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Vereniging Nederlandse Sigaretten- en Kerftabakfabrikanten

VSK

VSK is de brancheorganisatie van de in Nederland gevestigde sigaretten- en kerftabakindustrie.

Lobbying Activity

Response to Implementing act under Article 16(2) of the Tobacco Products Directive 2014/40/EU

2 Oct 2017

SECURITY FEATURE Reference Implementing Decision – article 2, article 3 and Annex Problem: 5 authentication elements are required. This increases costs and as well as the burden to manufacturers and importers. Furthermore EU COM included a new layer of security (semi-covert) which is not stipulated by TPD. The creation of lists of compliant technologies (elements) is lengthy and unspecified process. Solution: - Strike out the semi-overt category (not provided for in TPD) and subsequently limit number of authentication elements to two. - Instead of lists of compliant technologies make specific reference to ISO 12931:2012 which describes performance criteria for authentication solutions used to combat counterfeiting of goods and takes into account the extremely fast evolution in this sector Justification: The concept of semi-covert is not referred at all by ISO in the aforementioned standard. TPD doesn’t describe it either. Therefore it should not be included in the implementing acts as an additional requirement. The use of many of the described authentication elements is heavily directed towards imposing layered tax stamp solutions.
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Response to Delegated act under Article 15(12) of the Tobacco Products Directive 2014/40/EU

2 Oct 2017

The Vereniging Nederlandse Sigaretten- en Kerftabakfabrikanten (VSK) represents the interests of five Tobacco companies in the Netherlands, with three major production facilities for fine cut tobacco and cigarettes. These three factories produce for a world wide market. One of the main concerns with the proposed implementing regulation is therefore Export Marking. As destination markets also have their marking requirements, marking tobacco products to comply with EU standards is creating a barrier to trade. Such requirements also bring no value to law enforcement within the EU. We also believe that the Commission is overstepping its authority by going beyond TPD (as in the obligation to use the ID Issuer for aggregated levels, and in the obligation to include information on UIs into the reporting on transactional events), is creating new monopolies (as in the single ID issuer per Member State) and is proposing incomprehensible and unworkable requirements that totally ignore the Refit Agenda (as in the UID coding structure that is non-compliant with international standards, and in the demand to provide information about the machine on which the product will be manufactured).
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