EN
OPINION OF THE EUROPEAN CENTRAL BANK
of 30 April 2002
at the request of the Finnish Ministry of Finance
on a draft proposal concerning the rounding of payments denominated in euro
(CON/2002/15)
1. On 2 April 2002 the European Central Bank (ECB) received a request from the Finnish Ministry
of Finance for an opinion on a draft Government proposal concerning an amendment to theFinnish Act on the rounding of payments denominated in euro (hereinafter referred to as theproposal). The proposal intends to amend the Laki euromääräisten maksujen pyöristämisestä
890/2000 (the Finnish Act of 27 October 2000 on the rounding of payments denominated in
euro, hereinafter referred to as the Rounding Act) by providing that payments effected by abank card or other payment cards may be rounded to the nearest five cent.
2. The ECBs competence to deliver an opinion is based on Article 105(4) of the Treaty
establishing the European Community and first and second indents of Article 2(1) of CouncilDecision 98/415/EC of 29 June 1998 on the consultation of the ECB by national authoritiesregarding draft legislative provisions
1, as the proposal contains a provision concerning currency
matters and means of payment. In accordance with the first sentence of Article 17.5 of the Rulesof Procedure of the European Central Bank, the Governing Council of the ECB has adopted thisopinion.
3. According to the Rounding Act, in Finland ca sh payments denominated in euro are rounded
downwards or upwards to the nearest multiple of  five euro cent. The principal aim of the
Rounding Act is to restrict the use of one and two cent coins for cash payments. The reasoning
for the Rounding Act was that the minting of one and two cent coins was not cost-effective,since the production costs of one and two cent coins greatly exceed their face value.Furthermore, the use of these coins would excessively increase the costs for both authorities andbusinesses in handling and supplying coins.
4. According to the proposal, the current situation in which only cash payments have been rounded
has led to uncertainties with regard to the in terpretation of the Rounding Act. Therefore it is
proposed to extend the rounding rules for euro cash payments to cover also payments effectedby bank or other payment cards.
                                                     
1 OJ L 189, 3.7.1998, p. 42.
25. Since the ECB was not consulted at the time of adoption of the Rounding Act, the ECB takes
the opportunity to provide its opinion not only on the proposal but also on the Rounding Actcurrently in force in Finland.
6. The ECB notes that the current Rounding Act does not alter the legal tender status of one and
two cent coins in Finland. Nevertheless, taking into account the aims and principles of the singleEuropean coinage system established by the adoption of the euro, the ECB would like toemphasise that the Rounding Act should in any case not prevent the one and two cent coinsfrom being used as a means of payment, as they are de jure  legal tender in the entire euro area.
Member States' legislation should not lead to divergent treatment of the euro. 
7. Furthermore, the ECB notes that, while the principal aim of the Rounding Act was to restrict the
use of one and two cent coins for cash payments, the proposal now intends to extend therounding rule to cover other payments that are not cash payments, i.e. to payments by bank orother payment cards. The reasoning for the original Rounding Act was that these lowdenomination coins are impractical and excessively increase the cost of money supply inFinland. The ECB would like to remark that such reasoning does not apply to the rounding ofpayments effected by a bank or other payment cards.
The proposed extension of the rounding rule to payments with bank or other payment cardscreates the risk that this rule might not comply with Community law, in particular with Article 2of Council Regulation (EC) No 974/98 of 3 May 1998 on the introduction of the euro
2 (as
amended). The ECB considers it important for the competent Community institutions to assessthe compatibility of the proposed rule with Community law.
8. Finally, the ECB would welcome a provision in the proposal requiring a clear and
comprehensible indication to the consumer fulfilling payment obligations of the roundingpursuant to the Rounding Act. Therefore, th e rounding downwards or upwards of the amount
due to the nearest multiple of five euro cent shou ld be expressly stated in the invoice, receipt or
in another proof of payment. 
                                                     
2 OJ L 139, 11.5.1998, p. 1.
39. The ECB confirms that it has no objection to the competent national authorities making this
opinion publicly available at their discretion.
Done at Frankfurt am Main on 30 April 2002.
The President of the ECB
[signed]
Willem F. DUISENBERG