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International Tax Stamp Association

ITSA

The International Tax Stamp Association is a not-for-profit organisation founded in November 2015, that is working to ensure better understanding of the benefits of tax stamps and tax stamp technology, and to promote high professional standards through education, research and advocacy, and by developing and promoting best practice.

Lobbying Activity

Response to Targeted revision of the EU system of tobacco traceability

1 Dec 2022

The International Tax Stamp Association (ITSA) is grateful for the opportunity to provide feedback on the EU system for traceability of tobacco products. Since the very beginning of the stakeholder consultation process back in 2015, ITSA has highlighted to the European Commission weaknesses in the system design, and made recommendations to increase its efficacy to fight illicit trade in tobacco products. Unfortunately we note that the draft revision of the Implementing Regulation (EU) 2018/574 does not address these weaknesses and recommendations, focusing instead primarily on increasing the scope of work of the current provider of the secondary repository, which is likely to occur with limited or no competitive bidding. In line with previously communicated recommendations, ITSA believes that a comprehensive evaluation of the current traceability system should be conducted, to identify potentially structural changes that should be made to the system, not only to the Implementing Regulation (EU) 2018/574, but also the Implementing Regulation (EU) 2018/576 and the delegated Regulation (EU) 2018/573. We re-iterate our recommendation to strengthen the role of tax stamps, which should be a mandatory component of the system. Tax stamps should be issued by a government authority, and should carry, in addition to authentication features, a unique ID for tax stamp traceability. We recommend that ISO standard 22382 should be used as a compulsory guidance for the issuance of tax stamps. We also re-iterate our recommendation, in compliance with the FCTC Protocol to Eliminate Illicit Trade in Tobacco Products, that independent providers for the traceability system should be appointed by competent authorities from the Member States, rather than by the tobacco industry. ITSA stands ready to provide any additional contribution towards improving the EU system, and increasing its effectiveness to fight illicit trade in tobacco products.
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