Her Majesty's Revenue & Customs recently contacted The Chartered Institute of Logistics and Transport with guidance on the implementation of the tobacco track and trace system to pass on to businesses to understand that they will need to do to comply with the requirements.

Timing

In June 2018, the UK ratified the World Health Organization Protocol to Eliminate Illicit Trade in Tobacco Products and is committed to implementing a UK-wide track and trace system and new security features on tobacco products. These requirements are set out in the Tobacco Products Directive with a commencement date of 20 May 2019 for cigarettes and hand-rolling tobacco, and 20 May 2024 for other tobacco products.

New Economic Operator identifier codes

All businesses involved in the manufacture, importing, distribution and sale of tobacco products in the UK will need a new Economic Operator identifier code by 20 May 2019. You will need to apply for a code from the UK’s appointed ID Issuer. We have recently appointed ‘De La Rue’ as the UK’s ID Issuer and they will be setting out the process for requesting an identifier code soon. 

Tracking and tracing equipment

If you only sell tobacco products to the public, you will not need any new equipment.

If you store, distribute or sell tobacco products to other wholesalers or retailers you will need to obtain equipment to record the movement of these products. The tobacco industry are responsible for providing the equipment and have appointed a third party provider ‘SGS’ to act as the single point of contact. You can find out more information, such as how to work out what equipment you will need and how to obtain it, via the SGS website at: https://ontrack.sgs.com/en-US/.

Security features

We have published a list of security features that tobacco manufacturers and importers will need to incorporate onto cigarettes and hand-rolling tobacco from 20 May 2019.  The security features will be located on a new security label, which will be affixed to each unit pack. Please visit: www.gov.uk/guidance/security-features-for-tobacco-track-and-trace

Sell through period

There will be a 12-month sell-through period for cigarettes and hand-rolling tobacco. This means that you can continue to sell products without security features or unique identifier codes until 20 May 2020 as long as they were manufactured in, or imported into the UK before 20 May 2019.

Legislation

On 11 February, we published draft legislation for technical consultation. This includes sanctions and penalties for supplying non-compliant products. Our approach will be to support businesses involved in legitimate trade to comply whilst taking action against those who seek to deliberately avoid or abuse the rules. The consultation closes on 11 March. Please visit:  https://www.gov.uk/government/consultations/the-tobacco-products-traceability-and-security-features-regulations-2019

Guidance

To prepare for these changes we have published guidance on transporting tobacco products, manufacturing and importing tobacco products and putting unique identifier codes on tobacco products. Please visit: www.gov.uk/government/collections/rules-for-tobacco-products.