G/STR/N/19/EU  
 
30 June 2022  
(22-5056) Page: 1/12 
Working Party on State Trading Enterprises  Original: English  
 
STATE TRADING  
NEW AND FULL NOTIFICATION PURSUANT TO ARTICLE XVII:4(A) OF THE  
GATT 1994 AND PARAGRAPH 1 OF THE UNDERSTANDING ON  
THE INTERPRETATION OF ARTICLE XVII  
EUROPEAN  UNION   
The following communication, dated and received on 28 June 2022, is being circulated at the request 
of the delegation of the European Union.  
 
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Pursuant to Article XVII:4(a) of GATT 1994 and paragraph 1 of the Understanding on the 
Interpret ation of Article XVII of the GATT 1994, and in response to the call for notifications set forth 
in document G/STR/N/1 9, the European Union notifies the following state trading enterprises.  
I. ENUMERATION OF STATE TRADING ENTERPRISES  
A. Identification of state trading enterprises  
Systembolaget AB.  
B. Description of products affected (including tariff item number(s) encompassed in 
product description)  
Alcohol beverages (spirituous drinks, wines, strong beer and other fermented alcoholic  beverages) 
and non -beverage alcoholic preparations (Sw. alkoholdrycksliknande preparat).  
II. REASON AND PURPOSE  
A. Reason or purpose for establishing and/or maintaining state trading enterprise  
Systembolaget AB is a state -owned limited company that cond ucts retail sales of alcoholic beverages 
and as from 1 July 2019 also non -beverage alcoholic preparations, to the general public in Sweden; 
a retail monopoly. The reason for the monopoly is that the alcohol -related problems are reduced if 
alcohol is sold i n the absence of a profit motive. Systembolaget aims to reduce the total alcohol 
consumption by limiting availability. Systembolaget further strives to help limit the medical and 
social harm caused by alcohol, and thereby improve public health.  
B. Summary  of legal basis for granting the relevant exclusive or special rights or privileges, 
including legal provisions and summary of statutory or constitutional powers  
Systembolaget's mandate is governed by the Swedish Alcohol Act (2010:1622), by Systembolaget' s 
contract with the government (2019:552) and by the directives issued by the government in its 
capacity as the owner of Systembolaget.  G/STR/N/19/EU  
 
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  III. DESCRIPTION OF THE FUNCTIONING OF THE STATE TRADING ENTERPRISE  
A. Summary statement providing overview of operatio ns of the state trading enterprise  
Systembolaget has a nationwide retail network comprising approximately 450 stores and 475 agents 
(in smaller communities with an insufficient customer base for a store of their own). The agents act 
for and by authority fr om Systembolaget; they are not themselves selling the items but instead 
delivering the items on behalf of Systembolaget. The agents account for approximately 1% of 
Systembolaget's turnover and carry no items in stock, instead the consumers order the goods for 
collection. Systembolaget is responsible for ensuring that people shall have the option of purchasing 
alcoholic beverages and non -beverage alcoholic preparations wherever they may live in Sweden and 
thus Systembolaget is represented in all municipaliti es in Sweden. The Swedish Parliament sets the 
guidelines for the opening hours of Systembolaget's stores.  
According to Systembolaget's contract with the government, Systembolaget shall inform the public 
in Sweden about the risks combined with the consumpt ion of alcoholic beverages and non -beverage 
alcoholic preparations. This undertaking is also mentioned in Systembolaget's Articles of Association. 
As one way of fulfilling this undertaking, Systembolaget has formed the subsidiary IQ -Initiativet AB. 
IQ-Initiativet works to persuade people to reflect on their attitudes towards and behaviour in relation 
to alcohol. The aim is to reduce alcohol consumption and thereby the harm caused by alcohol.  
B. Specification of exclusive or special rights or privileges enjo yed by the state trading 
enterprise  
Systembolaget holds the retail monopoly for alcoholic beverages and non -beverage alcoholic 
preparations in Sweden.  
C. Type of entities other than the state trading enterprise that are allowed to engage in 
importation/exp ortation and conditions for participation  
As stated above, Systembolaget holds the retail monopoly for alcoholic beverages and non -beverage 
alcoholic preparations in Sweden.  
Other (non -state) entities are allowed to import and export alcoholic beverages. As described in 
section III.H below, wholesale activities may be conducted by an authorised warehouse keeper or 
registered consignee of alcoholic goods.  
D. How import/export levels are established by the state trading enterprise  
Systembolaget may not expo rt any alcohol to other countries. Systembolaget is only entitled to 
import alcohol upon the request of individual consumers and provided that the product is not already 
included in Systembolaget's range. If a customer wishes to buy a product that is not i ncluded in the 
range, Systembolaget shall according to the Swedish Alcohol Act import the product requested by 
the customer within the framework of Systembolaget's private import service.  
E. How export prices are determined  
As stated above, Systembolaget m ay not export any alcohol according to the Swedish Alcohol Act.  
F. How the resale prices of imported products are determined  
The resale price of an imported product from Systembolaget's supplier, at Systembolaget, is 
determined by adding the following mar k-ups to the supplier's price to Systembolaget before Excise 
Duty on Alcohol and, if applicable, recycling fee : (i) a variable mark -up (currently 17%) and (ii) a 
fixed mark -up (that is added on all items sold by Systembolaget and varies according to type of 
item). Excise Duty on Alcohol and, if applicable, recycling fee, as well as VAT is then added.  G/STR/N/19/EU  
 
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  G. Whether long -term contracts are negotiated by the state trading enterprise. Whether 
the state trading enterprise is used to fulfil contractual obligations entered into by the 
government  
Systembolaget has, as explained under section II.B, a contract with the government (Sw. 
Tillkännagivande (2019:552) av avtal mellan Systembolaget Aktiebolag och staten) dated 19  June 
2019.  
As Systembo laget is a monopoly; it is obliged to treat all suppliers of spirituous drinks, wines and 
strong beer and non -beverage alcoholic preparations in a non -discriminatory manner. The principle 
of non -discrimination means that Systembolaget must apply the same t erms and conditions to all 
such suppliers at any given time, and is not at liberty to negotiate the wording of them with one or 
several individual suppliers. The purchasing terms are reviewed – and updated – in general twice 
each year in accordance with a pre-set procedure.  
H. Brief description of market structure  
Systembolaget has a monopoly for off -premise retail sale in Sweden - for all alcohol beverages and 
non-beverage alcoholic preparations containing more than 2.25% alcohol by volume (with the 
exception of beer where the limit is 3.5% by volume). Beer with alcohol content between 2.8 % and 
3.5% by volume is taxed in Sweden by the same general rules as stronger beer whereas beer 
containing 2.8% or less alcohol by volume is exempted from alcohol taxati on. Beer with no more 
than 3.5% alcohol by volume can be sold in general stores and gasoline stations also selling food 
(and do not need a special license). Further, on -premise sale of alcoholic beverages takes place in 
restaurants, bars and cafés. A speci al license is required for on -premise sales of alcoholic beverages 
stronger than 3.5% alcohol by volume.  
The Alcohol Act permits wholesale trade in spirit drinks, wine, strong beer and other fermented 
alcoholic beverages as well as non -beverage alcoholic preparations to the retail monopoly, holders 
of serving licenses and other wholesalers. Wholesale activities may be conducted by an authorized 
warehouse keeper or registered consignee of alcoholic goods. The authorization and registration is 
conducted by t he Swedish Tax Agency. A seller and/or importer of alcoholic products that are not 
beverages such as for example denatured alcohol used for cooking, food additives and/or food 
products such as "pears in cognac" must notify the Public Health Agency of Swede n of its business.  
The legal age limit for buying alcoholic beverages in Systembolaget stores is 20 years. The legal age 
limit for buying beer in general stores is 18 years. The legal age limit for on -premise purchase of 
alcoholic beverages is 18 years fo r all alcoholic beverage categories.  
IV. STATISTICAL INFORMATION (SEE ATTACHED TABLES I - III)  
V. REASON WHY NO FOREIGN TRADE HAS TAKEN PLACE (AS APPROPRIATE)  
According to the Swedish Alcohol Act, Systembolaget may not export alcoholic beverages.  
VI. ADDITIONAL INFORMATION (AS APPROPRIATE ) 
  G/STR/N/19/EU  
 
- 4 - TABLE I  
STATE TRADING: SYSTEMBOLAGET AB  
STATISTICAL INFORMATION – IMPORTS: 2020 -21 
Year  Description of product(s) 
including HS  Total quantity 
imported 
(litres)  Quantity imported 
by state trading 
enterprise (litres)  Average import price 
(SEK incl. VAT)  Average representative 
domestic sales price 
(SEK incl. VAT)  Mark -up National 
production1 
1 2 3 4 5 6 7 
2020 Alcoholic beverages; spirituous 
drinks, wines and beer  332.098.673  194.256  462,27  80,63  n/a  444.000.000  
2021 333.798.794  200.487  510,29  82,56  n/a  n/a  
 
  
 
1 Statistics compiled by the Swedish National Institute of Public Health.   
  G/STR/N/19/EU  
 
- 5 - TABLE II  
STATE TRADING: SYSTEMBOLAGET AB  
STATISTICAL INFORMATION, EXPORTS  
NOT APPLICABLE2 
Description of product(s)  
(including HS number(s))  Total quantity 
exported3 Quantity exported 
by 
state trading 
enterprise3 Average 
procurement 
price4 Average 
representative  
domestic sales price  Average export 
price  National 
production  
1 2 3 4 5 6 7 
 
  
 
2 According to the Alcohol Act, Systembolaget may not export alcoholic beverages.  
3 In cases where no exports have taken place under columns 2 or 3, provide an explanation under Sect ion V of this questionnaire.  
4 In cases where the initial procurement price is augmented by other payments, additional payments should also be reported.   
  G/STR/N/19/EU  
 
- 6 - TABLE III  
STATE TRADING: SYSTEMBOLAGET AB  
STATISTICAL INFORMATION - DOMESTIC ACTIVITIES: 2020 – 21 
Year  Description of product(s)  
including HS numbers  Domestic purchases by  
state trading enterprise  
(SEK excl. Excise Duty on Alcohol)  National production 
(litres)5 Domestic sales 
(litres)  
by state trading 
enterprise  National 
consumption6 
 1 2 3 4 5 
2020 Alcoholic beverages; 
spirituous drinks, wines  
and beer  17.778.808.590  233.873.230  565.973.738  61.457.000.000  
2021 18.691.705.639  239.968.242  573.775.217  n/a 
 
 
5 Sales by Systembolaget of nationally produced items.  
6 n/a = National consumption 2021; statistics  as compiled by the Swedish National Institute of Health is not available yet. The latest figure concerns statistics 
regarding year 2020.  G/STR/N/19/EU  
 
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  I. ENUMERATION OF STATE TRADING ENTERPRISES  
A.  Identification of state trading enterprises  
Alko Oy (Alko Inc.).  
B. Description of products affected (including tariff item number(s) encompassed in 
product description)  
Alcoholic beverages (spirituous drinks, wines and strong beer over 5.5%).  
II. REASON AND PURPOSE  
A. Reason or purpose for establishing and/or maintaini ng state trading enterprise  
Alko Inc. is a state -owned limited company having an exclusive right (monopoly) stipulated in the 
Finnish  Alcohol Act to the retail sale of alcoholic beverages containing over 5.5% alcohol.  
Alko's monopoly and operations are b ased on the social and health policy objective of mitigating the 
adverse effects of alcohol consumption. The objective of the operations of Alko Inc. is to limit alcohol 
consumption and alcohol -related harms. The company is steered and supervised by the Mi nistry of 
Social Affairs and Health.  
B.  Summary of legal basis for granting the relevant exclusive or special rights or privileges, 
including legal provisions and summary of statutory or constitutional powers  
Alko's mandate is governed by the Finnish Al cohol Act (1102/2017) and the Government Decree on 
the enforcement of the Alcohol Act (151/2018).  
Alko Inc. belongs to the administrative branch of the Ministry of Social Affairs and Health and the 
State's special assignment companies, "which have been as signed a certain task by the State".  
III. DESCRIPTION OF THE FUNCTIONING OF THE STATE TRADING ENTERPRISE  
A. Summary statement providing overview of operations of the state trading enterprise  
The sole purpose of Alko  Inc. is to organize retail sales of above mentioned alcoholic beverages. It 
has a nationwide retail network comprising 356 stores and 60 order points.  
The aim of the arrangement is to reduce alcohol consumption and thereby the harm caused by 
alcohol in s everal ways:  
• the system limits physical availability of alcoholic beverages (the amount and the opening 
days and hours of retail stores);  
• the system limits marketing and sales promotion activities of alcoholic beverages in Alko's 
retail customer service (however Alko Inc. does not restrict the possibilities of producers and 
importers to advertise their products independently outside Alko's premises); and  
• the system safeguards responsible sales of alcoholic beverages (informing the public about 
the health  risks of alcohol consumption, ensuring age checks and no sales to intoxicated 
persons).  
B.  Specification of exclusive or special rights or privileges enjoyed by the state trading 
enterprise  
Alko Inc. has the exclusive right to the retail sale specified  in the Alcohol Act for above mentioned 
alcoholic beverages in Finland. Alko's exclusive right for retail sale does not cover any restrictions of 
import or export of alcoholic beverages, but it forbids any other retail sale of alcoholic beverages to 
consum ers in Finland regardless of the origin of the seller.  G/STR/N/19/EU  
 
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  C. Type of entities other than the state trading enterprise that are allowed to engage in 
importation/exportation and conditions for participation  
According to the Alcohol Act all domestic and foreign enterprises, which include at present Alko Inc. 
itself, about 200 producers, about 360 wholesalers of alcoholic beverages, about 6,400 retail shops 
selling alcoholic beverages of 2.8 % to 5.5% and about 9,600 on premise restaurants, have the right 
to import  and export alcoholic beverages without any licenses or quotas.  
However, Alko Inc holds the monopoly for retail sale of alcoholic beverages above 5.5%. 
Furthermore, the 6,400 retail shops selling alcoholic beverages of 2.8 % to 5.5% and the 9,600 
on-premis e restaurants need a license to sell alcoholic beverages to customers in Finland. No licence 
is needed for the sale of alcohol beverages of less than 2.8% to customers in Finland.  
D.  How import/export levels are established by the state trading enterpris e  
The sole purpose of Alko Inc. is to organize retail sales of above mentioned alcoholic beverages.  
Any domestic or foreign producer or seller of alcoholic beverages may apply for a listing of the 
product to Alko's general selection (currently 7,600 prod ucts are displayed and sold in the stores). 
Procedures for listing alcoholic beverages for retail sale in Alko apply similarly for domestic and 
foreign operators. Information is published in Alko's website:  
https://www.alko.fi/en/alko -inc/for -suppliers/  
Additionally any domestic or foreign producer has the right to list their products to Alko's 
sale-to-order selection (currently 3,800 products to be transported to the nearest store for the 
consumer) by announcement only. Alko Inc. does not affect or limit the quantities of alcoholic 
beverages to be sold in general selection or sale -to-order selection , i.e. the products may stay in 
the selection as long as customers want to buy them.  
Alko Inc. d oes not export any alcoholic beverages.  
E.  How export prices are determined  
Alko Inc. does not export alcoholic beverages; hence it does not influence their pricing.  
F.  How the resale prices of imported products are determined  
The retail prices of all domestic and imported products are determined in equal terms by adding the 
following mark -ups to the "back -door price" determined by the supplier:  
• Alko's margin ( coefficients for different beverage categories currently between 1,50 and 
1,81);  
• possible bottle or can deposit;  
• excise duty calculated according to the Council directive 92/83/EEC1 of 19 October 1992  on 
the harmonization of the structures of excise duties on alcoho l and alcoholic beverages;  
• environmental tax on retail containers; and  
• VAT, 24%.  
Alko's margins and other pricing information are openly published in Alko's website:  
https://www.alko.fi/en/alko -inc/for -suppliers/prices/price -calculator   
If a foreign producer does not want to deliver the products to Alko shops, it may use any 
contractor/importer to do this or request the service from Alko (freight, insurance, warehou se and 
shop delivery costs are added).  
 
1 O.J. L 316, 31.10.1992:  
http://eur -lex.europa.eu/legal -content/EN/TXT/?qid=1491894841970&uri=CELEX:31992L0083  G/STR/N/19/EU  
 
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  G. Whether long -term contracts are negotiated by the state trading enterprise. Whether 
the state trading enterprise is used to fulfil contractual obligations entered into by the 
government  
According to 25§ of the Alc ohol Act (1102/2017), it is obliged to treat all domestic and foreign 
beverage suppliers equally. The principle of equal treatment means that Alko Inc. must apply the 
same terms and conditions to all beverage suppliers at any given time, and is not at libe rty to 
negotiate different terms with one or several individual suppliers.  
The general purchasing terms are reviewed and updated twice each year.  
 H.  Brief description of market structure  
Alcoholic beverages, including spirituous drinks, wines and stro ng beer, over 5.5% are sold to 
customers in 373 Alko shops. Additionally Alko has around 150 delivery points in the rural areas, 
where customer's orders are transported to be picked by customers (no beverages on display in 
delivery points).  
Alcoholic beve rages of 2.8 % to 5.5% are sold to customers in about 6,400 licensed retail grocery 
shops and all beverages under 2.8% freely without any license requirements.  
All alcoholic beverages are served to customers in about 9 ,600 licensed restaurants and pubs.  
The total number of alcohol products in the market is around 21 ,500.  
IV. STATISTICAL INFORMATION (SEE ATTACHED TABLES I - III)  
V. REASON WHY NO FOREIGN TRADE HAS TAKEN PLACE (AS APPROPRIATE)  
Not applicable.  
VI. ADDITIONAL INFORMATION (AS APPROPRIATE) 
  G/STR/N/19/EU  
 
- 10 - TABLE I  
STATE TRADING: ALKO INC.  
STATISTICAL INFORMATION, IMPORTS 2020 - 21 
Description of 
product(s)  
(including HS 
number(s))  Total quantity 
imported (litres)  Quantity imported by 
state trading 
enterprise  
(litres)  Average import 
price  Average representative 
domestic sales price  Mark -up National production 
(litres)  
1 2 3 4 5 6 7 
Alcoholic 
beverages  2020: 142 136 303  
2021: 141 113 013  2020: 1 528 145  
2021: 1 554 572* 2020: 16 .01 EUR/l 
2021: 16 .37 EUR/l  2020: 2.35 EUR  
2021: 2.42 EUR  2020: 530 969 449  
2021: 527 753 070  
*  This amount corresponds to the imported alcoholic beverages by Alko, as requested  by the foreign seller. (Alternatively all foreign producers and sellers have 
the right to import alcoholic beverages to Finland by themselves without any prior licenses or quotas – see III C.).    
  G/STR/N/19/EU  
 
- 11 - TABLE II  
STATE TRADING: ALKO INC.  
STATISTICAL INFORMATION, EXPORTS  
NOT APPLICABLE  
Description of 
product(s)  
(including HS 
number(s))  Total quantity 
exported  Quantity exported 
by  
state trading 
enterprise  Average 
procurement price  Average 
representative  
domestic sales price  Average ex port 
price  National production  
1 2 3 4 5 6 7 
 
   
  G/STR/N/19/EU  
 
- 12 - TABLE III  
STATE TRADING: ALKO INC  
STATISTICAL INFORMATION, DOMESTIC ACTIVITIES 2020 - 21 
Description of product(s)  
(including HS number(s))  Domestic purchases by  
state trading enterprise  National production  
(litres)  Domestic sales by  
state trading enterprise  
(litres)  National consumption 
(litres)  
1 2 3 4 5 
Alcoholic beverages  2020: 92 726 921  
2021: 89 039 047  2020: 550 300 000  
2021: 555 100 000  2020: 92 726 921  
2021: 89 039 047  2020: 550 518 000  
2021:  555 145 000  
 
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