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SMD Logistics

SMD

SMD Logistics AB distributes foremost tobacco products for the Swedish market.

Lobbying Activity

Response to Implementing act under Article 15(11) of the Tobacco Products Directive 2014/40/EU

2 Oct 2017

Views on the commission delegated regulation (EU) dated 04/09/2017 of the implementation of Article 15 of the Tobacco Product Directive SMD Logistics AB (“SMD”) provides distribution services in Sweden to manufacturers and marketers of tobacco products active on the Swedish market. SMD distributes to approximately 10.000 customers/point of sales in a well-established and secure distribution network. The number of employees amounts to approximately 170 and the company is a wholly owned subsidiary of Swedish Match AB (publ). SMD would like to express its concern that the drafts from the European Commission provides for a system that does not use internationally recognized open standards, preferably the “GS1-standard”. SMD finds the Commissions proposed regulation as both unnecessary cumbersome and expensive since tested and verified solutions already exist on the market. SMD particularly would like to comment on the following: • Open standards SMD finds it obvious that an open standard should be used instead of a specially designed solution that has never been tested before and which obviously seems to be unnecessarily complicated. We favour the internationally accepted and recognized standard “GS1” which is already used by many actors. An open standard solution would facilitate the integration with your current IT system, which is a requirement regardless of which solution that is decided upon. • Timetable The scheduled timetable to implement Article 15 as per May 20, 2019 is no longer realistic in our opinion, especially if an open standard is not used. SMD kindly urges the European Commission to take our concerns seriously and hence amend the proposal accordingly as the current version will lead to, amongst others, higher costs, unnecessary logistic challenges and more administration. Best regards, SMD LOGISTICS AB
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