Culture programme to the book chain. Essentially, the EBO would play a key role in promoting cultural diversity and European literature. Its mission would be make sure that the work of emerging authors celebrated by the EUPL, as well as high quality literature, would reach as many European citizens as possible, with the collaboration of authors, publishers and booksellers representatives.

In its contribution, EBF underlines that booksellers are both commercial entities, employing over half a million people in Europe, and cultural agents, providing the public with unbiased, reliable and informed advice and promoting literacy and reading – the fundamental basis of a knowledge society.  Once more, EBF stresses the importance of a fair level field for commercial and non-commercial actors and of a relentless fight against piracy.

EBF lists 3 the priority actions for the next culture programme:

1. Support the promotion of cultural and linguistic diversity

2. Support Exchange of Best Practices and Risk Taking

3. Support Innovation and Fight Piracy

Priority actions from EBF for the Commission to consider

1. Support the promotion of cultural and linguistic diversity (answer to questions 3.10, 3.12 and 3.13 of the questionnaire)

EBF strongly recommends that the new Culture Programme include a chapter on supporting linguistic diversity, implemented in particular through grants schemes for the translation of books, as this has already been the case in the current Culture Programme. In this respect, EBF would suggest a few adaptations, like the reinforcement of the fast track process for the EUPL winners to obtain translation grants, in order to make the book available in the book market in a timely way, and to take advantage of the novelty factor.

EBF would further recommend that grants to small language markets could be adapted in order to compensate for the higher financial risks that publishers take when investing resources in the translation of a book that has limited potential sales (e.g. because of being published in a restricted language area). In this specific case, grants for literary translation could allow other costs to be included, such as the purchasing of rights and other costs (as asked in the questionnaire under question 3.13).

EBF would further recommend to the Commission to broaden the criteria for admission to translation grants, so as to include non-fiction works.

Translating a book into another language, however, does not yet make a book widely known across linguistic borders. The translated book also has to be promoted and marketed and finally “hand sold” by booksellers.

EBF therefore recommends to the Commission that it extend its translation support scheme to a dissemination/promotion scheme for translated books, as asked in Question 3.13a. Such a scheme would offer a financial grant to bookshops willing to promote non-national, European emerging authors whose works have been translated into other European languages.

Promoting authors who lack visibility and who have books that report a low stock turn on booksellers’ shelves is not easy for booksellers who need to implement profitable business models. Offering financial support to book retailers who promote emerging, translated authors, would contribute to the dissemination of the rich European literary heritage, both European-wide and globally. Such support should at least cover the travel and accommodation expenses of the authors promoted, as well as the production of promotion material.

The dissemination/promotion scheme could also be linked to a “European Quality Bookshop Label” project, which would be welcomed by EBF and its members. In practical terms, to launch such a process, EBF would favour a selective, step-by-step approach, whereby a sample of bookshops, carefully identified by EBF and its member BA’s, would participate in a first pilot project to test the European bookshop label system. Based on the experience gained, these bookshops could then assist the Commission in defining the exact criteria and other practicalities for a larger, EU-wide scheme. The participating bookshop would have to fulfil a certain number of criteria (including the requirement to sell a given percentage of non-national literature) in order to be entitled to apply for the label.

However, when setting up a European quality bookshop label scheme, it is important to make sure that from the outset, the application process is not too burdensome for the bookshops involved, so as not to discourage potential applicants.

Another way of promoting linguistic diversity could be through support for the translation of selected book excerpts, intended for book professionals outside the national markets and outside the EU (publishers, agents etc.) – as asked in the questionnaire under question 3.13. Such material could be distributed during Book Fairs at dedicated events involving rights directors.

2. Support Exchange of Best Practices and Risk Taking (answer to questions 3.1 and 3.2. of the questionnaire)

For book trade professionals – who act as cultural agents by promoting literacy and knowledge – it is essential to keep abreast continuously with and adapt to the numerous technology and market developments as well as to changing consumer behaviour.

To help booksellers to adapt to the changing environment, to adopt new skills and to create new business models, EBF could see a real added value in setting up mechanisms for the exchange of best practices between booksellers from different countries.

EBF, as the European body representing booksellers, could play an active role in the facilitation of such an exchange, for instance by collecting and disseminating ideas and best practices (as an example, how best to promote guidebooks) or by organizing conferences dedicated to the exchange of knowledge and professional experience.

The support of the Culture Programme to such facilitation exercises would be most welcome and beneficial.

3. Support Innovation and Fight Piracy (answer to questions 3.5 and 3.6 of the questionnaire)

Digital bookselling has long become a reality and many terrestrial bookshops have engaged in online selling. Selling e-books and reading devices is a further step that booksellers are in the process of achieving, often via third parties who provide portal facilities, webshops, etc. Online e-book distribution platforms have been set up by booksellers, in partnership with aggregators and publishers, in various EU countries. All these initiatives require substantive investments, both in terms of finance and time (training). The support of the Culture Programme in this area would be an excellent means to implement one of the flagships of the EU2020 Strategy, the Digital Agenda. In this regard the support that booksellers and other book trade professionals need from the European Commission is the certainty that they can rely on a solid legal guarantee in terms of (a) respect of copyright and on (b) a commitment from the European Union and its Member States to fight against piracy of copyright and intellectual property.

EBF would therefore welcome a focussed anti-piracy campaign under the new Culture Programme.

Additional remark on possible new support activities in the next Culture Programme (answer to question 3.15 of the questionnaire)

EBF, together with the Federation of European Publishers and the European Writers’ Council, has been involved in the organisation of the first two editions of the European Union Prize for Literature (EUPL).

EBF believes strongly that the EUPL is a prominent instrument to put cultural diversity in the spotlight and to promote emerging talents from all the countries in Europe. Although the Prize is still quite young, it has great potential in attracting the interest of the specialist press and of the reading community at large.

However, all Prizes need time to acquire visibility and EBF believes that it is important that the Culture Programme does not engage in new Prizes, as this would eventually lead to a dispersion of attention and resources – as well as a weakening of the expected results.

For further information, please contact eurobooks@skynet.be

A proposal to apply what its sponsors called a “cultural flat rate” was defeated recently in the European Parliament. The cultural flat rate is a proposed tax on all internet users. The funds thus raised would be administered by a collective body (less its administration costs) and disbursed to rights holders to compensate them for piracy and other breaches of copyright. The Federation of European Publishers and the European Booksellers Federation welcome the defeat of this proposal.

It offends free market principles and the practice of copyright law.

The cultural flat rate is inconsistent with the principles of democracy and a free market economy.
In a free market economy, markets are regulated by the contracting parties. Some businesses, such as financial services or airlines and telecoms, require a third party regulator to supervise their activities because of the potentially excessive risks that they run. No such regulation has ever been required in the book trade. Any proposal to introduce a cultural flat rate would have the effect of creating such a regulatory regime. Since no such regime has existed in the past, only the most overwhelming case for change should inform such an innovation. We believe that there is no such overwhelming case. A cultural flat rate, which would necessarily require control by a public authority or a collective body, is at odds with the normal workings of the free market. It would take away from authors and publishers the right to control the use of their works.
The book trade has been an exceptional guarantor of democracy. An independent book trade is vital to the formation of a mature public opinion and the advancement of intellectual life. The independence of the book trade is a distinguishing feature of free societies and is a notable absence in repressive ones. In this an independent, self regulating book trade is as vital to democracy as a free press. The vast range of ideas, opinions and knowledge disseminated through the European book trade represents a key strand in our free democracy.
Publishers and booksellers guarantee a quality chain which delivers to citizens a cornucopia of riches across an almost endless spectrum of human activity. Any proposed measure which might compromise this successful regime should only be undertaken for the gravest reasons. In what follows, we hope to demonstrate that such reasons do not exist in this instance

The cultural flat rate is not economically viable

For publishers to continue to publish books and booksellers to sell them there must be a return on investment. The current turnover of the European publishing industry exceeds €45 billion by retail value.
A tax of €100 a year applicable to each of the 500 million EU citizens (which would therefore include all those under age) would generate a gross amount of €50 billion, just a few billion more than the actual turnover of the publishing industry for all cultural goods available in book shops or online. One of the functions of any body managing the collection of a cultural flat rate tax would be to distribute this sum to rights holder, having first deducted its own fee for the service provided. The residue would then be redistributed to rights holders, authors and publishers. Add to this the turnover of the other creative European industries – music, video, film etc. – and calculate how many more billion euro would be required to remunerate all the cultural industries. Then calculate what the annual tax on each citizen would be. It would be some hundreds of euro per capita per annum.
Moreover, it would be a poll tax falling equally on those with ability to pay and those without.

The cultural flat rate is unfair

The obvious unfairness of this poll tax hardly needs to be elaborated, but a number of issues are worth highlighting.

• EU citizens do not have equal access to the internet or to high speed broadband, yet the tax would be levied equally on the privileged and the disadvantaged.
• EU citizens in poorer countries would be taxed in the same way as citizens of wealthier ones.

• Citizens who buy online would pay twice, once through the yearly tax and every time they make a purchase online.

• Nearly half of all EU citizens do not buy or read books at all. They would therefore be taxed for a commodity which they never purchase. This will be equally true of other media.

• Even among readers, the tax would discriminate against those who buy or read only a few books a year as against those who are heavy readers.

Cultural flat rate assumes no bookshops

Publishers publish books and sell them through a variety of channels, bookshops being the most established ones. Even with the advance of e books and online book shops, no serious book trade analyst predicts the wholesale disappearance of the traditional bookshop. The proposal for a cultural flat rate, however, assumes that terrestrial booksellers will simply disappear and that the only offer made to the book-buying public is one that will be made online. This is hopelessly unrealistic. Even if it were to come to pass, it would impoverish our communities and lead to a poorer offer to consumers. The proposal for a cultural flat rate therefore assumes economic loss for publishers and booksellers with attendant job cuts. A proposal which is grounded in such an unrealistic assumption, and a malign assumption at that, deserves serious re-examination.

The cultural flat rate is a bad idea. It should never be revived.

Fergal Tobin, President FEP and John Mc Namee, President EBF

The full contribution can be found in attachment. 

The full contribution can be found in attachment. 

Click on the attachment to access the pdf-file.

Click on the attachment to access the pdf-file.

DON’T TAX READING !

The VAT rate applied to printed books by Member States throughout the European Union (EU) currently varies from 0% to 25%. The Customs and Taxation Directorate within the European Commission is currently developing plans to harmonise VAT rates throughout the EU. Indications suggest that in the future Member States may be instructed to allocate a VAT rate of not less than 15% on almost all products and services. However, EU countries may well be able to impose a reduced rate of not less than 5% on a small number of items, including printed books.

Grateful as we are to the possibility that printed books may be allocated a lower tax band, the European Booksellers Federation strongly believes that printed books should not be taxed at all throughout the EU in the future, and that under the harmonisation arrangements, any Member State that wishes to allocate a 0% VAT rate for printed books should be allowed to do so.

Moreover, EBF feels that electronic books should be treated in the same way. A printed book and electronic book of the same title will have the same content and purpose’.

WHY PRINTED AND ELECTRONIC BOOKS SHOULD NOT BE TAXED: FOR EUROPE AS A WHOLE

• · BOOKS are central to the acquisition of literacy, education and knowledge of all kinds: special and general, informal and formal, whether for adults or children, providing the basis of reading skills, inquiry, comprehension and individual enterprise.
• BOOKS build and transmit the culture, science and history of Europe. European identity lives through the written word.

0% VAT RATE ON BOOKS: BENEFITS FOR THE CONSUMER …

• Will lead to lower prices for BOOKS; lower prices will lead to more books purchased and to an increase in reading throughout the EU.
• Consumers will have greater access and choice from which to make BOOK purchases, as more bookshops will survive.
• Consumers will see a broader range of BOOKS in the shops.

0% VAT RATE ON BOOKS: FOR THE EUROPEAN ECONOMY …

• Will strengthen Europe’s economy by raising the level of education, literacy and life-long learning programmes.
• Will increase investment and employment within the book trade; a healthy sector will lead to greater tax revenues for the fiscal authorities.
• Will encourage risk taking and innovation by publishers and booksellers.

DON’T TAX READING!

Given the positive impact and the benefits of a 0% rate of VAT for (i) Europe as a whole (ii) the consumer and (iii) the European economy, the European Booksellers Federation urges that in any harmonisation plans developed by the Commission, any Member State of the EU that wishes to allocate a 0% VAT rate for books should be allowed to do so.

This position is supported by the Council of Europe and UNESCO.

26 November 2002.