BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 689
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          Date of Hearing:  April 20, 2009

                     ASSEMBLY COMMITTEE ON REVENUE AND TAXATION
                             Charles M. Calderon, Chair

            AB 689 (Charles Calderon) - As Introduced:  February 26, 2009
           
           4/5 vote.  Fiscal committee.

           SUBJECT  :  Cigarette and Tobacco Products Tax Law:  tobacco  
          products

           SUMMARY  :  Expands the definition of "tobacco products" contained  
          in both the Tobacco Tax and Health Protection Act of 1988  
          (Proposition 99) and the California Children and Families First  
          Act of 1998 (Proposition 10) to include any articles or products  
          made of or containing tobacco.  Specifically,  this bill  :

          1)Contains legislative findings noting that its provisions are  
            in furtherance of, and consistent with the purposes of, both  
            Proposition 99 and Proposition 10.

          2)Specifies that it does not require the reimbursement of any  
            local government costs under the California Constitution  
            because the only costs that may be incurred by a local agency  
            or school district are associated with creating a new crime or  
            changing the definition of a crime.  

           EXISTING LAW  :

          1)Provides, under both Proposition 99 and Proposition 10, that  
            the term "tobacco products" includes, but is not limited to,  
            "all forms of cigars, smoking tobacco, chewing tobacco, snuff,  
            and any other articles or products made of, or containing at  
            least 50 percent, tobacco"  excluding cigarettes.  

          2)Defines the term "cigarette" as "any roll for smoking, made  
            wholly or in part of tobacco, irrespective of size or shape  
            and irrespective of whether the tobacco is flavored,  
            adulterated or mixed with any other ingredient, where such  
            roll has a wrapper or cover made of paper or any other  
            material, except where such wrapper is wholly or in the  
            greater part made of tobacco and such roll weighs over three  
            pounds per thousand."  









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          3)Imposes a tax, under Proposition 99, upon the distribution of  
            tobacco products, based on the wholesale cost of these  
            products, at a tax rate equivalent to the combined rate of tax  
            imposed on cigarettes.

          4)Provides that Proposition 99 revenues are to be deposited in  
            the Cigarette and Tobacco Products Surtax Fund and used only  
            for specified purposes, including health education programs,  
            disease research, and medical care for specified patients.  

          5)Specifies that the provisions of Proposition 99 may only be  
            amended by a vote of four-fifths of the membership of both  
            houses of the Legislature.  

          6)Imposes an additional tax, under Proposition 10, on tobacco  
            products based on the wholesale cost of these products, at a  
            rate equivalent to the $0.50 per pack rate Proposition 10  
            imposes on cigarettes.

          7)Provides, under the California Constitution, that whenever the  
            Legislature or any state agency mandates a new program or  
            higher level of service on any local government, the State  
            shall provide a subvention of funds to reimburse that local  
            government for the costs of the program or increased level of  
            service.  No reimbursement, however, is required when the  
            costs are associated with legislation defining a new crime or  
            changing the existing definition of a crime.  

           FISCAL EFFECT  :  The Board of Equalization (BOE) estimates that  
          this bill will increase tobacco products revenues by roughly  
          $100,000 per year.  To the extent that new dissolvable tobacco  
          products enter the California market, revenue gains will be  
          higher by an unknown amount.  

           COMMENTS  :

          1)The author states:

                Current law defines the term "tobacco products" to include  
                any product that contains at least 50% tobacco.  In  
                today's marketplace, more products are being produced that  
                contain varying levels of tobacco.  Moreover, the state  
                must generally rely on manufacturer representations  
                regarding the percentage of tobacco in each product.   









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                AB 689 addresses this concern by creating a bright line  
                rule for purposes of imposing the tobacco tax.   
                Specifically, this bill revises the definition of tobacco  
                products to include any product that contains tobacco,  
                irrespective of the amount.  By eliminating an arbitrary  
                content threshold, this bill ensures that no tobacco  
                product will escape taxation.  
                    
          2)Proponents state, "AB 689 seeks to clarify existing law with  
            regard to application of some California taxes on tobacco  
            products.  Specifically, the bill would impose taxes  
            authorized by the Tobacco Tax and Health Protection Act of  
            1988 (Proposition 99) and the California Children and Families  
            First Act of 1998 (Proposition 10) on all products that  
            contain any amount of tobacco."  Specifically, proponents  
            state, "AB 689 will help provide certainty for tobacco  
            licensees, who are responsible for collecting the taxes and  
            remitting them to the State."  

          3)Opponents state, "[T]ax increases that single out a specific  
            industry or group to shoulder new taxes will kill good jobs  
            and harm industries essential to California's economy."   
            Opponents also state, "Of 57 state excise tax increases that  
            were implemented between 2003 and 2007, only 16 of them met or  
            exceeded the projected revenues."  Finally, opponents state  
            that, "AB 689 may result in new government programs and  
            spending that may become locked into the state budget."  

          4)Committee Staff Comments:

              a)   The current definition of tobacco products  :

               i)     In 1988, California voters passed Proposition 99,  
                 which imposes a tax upon the distribution of tobacco  
                 products, based on the wholesale cost of these products,  
                 at a tax rate equivalent to the combined rate of tax  
                 imposed on cigarettes.  Proposition 99 provides that the  
                 term "tobacco products" includes, but is not limited to,  
                 "all forms of cigars, smoking tobacco, chewing tobacco,  
                 snuff, and any other articles or products made of, or  
                 containing at least 50 percent, tobacco, but does not  
                 include cigarettes".  

               ii)    The very same definition was later included in  
                 Proposition 10, which California voters passed in 1998.  








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               iii)   This definition can be interpreted in at least one  
                 of two ways, depending upon whether the clause "made of,  
                 or containing at least 50 percent, tobacco" is read to  
                 qualify all items listed in the definition or only "any  
                 other articles or products".  

               iv)    Based on its interpretation of federal statutes  
                 defining "tobacco products", BOE has taken the second  
                 approach and concluded that the term "tobacco products"  
                 includes  all  forms of cigars, smoking tobacco, chewing  
                 tobacco, and snuff, irrespective of the amount of pure  
                 tobacco they contain.  By the same token, BOE has  
                 determined that the 50% tobacco threshold only applies to  
                 "other articles or products".  

               v)     This seems to be a reasonable interpretation given  
                 the underlying purpose of Propositions 99 and 10, and the  
                 fact that the definition specifically provides that the  
                 term "tobacco products"  includes, but is not limited to  ,  
                 the specified product categories, suggesting the  
                 definition should be given broad application.  

               vi)    In addition, Committee staff are not aware of any  
                 other state that has a 50% tobacco content threshold.   
                 Therefore, it would appear that this bill would make  
                 California's definition of tobacco products similar to  
                 the definition used by other states for tax purposes.  

              b)   What exactly are "other articles or products"?
              
               i)     In response to increased restrictions on public  
                 smoking, the tobacco industry has been actively  
                 developing new smokeless products.  For example, R.J.  
                 Reynolds Tobacco Co. is currently introducing three  
                 dissolvable smokeless products - Camel Orbs (a  
                 lozenge-like pellet), Camel Sticks (a twisted  
                 toothpick-size stick), and Camel Strips (a film strip for  
                 the tongue).   

               ii)    If these or similar products are represented to  
                 contain less than 50% tobacco, and are subsequently found  
                 to contain more than 50% tobacco, distributors are  
                 concerned that they will be held responsible for payment  
                 of back taxes on these products.  This bill seeks to  








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                 alleviate this concern by creating a bright line rule  
                 that all products containing tobacco will be treated as  
                 tobacco products for purposes of taxation, irrespective  
                 of the tobacco content.  

              c)   Related Bills in the Current Legislative Session  :

               i)     AB 89 (Torlakson) would impose an additional excise  
                 tax on cigarettes of $2.10 per pack.  The proceeds would  
                 fund various education, health, and research programs.   
                 This bill is scheduled to be heard by the Committee on  
                 Governmental Organization on April 22, 2009.  

               ii)    SB 600 (Padilla) would impose an additional excise  
                 tax on cigarettes of $1.50 per pack, with the amount  
                 adjusted annually for inflation.  Funds would be  
                 deposited in the Tobacco Tax and Health Protection Fund  
                 and the General Fund.  

              d)   Technical amendment  :  Committee staff suggest a  
               technical amendment to insert the word "the" before  
               "provisions" on page 2, line 23.  

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          California Distributors Association (sponsor) 
          California Grocers Association 

           Opposition 
           
          California Chamber of Commerce
           
          Analysis Prepared by  :  M. David Ruff / REV. & TAX. / (916)  
          319-2098