Brussels, 19 March 2024
Today in Europe, most merchants continue to offer consumers the option to pay in cash, despite a consistent decrease in the use of this payment method in everyday transactions. The principle of mandatory acceptance of Euro cash by merchants is therefore unnecessary, yet it may pose great difficulties in specific use cases. As a group of European organisations representing the interests of millions of merchants across Europe in key sectors of the economy, we call on the co-legislators to ensure that any such obligation to accept Euro banknotes and coins be supported by a pragmatic list of exemptions.
The co-legislators must extend the list of exemptions (Article 5(2)) to:
- Premises with unmanned (electronic) check-outs. Thanks to technological development, it is now becoming commonplace to open small retail shops with no cashier, with longer opening hours to serve customers in specific locations. Similarly, there are unmanned fuel stations, EV chargers and vending machines. In such instances, it is impossible to accept cash.
- Situations with high security/robbery risks: Shopkeepers in areas with high crime rates may often be exposed to robberies, aggression and physical or psychological harm. For their and their consumers’ safety, shopkeepers should legitimately be allowed to decline cash acceptance, as the only means of avoiding the recurrence of such violent and traumatic events. Similarly, maintaining a cash acceptance infrastructure for services onboard aircraft raises several important security and practical concerns.
- Specific situations where cash handling/acceptance entails disproportionate costs: Merchants should have a right to choose the payment methods they offer based on their prevalence and their costs. The cost of cash handling depends on several factors, including the frequency of cash used in daily payments, the cash supply costs, the type of business and its location. For instance, maintaining cash payments in remote areas with limited infrastructure (to obtain cash and for deposits), may prove to be disproportionately expensive. Another concern is the acceptance of cash aboard aircraft, which is extremely cumbersome given the logistic aspects of traveling to multiple/remote airports. When customers overwhelmingly favour digital payments and cash payments amount to only a very small minority of payments, the costs of cash handling can be disproportionately high.
To this end, we call upon the co-legislators to:
- Support amendment 84, extending the exemption in case of significant security risks;
- Introduce an exemption for payees operating unmanned self-check-outs;
- Introduce an exemption when payees would incur genuinely disproportionate costs for accepting cash compared to the cost of digital payments;
- Introduce an explicit exemption for onboard aircraft transactions.
- Maintain the current possibility of an ex-ante unilateral exclusion of the acceptance of cash payments (i.e. ‘no cash’ signs), as long as it does not undermine the role of cash as a legal tender in a given territory.
We count on your support to reach a balanced position and we remain open to further discussing these issues with you.
Ecommerce Europe is the sole voice of the European Digital Commerce sector. It represents, via its national associations, more than 150,000 companies selling goods and services online to consumers in Europe. Ecommerce Europe acts at European level to help legislators create a better framework for online merchants, so that their sales can grow further.
EuroCommerce is the principal European organisation representing the retail and wholesale sector. It embraces national associations in 27 countries and 5 million companies, including leading global players and many small businesses. Over a billion times a day, retailers and wholesalers distribute goods and provide an essential service to millions of business and individual customers. The sector generates 1 in 7 jobs, offering a varied career to 26 million Europeans, many of them young people. It also supports millions of further jobs throughout the supply chain, from small local suppliers to international businesses. EuroCommerce is the recognised European social partner for the retail and wholesale sector. More information on www.eurocommerce.eu/payments.
Independent Retail Europe is the European association that acts as an umbrella organisation for groups of independent retailers in the food and non-food sectors. Our members are groups of independent retailers, associations representing them as well as wider service organizations built to support independent retailers. Independent Retail Europe represents 23 groups and their 462.000 independent retailers, who manage more than 737.000 sales outlets, with a combined retail turnover of more than 1,385 billion euros and generating a combined wholesale turnover of 604 billion euros. This represents a total employment of around 6.400.000 persons.
The International Air Transport Association (IATA) is the trade association for the world’s airlines, representing some 300 airlines or 83% of total air traffic. We support many areas of aviation activity and help formulate industry policy on critical aviation issues.
SMEUnited is the association of crafts and SMEs in Europe with around 70 member organisations from over 30 European countries. SMEunited is a recognised employers’ organisation and European Social Partner and acts on behalf of crafts and SMEs in the European Social Dialogue and in discussions with the EU institutions.
Source – Eurocommerce