AlpVision SA
Inform about the invisible authentication feature that we developed in order to fight counterfeits.
ID: 350385813808-39
Lobbying Activity
Response to Implementing act under Article 16(2) of the Tobacco Products Directive 2014/40/EU
2 Oct 2017
Our comments are specifically related to the draft of the “COMMISSION IMPLEMENTING DECISION (EU) …/… on technical standards for security features applied to tobacco products”, dated 04/09/2017, regarding the Implementing act under Article 16(2) of the Tobacco Products Directive 2014/40/EU,.
We think that the list of authentication features given in the “Annex - Ares(2017)4305574/1” and titled “TYPES OF AUTHENTICATION ELEMENTS” allowable for implementation under the guideline is inappropriate. We do not know how this list was made and based on which requirements the features were selected, however, we believe that the listed features will be either ineffective or counterproductive, moreover some missing features will negatively impact the effectiveness of the Article 16. To illustrate our analysis, here are some examples:
1. The features are both outdated and not appropriate for brand protection.
For instance:
- Guilloche feature is an old solution, and with the advances of digital imaging processes, it has become very easy to duplicate. This feature therefore provides little, or even no protection against counterfeiting.
- Watermark features require to see through the document, which is just impossible on tobacco products. Even if implemented on the tax stamp, watermarks cannot be verified as the stamp is stuck on the box.
2. The Annex completely ignores the work (over 25 months effort) that was performed by third party companies mandated by the EC and financed by the EC, namely:
- Sovereign Border Solutions, signed on November 2013 which took 14 months to complete
- Everis, started on June 2016 with took 11 months to complete
We understand that this Annex includes a disclaimer stating that it is not endorsed by the EC. However, we believe that chances are high that it remains ‘as is’ in the final act and will be perceived as an exhaustive and exclusive list by the various stakeholders and implementing states.
Therefore, we ask that this table be removed from the draft implementing decision or, alternatively, be replaced by the table presented by Everis during the stakeholder meeting of May 15th 2017 (attached here for reference), which although imperfect, is much more appropriate.
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