German GambIing Iaws vioIate EU Iaw

1. n a liberal European democracy everyone enjoys the right to do as one pleases as far as others
remain unharmed. t is within the field of personal responsibility to have fun and potentially endanger
oneself. No matter if it is about skiing, driving a car or gambling. The new German State Treaty on
Gambling denies this liberty and restricts the citizens.
2. Furthermore, the new State Treaty on Gambling violates again the Court of Justice of the European
Union criteria. t is legally incoherent and falls short of the alleged main goals: protection of the gamers
and channeling gambling into legality.
3. State-run Casinos and commercially run gambling halls are increasingly being treated differently
despite a comparable range of products and clientele:
a) n gambling halls each gambling machine has to correspond with at least 12m
2
of the location's
surface. n state-run Casinos, no such requirement exists, so that factually six times more machines can
be deployed.
b) The maximum amount of machines in gambling halls is limited to 12. Again this restriction does not
apply to public Casinos. On average, 100 machines can be found per room and up to 370 in the whole
building.
c) n gambling halls there is a maximum wager of C 0.20 and a maximum prize of C 2 per five seconds.
No such limits exist in Casinos, even though slot machines contribute to around 75% of the turnover.
d) Public Casinos not only have the license to serve alcohol, but customers may also smoke within the
premises and have immediate access to cash machines. All of this is not permitted in gambling halls.
4. Gambling halls prevent illegal online gambling. Restraining them is counter-productive and only serves
the aim to protect the state-run Casinos from private competition.
5. Large gambling halls with multiple licenses provide the safest environment and the highest quality. The
cancellation of the multiple licenses concept by the Gambling State Contract harms the gamer's
protection.
6. Only about 0.2 to 0.56% of the German population between 18 and 65 are considered to be pathologic
gamblers. The pathology-potential of gambling sectors is 0.31 for lottery, 2.21 for gambling in Casinos,
0.79 for instant money games and 5.73 for online gambling.
7. The annual economic benefit of slot machines equals about seven billion euros while the loss roughly
0.2 to 0.3 billion euros.
8. The slot machine industry employs more than 250,000 employees in Europe, whose jobs are put at
stake by the new German State Treaty on Gambling.
The correct soIution wouId be the introduction of a quaIity management system for gambIing
haIIs, paIm scans at the entry to prevent the access of pathoIogic gambIers, codes for money
transfers in the machines to discourage money Iaundering, prevention training for the empIoyees
in cooperation with sociaI institutions and a obIigatory cataIogue of minimum standards
(certification) regarding quaIity and security for gambIing haIIs.