Thai Chamber opposes cabinet move to ease wine imports

The Thai Chamber of Commerce has submitted a letter to the Secretary-General of the Cabinet to oppose a new draft ministerial regulation on the import of alcoholic beverages, for consideration in the cabinet agenda.

The issue follows the cabinet meeting on February 3, 2026, which approved in principle a draft ministerial regulation on permission to import alcoholic beverages into the Kingdom (No. …) B.E. …, as proposed by the Ministry of Finance.

The key change is the removal of the eligibility requirement for applicants seeking a Type 1 import licence, meaning they would no longer need to be the sole authorised agent (sole agent) for the alcoholic beverages they import.

The draft also provides an exception allowing the director-general of the Excise Department to require Type 1 licence applicants to be the sole authorised agent if deemed necessary. However, in the initial phase, the Excise Department plans to apply the exemption only to imports of fermented alcohol in the categories of wine and sparkling wine — meaning applicants importing wine and sparkling wine would not need to be the sole authorised agent.

Dr Poj Aramwattananont, chairman of the Thai Chamber of Commerce and the Board of Trade of Thailand, sent the letter to convey the chamber’s views on the new draft regulation.

The chamber said it disagrees with the draft because it could affect trade governance, the excise tax collection system, fair competition, consumer safety, and the stability of state revenue — in ways that do not align with regulatory principles and the intent of relevant laws.

In its detailed objections, the chamber cited six main reasons:

1. The sole-agent system is a key trade-governance mechanism, as it clearly assigns primary responsibility for imported products, particularly those subject to excise tax controls, where accurate tax collection is a central objective of the law. Allowing parallel imports could distort competition and undermine fair taxation because parallel importers may gain cost advantages without bearing the same obligations as official importers — such as marketing and brand-building costs, after-sales service, warranties, and consumer liability — creating “free-rider” behaviour and weakening incentives for compliant businesses to invest for the long term.

2. Parallel importers could set recommended retail prices (RSP) below the true economic value due to much lower overall costs. If an artificially low price is used as the tax base, excise tax collected could fall significantly, causing unnecessary revenue losses and creating perverse incentives to depress taxable values.

3. Product quality oversight and traceability would be weakened. The sole-agent system supports effective traceability and supply-chain verification. Parallel imports, the chamber argued, would make it harder to confirm origins and raise risks of contamination or adulteration throughout the supply chain. Testing only sample products under standard procedures may not be sufficient to guard against counterfeit or substandard goods under international product-safety expectations.

4. Responsibility and accountability would be unclear. Parallel importers may lack contractual obligations to brand owners and may not have clear legal responsibility for consumer harm, recalls, or brand damage. The chamber also warned about risks to the credibility of excise stamps if products with unclear provenance carry tax stamps, potentially misleading consumers into believing quality has been verified. If problems arise, public trust in the tax system could be eroded, potentially pushing consumers towards untaxed products and compounding revenue losses.

5. Relaxing product labelling notification requirements could open tax-avoidance loopholes, such as misdeclaring grape wine (typically taxed at a higher rate) as another type of fermented alcohol with a lower tax rate. The chamber said labelling controls are not unnecessary red tape but an important regulatory safeguard that supports correct product classification and prevents systematic tax avoidance.

6. The Thai wine market is largely mass-market and needs closer oversight. The chamber estimated that around 98% of wines sold in Thailand are priced below 2,000 baht per bottle — a segment typically operating under sole-agency arrangements. As it is a large market where consumer knowledge may be limited and producers have less control over supply chains than in premium segments, the risk of substandard or counterfeit wine entering the market is higher, with potential impacts on consumers, taxation and market fairness.

Based on these six considerations, the Thai Chamber of Commerce said it does not agree with the draft ministerial regulation on permission to import alcoholic beverages into the Kingdom (No. …) B.E. ….