Track and trace is a system for monitoring the production and distribution of tobacco products, with the aim of combatting the illegal trade of tobacco products in Europe. The fight against the illegal tobacco trade is crucial for protecting European citizens. The World Health Organisation’s Protocol to eliminate illegal trade and the European Directive on Tobacco Products require that such a system be established by 2019 for cigarettes and fine-cut tobacco placed on the EU market, and by 2024 for other tobacco products.
Member States will have to ensure that all unit packets of tobacco products are marked with an irremovable unique identifier (UID), which will integrate data relating to the product itself, its manufacturing process, as well as distribution and financial information. The European Commission, in coordination with Member States, will have to define and adopt the technical details and system specifications on which Track & Trace will be based. In doing so, the European Commission and Member States must keep in mind the primary objective of this Track & Trace system, which is to reduce the volume of counterfeit and illegally traded tobacco products available on the European market. It is not the system’s main goal to control the manufacturing of legally compliant tobacco products.
Tracking and tracing tobacco products in the EU will require monitoring the movements of around 29 billion tobacco packaging units per year, meaning 80 million units per day.
Each unit will be scanned up to five times before it is placed on the market. This process will require unprecedented data transfers and a very performant IT infrastructure, which will take time to design and, more importantly, to implement.
Even though the issue of illegal trade is mostly related to cigarettes, and so-called ‘illicit whites’ that often come from outside the EU, the requirements of the Directive will apply to all tobacco products placed on the EU Market. The Track and Trace system must be developed taking into account the specificities and packaging of all tobacco products and all companies, including SMEs and mid-sized companies, whether they are manufacturers, distributors or wholesalers.
For smaller companies manufacturing tobacco products other than cigarettes, the cost of implementing Track and Trace will be 10 to 15 times higher per unit produced than for large-scale cigarette manufacturers.
The system must therefore reflect industry practices and specificities, ensuring interoperability by using GS1 standards and mirroring smaller tobacco companies that trade differently than multinational companies.
A realistic system to track and trace tobacco products sold in Europe must acknowledge other existing and efficient tools, such as the Excise Movement Control System used in monitoring excise goods intended for export, and avoid redundancies and additional burdens.