Combating the trade in illicit tobacco

May 3, 2019, by Seán Dennison - Category: traceability

In November 2017, GS1 Ireland wrote to the Minister for Health, Simon Harris, copying the Minister for Finance and Public Expenditure & Reform, Pascal Donohoe, in support of the European Commission’s draft implementing acts to combat the trade in illicit tobacco.

According to the World Health Organisation:

  • Nearly 10% of the global cigarette trade is illicit
  • This is significantly higher in low and middle income countries, up to 50% or more
  • If illicit trade were eliminated, governments worldwide could gain at least $30b per annum in tax revenue

GS1 (through GS1 in Europe) welcomed the efforts made by the European Commission to develop the fight against this illicit trade and actively participated in the consultation processes. GS1 submitted detailed comments in reply to the public consultation.

Article 15 of the Tobacco Products Directive introduces a tracking and tracing system with a unique identifier at the level of a unit packet of tobacco products.

Article 16 requires that all unit packets carry a tamper proof security feature, composed of visible and invisible elements to allow the following to be determined:

  • the date and place of manufacturing;
  • the manufacturing facility;
  • the machine used to manufacture the tobacco products;
  • the production shift or time of manufacture;
  • the product description;
  • the intended market of retail sale;
  • the intended shipment route;
  • where applicable, the importer into the Union;
  • the actual shipment route from manufacturing to the first retail outlet, including all warehouses used as well as the shipment date, shipment destination, point of departure and consignee;
  • the identity of all purchasers from manufacturing to the first retail outlet; and
  • the invoice, order number and payment records of all purchasers from manufacturing to the first retail outlet.

GS1 firmly believes that the proposal, when implemented based on existing open GS1 standards, can provide for the required scale and interoperability to achieve the Commission’s desired outcome.

The regulatory design supported by GS1 identifiers (GTIN, SSCC) and standards (AIDC) will benefit Member States’ Authorities, Small and Medium Enterprises, and all economic operators based on GS1’s capacity to:

  • uniquely identify products, logistic units, economic operators, facilities, and machines;
  • automatically capture, record, and share event data;
  • integrate business message data by using the same identifiers.

GS1 believes that an approach utilising GS1 open standards, which is already in use in most other parts of the supply chain today, will meet the requirements of the Directive and Implementing Acts.

We believe it will also do so with the shortest path to implementation and with reduced impact on SMEs. It will also provide an interoperable, secure system between Member States, and autonomy for Member States on critical control functions.

The Commission’s proposal was adopted on 29/11/2017. This provides an opportunity for GS1 to be involved in issuing the Unique Identifiers and providing track and trace capabilities. While the overall solution will be challenging, GS1 position as an independent, neutral standards organisation will be working with the relevant stakeholders to help them implement the new processes over the course of the next 18 months. The technical rollout is due to be completed by 20th May, 2019.

Tags: track, trace, tobacco, legislation