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Coalition Against Illicit Trade

CAIT

Mission and Objectives The trade of counterfeited and contraband goods represents a significant threat to consumers, public authorities, companies, and society in general. Counterfeiting and the trade in contraband is a global issue that affects a huge range of industries: pharmaceuticals, automotive parts, luxury goods, alcohol, tobacco, chemicals, cosmetics, toys, gemstones, watches and clothing, to name just a few. The trade in unregulated and untested counterfeit goods poses a significant danger to consumers’ health, and costs governments around the world untold billions in lost revenues – funds that could be used to build schools, provide healthcare, and cut taxes. We established CAIT to foster enhanced co-operation among stakeholders, share best practice, and discuss practical solutions to the problem. Industry involvement is vital, given its hard-won insights into markets, supply chains and effective control processes. Our members have significant experience in implementing track & trace systems and authentication solutions. With CAIT, we have created a forum dedicated to advancing common technological standards – and to stepping up the fight against illicit trade worldwide. Our Mission - Encourage collaboration and exchange best practice between industry, regulators and policymakers - Promote open technology standards to develop effective solutions in the fight against counterfeiting and illicit trade - Deepen our understanding of track & trace and anti-counterfeiting technologies and their practical application Membership is open to all companies and organisations who share the coalition’s objectives and principles.

Lobbying Activity

Response to Delegated act under Article 15(12) of the Tobacco Products Directive 2014/40/EU

2 Oct 2017

The Coalition Against Illicit Trade (CAIT) welcomes this Commission consultation and we are glad to share our feedback on the current draft implementing and delegated acts. Our contribution takes account of the practical experience of our members, which include leading experts in the provision and implementation of tracking, tracing and authentication systems deployed in multiple sectors across the EU and beyond. We found that the drafts under consultation have the merit to make progress and to provide a degree of clarity on the European Commission’ services views regarding traceability and authentication systems foreseen for the implementation of Articles 15 and 16 of the Tobacco Product Directive (TPD). However, there are a number of critical issues that remain of particular concern for service and solution providers that may jeopardise the development, implementation and market competition of innovative, effective, timely and interoperable solutions in this area. Given the complexity of the mission to be undertaken, key pre-requisites for a successful implementation should respect the spirit and the letter of TPD provisions on traceability and authentication, and be compliant with the ‘Better regulation’ commitments, as reaffirmed by President Juncker in his latest intervention on the State of the Union this September. Constant vigilance is required to protect against the threat of counterfeiters and smugglers. CAIT advocates that an open specification be drafted into the framework regulatory requirements to be adopted so that regulators avoid giving counterfeiters a blueprint to work to, and that innovative solutions that emerge in the future can be incorporated to react and respond to increasingly sophisticated counterfeiting attempts. Moreover, the issue of the potential conflict of rules between obligations imposed on products exported outside the EU with obligations imposed by the non-EU countries of import is not addressed. The main Issues of Concern for Service and Solution Providers, as well as detailed proposals for amendments to the draft texts can be found in annex.
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Response to Implementing act under Article 15(11) of the Tobacco Products Directive 2014/40/EU

2 Oct 2017

The Coalition Against Illicit Trade (CAIT) welcomes this Commission consultation and we are glad to share our feedback on the current draft implementing and delegated acts. Our contribution takes account of the practical experience of our members, which include leading experts in the provision and implementation of tracking, tracing and authentication systems deployed in multiple sectors across the EU and beyond. We found that the drafts under consultation have the merit to make progress and to provide a degree of clarity on the European Commission’ services views regarding traceability and authentication systems foreseen for the implementation of Articles 15 and 16 of the Tobacco Product Directive (TPD). However, there are a number of critical issues that remain of particular concern for service and solution providers that may jeopardise the development, implementation and market competition of innovative, effective, timely and interoperable solutions in this area. Given the complexity of the mission to be undertaken, key pre-requisites for a successful implementation should respect the spirit and the letter of TPD provisions on traceability and authentication, and be compliant with the ‘Better regulation’ commitments, as reaffirmed by President Juncker in his latest intervention on the State of the Union this September. Constant vigilance is required to protect against the threat of counterfeiters and smugglers. CAIT advocates that an open specification be drafted into the framework regulatory requirements to be adopted so that regulators avoid giving counterfeiters a blueprint to work to, and that innovative solutions that emerge in the future can be incorporated to react and respond to increasingly sophisticated counterfeiting attempts. Moreover, the issue of the potential conflict of rules between obligations imposed on products exported outside the EU with obligations imposed by the non-EU countries of import is not addressed. The main Issues of Concern for Service and Solution Providers, as well as detailed proposals for amendments to the draft texts can be found in annex.
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Response to Implementing act under Article 16(2) of the Tobacco Products Directive 2014/40/EU

2 Oct 2017

The Coalition Against Illicit Trade (CAIT) welcomes this Commission consultation and we are glad to share our feedback on the current draft implementing and delegated acts. Our contribution takes account of the practical experience of our members, which include leading experts in the provision and implementation of tracking, tracing and authentication systems deployed in multiple sectors across the EU and beyond. We found that the drafts under consultation have the merit to make progress and to provide a degree of clarity on the European Commission’ services views regarding traceability and authentication systems foreseen for the implementation of Articles 15 and 16 of the Tobacco Product Directive (TPD). However, there are a number of critical issues that remain of particular concern for service and solution providers that may jeopardise the development, implementation and market competition of innovative, effective, timely and interoperable solutions in this area. Given the complexity of the mission to be undertaken, key pre-requisites for a successful implementation should respect the spirit and the letter of TPD provisions on traceability and authentication, and be compliant with the ‘Better regulation’ commitments, as reaffirmed by President Juncker in his latest intervention on the State of the Union this September. Constant vigilance is required to protect against the threat of counterfeiters and smugglers. CAIT advocates that an open specification be drafted into the framework regulatory requirements to be adopted so that regulators avoid giving counterfeiters a blueprint to work to, and that innovative solutions that emerge in the future can be incorporated to react and respond to increasingly sophisticated counterfeiting attempts. Moreover, the issue of the potential conflict of rules between obligations imposed on products exported outside the EU with obligations imposed by the non-EU countries of import is not addressed. The main Issues of Concern for Service and Solution Providers, as well as detailed proposals for amendments to the draft texts can be found in annex.
Read full response