Tobacco Europe AISBL
TE
Tobacco Europe is a non commercial association which was formed to represent the common views of major European–based tobacco and nicotine products manufacturers.
ID: 1496873833-97
Lobbying Activity
Meeting with Gaetano Pedulla' (Member of the European Parliament, Shadow rapporteur)
29 Jan 2026 · Mercato europeo prodotti del fumo, tassazione
Meeting with Enikő Győri (Member of the European Parliament)
6 Nov 2025 · Revision of the Tobacco Taxation Directive
Response to Proposal amending the Batteries Regulation (EU) 2023/1542 as regards battery due diligence obligations
23 Jul 2025
Tobacco Europe welcomes the opportunity to provide input on the proposed postponement of due diligence obligations under the Batteries Regulation. In our contribution attached, we highlight two key points we believe are essential for a proportionate and effective implementation: (1) the timely publication of implementing guidelines, and (2) the need for clarification on scope and thresholds.
Read full responseMeeting with Michele Piergiovanni (Acting Director Competition)
7 May 2025 · Presentation of the most relevant policy files for Tobacco Europe
Meeting with Kristoffer Storm (Member of the European Parliament)
4 Mar 2025 · Tobacco Industry
Meeting with Katarína Roth Neveďalová (Member of the European Parliament)
22 Oct 2024 · Presentation of issues of the tobacco industry
Meeting with Thierry Mariani (Member of the European Parliament)
11 Jul 2024 · Enjeux de la filière des produits à base de nicotine au niveau européen
Response to Revision of the Union Customs Code
19 Oct 2023
Tobacco Europe AISBL represents the common views of major Europeanbased tobacco and nicotine products manufacturers which includes British American Tobacco (BAT), Imperial Brands (IMB), and Japan Tobacco International (JTI). We welcome the customs reform and would like to pr esent our position that follows the guiding principles of a collaborative mindset across jurisdictions and organisational siloes, common standards, interoperability between systems, a data driven culture, and flexibility to learn and adapt. The proposed ne ar term solutions are fully in line with the conclusions of the Wise Persons Group report and the EU Commission proposal. We also believe that a greater collaboration between the private and public sector (EU customs and law enforcement authorities) can b enefit the process for reforming the Union customs legislation and drafting the revised Delegated and Implementing Acts of the modernised Union Customs Code. Our key points comprise the following (but not limited to): 1. The removal of the customs duty de Minimis threshold (for which Tobacco Europe is supportive of the Commission's proposal); 2. The creation of the EU customs data hub and customs digitalization; 3. The Trust & Check Trader and Trusted Supply Chains Our key points are highlighted in the attached position paper, notably our assessment on why the EU Commission proposal for de minimis removal is compliant with EUs Free Trade Agreements and the WTO agreements, including the WTO TFA. We hope our views will be considered by the legislators on the ongoing negotiations and remain at your disposal should you need any additional information or clarification on our views regarding this important dossier. Kind regards, Nathalie Darge Acting Secretary General of Tobacco Europe
Read full responseResponse to Review of the requirements for packaging and feasibility of measures to prevent packaging waste
21 Apr 2023
Tobacco Europe welcomes the opportunity to provide feedback to the review of rules on reducing packaging waste. Tobacco Europe is fully committed to the EU Green Deal objectives and the respective efforts striving for the reduction of waste in general and packaging waste in particular. We welcome the choice of a Regulation as a legal instrument, as we believe that to fully achieve a sustainable circular economy, a higher level of harmonisation of EU waste and packaging legislation across EU Member States is needed. We also support the choice of an internal market legal basis as the right step towards boosting packaging circularity across the EU. However, we remain concerned that certain provisions included in the Commissions proposal could still allow Member States to introduce diverging national requirements. The detailed position of Tobacco Europe can be found in the document enclosed. We hope our comments will be considered in the ongoing work of the Commission and remain available for further clarifications.
Read full responseResponse to Targeted revision of the EU system of tobacco traceability
1 Dec 2022
Tobacco Europe AISBL is the umbrella organisation representing the common views of major Europeanbased tobacco and nicotine products manufacturers such as British American Tobacco, Imperial Brands, and Japan Tobacco International, located in Brussels, Belgium. Tobacco Europe welcomes the opportunity offered by the EU Commission to provide input to the draft amending Implementing Regulation (EU) 2018/574 on technical standards for the establishment and operation of a traceability system for tobacco products published by the Commission on 3 November 2022. In our views, this draft should essentially regulate clarifications and specifications on technical operating procedures and IT processes aiming at improving both the quality of the T&T system and uniform processes in the European Union. Our full-length submission is attached in the annex. Tobacco Europe and its members hope that the content provided in this submission contributes to the ongoing work of the European Commission.
Read full responseResponse to Revision of the Union Customs Code
16 Sept 2022
CALL FOR EVIDENCE: REFORM OF THE UNION CUSTOMS LEGISLATION
Tobacco Europe AISBL represents the common views of British American Tobacco (BAT), Imperial Brands (IMB), and Japan Tobacco International (JTI).
We appreciate the initiative of the European Commission with respect to the reform of the union customs legislation.
We would like to contribute to this initiative by proposing clarifications on certain issues which are of concern for our members if not addressed appropriately and call for greater collaboration between the private and public sector (EU customs and law enforcement authorities).
Our recommendations are:
1. Decrease of the customs duty ‘de Minimis’ threshold: e-commerce has created new distribution channels for illicit and counterfeit traded goods. A decrease of the customs duty ‘de Minimis threshold’ can contribute to the reduction of the illicit trade supply chains. We therefore welcome the Wise Persons Group recommendation to remove the EU ‘de-minimis’ threshold and we call on the EU Commission to implement this recommendation as soon as possible.
2. The EU Commission in collaboration with the private sector should evaluate and determine whether new and emerging technologies can support the customs union in controlling the safety and security risks associated with e-commerce. These new and emerging technologies may include blockchain and artificial intelligence (AI) solutions.
We attach in annex our letter which provides further details regarding the current challenges and proposed solutions.
We would welcome the opportunity to meet the Commission to outline in more detail our recommendations.
We hope that the content provided in this submission contributes to the ongoing work of the EU Commission.
Kind Regards,
On behalf of Tobacco Europe,
Nathalie Darge, Director
Read full responseResponse to Revised recommendation on smoke-free environments
19 Jul 2022
Tobacco Europe welcomes the opportunity offered by the EU Commission to provide input to the Call for Evidence on smoke-free environments published by the Commission on the 22 June 2022.
Our contribution will focus both on:
1) Tobacco Europe views on the Commission’s initiative to extend the recommendations’ coverage to emerging products, such as e-cigarettes and heated tobacco products (HTPs), and to explicitly include certain outdoor spaces in the definition of smoke-free environments
2) The weaknesses identified in the process and content of the RAND Study on smoke-free environments and advertising of tobacco and related products.
1. Tobacco Europe views on the Commission’s initiative
a) On the extension of the coverage to emerging products, such as e-cigarettes and HTPs
Tobacco Europe believes that there is no scientific-based justification for the inclusion of “emerging products” such as e-cigarettes and HTPS in existing smoke-free regulations.
The Tobacco Europe’s member companies are heavily involved in the development of e-cigarettes, heated tobacco products, which are also known as reduced risk products (RRPs). This is beneficial as they have the resources and expertise to fully deliver the potential of such reduced risks products as an alternative to tobacco products.
As such, e-cigarettes are fundamentally different from combustible tobacco products as they do not burn tobacco. Similarly, HTPs are tobacco products that heat tobacco without combusting it and deliver an aerosol containing nicotine.
According to various studies, there is no direct evidence that neither exhaled vape aerosol nor Tobacco heated aerosol poses a risk to bystanders.
Importantly, the unintended consequences of such restrictive policies should be considered. A review of the scientific literature found the use of e-cigarettes in areas where smoking is banned “may encourage smokers to make the switch to a product that could improve their health and save their lives, thereby helping to de-normalise smoking by reducing the overall number of smokers”.
b) On the extension of the scope to certain outdoor spaces such as outdoor terraces with bars and restaurants in its scope
Tobacco Europe considers that regulators should approach public smoking in a balanced and proportionate way, based on sound scientific evidence, whilst it is the role of consumers to be courteous and considerate when smoking in public place, and in particular should exercise care to avoid smoking around children.
Tobacco Europe believes that measures to restrict smoking in outdoor public places such as outdoor terraces with bars and restaurants have no scientific legitimacy.
2. The weaknesses identified in the process and content of the RAND Study :
Tobacco Europe would like to draw your attention to some weaknesses identified in both the process and content of the 2021 RAND Study.
The Commission developed the 2021 Rand report based on both a questionnaire and desk research on the implementation of the 2009 Council Recommendation on smoke-free environments. This report is meant to be the basis in 2022 for a Commission proposal in 2023.
The Commission is considering the RAND report on the Tobacco Advertising Directive and Smoke-free environments as an “evaluative study”. However, this report does not follow the evaluation structure imposed by the Better Regulation Principle. Importantly, the Commission should have run both a proper evaluation and an Impact Assessment.
In Tobacco Europe’s view, the RAND report does not provide clear data.
All in all, Tobacco Europe and its members remain fully committed to assisting the Commission in the process of reaching a consensus which meets the goal of achieving public health on the solid foundations of internal market objectives, robust evidence and sound science.
Further details are annexed to this feedback.
Read full responseResponse to Reporting of data on post-consumption waste of tobacco products with plastic filters
20 Oct 2021
l.s.
The proposed implementing act on reporting of data on post-consumption waste of tobacco products with plastic filters is in line with the findings of the report carried out by consultants on behalf of the European Commission on Work Package 4, “Study to support the development of implementing acts and guidance under the Directive on the reduction of the impact of certain plastic products on the environment”.
More specifically, the format for reporting data and information on the collected post-consumption waste of tobacco products filter outlined in the proposed implementing act, is aligned with the general practice already used across Member States for reporting information and data on collection of other type of waste.
As outlined in the abovementioned report:”Reporting the amount of post consumption waste by weight (defined as mass measured in tonnes) was preferred in the stakeholder consultations by both operators of public collection systems and manufacturers. Operators of public collection systems argued that waste is generally measured in tonnes.”
As a matter of fact, the same methodology, based on the metrics of weight has been also applied in the Commission Implementing Decision (EU) 2021/1752 of 1 October 2021 laying down rules for the application of Directive (EU) 2019/904 of the European Parliament and of the Council as regards the calculation, verification and reporting of data on the separate collection of waste single-use plastic beverage bottles.
To conclude, it is worthy to reaffirm the positive evaluation of the proposed implementing act as it ensures consistency with the methodology applied to other type of waste and represents the most feasible solution for operators of public collection systems.
Read full responseResponse to Tobacco taxation – revision of EU rules
21 Dec 2020
Tobacco Europe welcomes the opportunity offered by the EU Commission to provide input to the inception impact assessment on the revision of Directive 2011/64/EU on the structure and rates of excise duty applied to manufactured tobacco. Please find attached our contribution.
Read full responseMeeting with Dermot Ryan (Cabinet of Commissioner Phil Hogan)
22 Jul 2020 · EU-UK future trade relations
Response to General arrangements for excise duty – harmonisation and simplification
24 Jul 2018
The Confederation of European Community Cigarette Manufacturers (CECCM) represents the common views of major European–based cigarette manufacturers such as British American Tobacco (BAT), Imperial Brands (IMB), and Japan Tobacco International (JTI).
CECCM and its members welcome the opportunity to comment on the recast of the Council the Directive 2008/118/EC concerning the general arrangements for excise duty – COM (2018) 346 final.
In general, CECCM welcomes the above-mentioned Commission’s proposal. However, we believe some improvements could be made in certain areas (e.g. on exceptional situations (irregularities), guarantees, etc..).
Please find in annex the CECCM position paper for a more detailed explanation on our views and possible improvements.
Read full responseResponse to Implementing act under Article 15(11) of the Tobacco Products Directive 2014/40/EU
29 Sept 2017
CECCM welcomes the opportunity to provide our feedback on the draft secondary legislation. Our members are fully committed to complying with the provisions of Articles 15 and 16, and have urged policymakers to ensure that secondary legislation is prepared, agreed and adopted in a timely manner. A workable tracking and tracing system must respect fair competition, it should boost innovation and ensure that the Commission operates within the mandate set for it by TPD2. We would propose the following changes to the text in order to meet those goals.
Competition: one of our key concerns has been that legislation should prescribe recognized international open standards and ensure competition between providers of solutions (track and trace, security feature and data storage), allowing all economic operators in charge of implementing Article 15 to select their preferred suppliers. The appointment of a single ID issuer per Member State is arbitrary, will hinder competition, promote monopolies and thereby risk increasing the cost of production.
Solution: Member States should be permitted to approve a list of qualified providers based on a transparent set of criteria, and allow manufacturers to select their provider from this list.
Innovation: the absence of competition amongst ID issuers will remove incentives to provide greater levels of innovation. As other available solutions are unable to enter the market, there will be no need to improve service, nor invest in improvements. An example is in favoring outdated technology which will require manufacturers to place stickers on every pack and carton. The system should instead encourage the latest technology using electronic means to disseminate unique identifiers from an ID Issuer to a manufacturer.
Solution: Each ID Issuer should have the capacity to deliver both electronically and physically. Delivery format is based on the specification outlined by the manufacturer or importer.
Interoperability: open standards are essential to ensure the T&T system is interoperable and functions correctly and such systems are already successfully used by operators today, at a high level of security. Interoperability is a fundamental part of any workable, and efficient T&T system. Furthermore, introducing a semi-covert security feature is incompatible with ISO standards used to fight counterfeiting and goes beyond the Tobacco Products Directive.
Solution: The UID coding structure should be specifically referenced to an ISO (or GS1) standard. So-called semi-covert security features should not be included in the implementing acts as an additional requirement.
Reduce administrative burdens: it is unrealistic to require operators to include information on UIs as part of the reporting on transactions (issuing invoice, payment order, receipt of payment). This proposal from the Commission risks generating barriers to trade and will increase the cost of doing business within the EU and goes beyond the scope of the original legislation.
Solution: Delete reference to UIs from the data to be reported on transactional events.
Mitigate impact on jobs: requiring tobacco products destined for export to be placed under the track and trace system will create a trade barrier. Export markets in some regions will not accept marked tobacco products because of local laws, and our trade partners will simply go elsewhere to source product - at the expense of European jobs. EU manufacturers will face this risk while there is no parallel benefit to improved law enforcement.
Given the industry currently manufactures more than 50 billion sticks of cigarettes per year in the Union which are exported to more than 25 markets, bringing in a surplus of over €3 billion per year, there is the serious risk of damaging valuable trade links, as part of a measure that goes beyond TPD2.
Solution: The Commission should adhere to the the scope of TPD, and not impose extra requirements on manufacturers.
Read full responseMeeting with Bernardus Smulders (Cabinet of First Vice-President Frans Timmermans) and DIGITALEUROPE and
14 Jan 2016 · AECA Round-Table on “Dealing with Regulatory Burden
Meeting with Malgorzata Iskra (Cabinet of Commissioner Pierre Moscovici), Maria Elena Scoppio (Cabinet of Commissioner Pierre Moscovici)
25 Mar 2015 · Tobacco Product Directive, Revision of the Excise Directive