IRPLAST S.p.A
IRPLAST
FABBRICAZIONE E COMMERCIALIZZAZIONE DI FILMS PLASTICI IN GENERE, CON PARTICOLARE RIGUARDO AI FILMS BIORIENTATI E COESTRUSI IN POLIPROPILENE, E LORO RELATIVE ELABORAZIONI QUALI LA METALLIZZAZIONE, L'ADESIVIZZAZIONE E LA STAMPA, LE CONFEZIONI PER IMBALLI ED A TUTTI I TIPI DI ACCOPPIAMENTO, ANCHE CON ALTRI TIPIDI MATERIALI A CUI I FILMS MEDESIMI SI PRESTANO
ID: 037176424304-24
Lobbying Activity
Response to Implementing act under Article 16(2) of the Tobacco Products Directive 2014/40/EU
29 Sept 2017
Our organization is firmly convinced that clear wrap (by which we mean the transparent shrinkable BOPP wrapping film universally used for over-wrapping each packet of cigarettes on the market in all UE countries) should be considered as a potential irremovable and tamper-proof security feature. The clear wrap could easily be designed to incorporate an invisible security feature to confirm authenticity, and which could additionally either incorporate “images” as a visible security feature OPTION S2, or could protect in a tamper-proof manner an affixed visible security feature OPTION S3.
Based on the concepts in Article 16 of TPD2, the ideal security feature according to our opinion should include:
• Features composed of visible and invisible elements
• Tamperproof
• Applied at unit packaging level
The BOPP film currently used to wrap cigarette packs, and designed to be removed by the action of the tear-tape mechanism, is inherently TAMPER-PROOF. It is sealed, and when the pack is opened, it cannot be re-sealed or re-used and the film cannot be technically recomposed once torn by the tear tape.
It follows that, if the BOPP film used is intended to be used as a security feature, it must contain additional special properties which render it unique and identifiable to any controlling authorities through both simple laboratory or hand-held device checks, and as court-admissible forensic evidence of security feature authentication.
Our Company operates a special system for extruding and stretching large industrial quantities of BOPP film, which is the only existing equipment of its kind in the world. The film produced on this LISIM production line has a “fingerprint” which is unique and clearly identifiable using methodologies which are being finalized through in studies commissioned by our company with leading international universities in Switzerland and Italy specialized in both forensic science and material physics. Together with these universities, we are currently testing portable devices with suitably modified software which would allow any controlling body (manufacturers, retailers, customs or police) to immediately identify authentic/non-authentic wrapping film, and a forensic method which provides court-admissible authentication.
We would also add that the kind of developments we are doing on all three features, while understandably specific and unique for our process, could be divulged for development, using slightly different parameters, for other qualified and specialist OPP producers.
- In the list of the 12 types of authentication elements the “Laser image” has been considered as a Semi-covert element, our proposal is to include this option in the covert element because from our packaging solution, it doesn’t need any device to make it visible.
- The “DNA Taggants” option can be considered in the Semi-covert element because it doesn’t require any forensic method to be perceived but only a mobile device.
- We noticed that in the Article 8, a provider of authentication elements to be considered independent, it has to generate less than 20% of its annual overall turnover with the goods and services supplied to the tobacco sector; currently our Company respects this requirement, but we suppose that if our proposal will be accepted as a solution which contains several security features, more than the 20% can be achieved. So it would be appreciated if the decision on the limit was set to more than the 20%.
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