Manufacture de Tabacs Heintz van Landewyck
HvL
Landewyck Tobacco is a family-owned business founded in 1847.
ID: 923856024330-39
Lobbying Activity
Response to Targeted revision of the EU system of tobacco traceability
1 Dec 2022
Heintz Van Landewyck is the sole tobacco manufacturer present in Luxembourg, family owned and having production facilities in Luxembourg, Germany and Hungary. Our company wants to engage and warn at this momentum in order to adapt the Commission Implementing Regulation 2018/574/EU on the traceability system for tobacco products in two ways. As we are active in several member states, we are also member of our local national manufacturers association as well as of European Smoking Tobacco Association, known as ESTA. The European umbrella organization intervened taking into account the necessity for a multi member state approach in technical matters but also for the concern on the export barrier still imposed by the current Implementing Regulation. ESTA proposed the recommended modifications in a separate memo enclosed, in a first part by fine tuning the technical recommendations, followed by - repeating - the concerns on the export issue. Technically : the approach and content on the machine parts flexible and mobile parts - should be clarified and applied in a uniform way in the Member States. Data management as collected from the operations should be better clarified in a uniform sense. We are a typical remaining European SMEs (one of the Small and Medium Enterprises in the tobacco sector) having production facilities ONLY in the EU, also present in many small tobacco product groups being exposed simultaneously to the next implementation wave of the traceability system for tobacco products as from May 2024. Our company depends for its specialized tobacco products also on its export possibilities to customers based in countries of destination outside the EU. Imposing marking requirements for products to be exported to destinations outside EU means an excessive additional cost for SMEs as us while we have no critical volume presence even not within the EU and not on markets outside the EU. Smaller companies operating in a severe regulated productsector as tobacco products can only remain in place via their qualitative product differentiation. Doubling regulations affecting unilateraly our European production in international trade terms means for our company we are forced to abstain to participate in those countries outside EU. The Commission has been alerted and made aware many times as well by ESTA as by some Member States, the current IR 2018/574/EU is more strict than the disposals of the directive 2014/40/EU while an Implementing Regulation cannot deepen the directive by introducing a discrimination not wanted nor inscribed by the directive. The application of the WHO FCTC protocol does not impose such a discrimination for exports outside the EU. The Heintz Van Landewyck team remains available to show and prove the impact of both concerns as from one of their production sites.
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