Status of the tobacco product tracking and tracing system

Author: Luk Joossens, consultant for Smoke Free Partnership Translation by the National Committee against Smoking

The Protocol to Eliminate Illicit Trade in Tobacco Products

This Protocol is the first protocol to the WHO Framework Convention on Tobacco Control (FCTC). It constitutes a new international treaty in its own right. It was negotiated by the Parties to the FCTC and was adopted by consensus on 12 November 2012 at the fifth session of the Conference of the Parties (Seoul, Republic of Korea, 12–17 November 2012). It entered into force on 25 September 2018.

• The objective of the Protocol

The objective of the Protocol is to eliminate all forms of illicit trade in tobacco products. To achieve this objective, it aims to secure the supply chain of tobacco products through a series of measures. It requires the establishment of a global tracking and tracing regime within five years of its entry into force, including national and regional tracking and tracing systems and a global information sharing point located within the Secretariat of the Framework Convention.

• Status of the Protocol

The first session of the Meeting of the Parties (MOP1) to the Protocol was held from 8 to 10 October 2018, the second MOP from 15 to 17 November 2021. A third session is scheduled for 27 to 30 November 2023 and is expected to take decisions regarding the global focal point for the exchange of information.

• Protocol Outlook

Eliminating the illicit tobacco trade globally has the potential to increase tax revenues and reduce overall tobacco consumption. Based on 2007 data, the total tax revenue lost from the illicit cigarette trade has been estimated at approximately $40.5 billion per year. If this illicit trade were eliminated, governments would gain at least $31.3 billion per year and the expected reduction in consumption would be 2 %[1]. A study published in 2020 confirmed that eliminating illicit cigarettes in 36 countries with robust data from independent sources on illicit trade would reduce total cigarette consumption by 1.9 %. The study also confirmed that tax revenue from legal cigarette sales would increase by 11.2 % in these countries.[2].

The Protocol's tracking and traceability system

• Definition

"Tracking and tracing" means the systematic monitoring and reconstruction, by competent authorities or any person acting on their behalf, of the route or movement of items throughout the supply chain. (Article 1.14 of the Protocol)

• Objective

The objective of the tracking and tracing system is to secure the supply chain and facilitate investigations into illicit trade in tobacco products (Article 8.1) and to assist Parties in determining the origin of tobacco products, the point of diversion where applicable, and to monitor and control the movement of tobacco products and their legal status (Article 8.4.1).

In practice, a tobacco product tracking and tracing system must enable any authorized user to identify the current, past and future location of all tobacco products.

• Obligations of the tracking and tracing system

In accordance with the Protocol, each Party requires that unique, secure and irremovable identification marks, such as codes or stamps, be affixed to all unit packets and any other external packaging such as cartridge packaging.

In addition, each Party requires that information be made available, either directly or through a link. This information is intended to assist Parties in determining the origin of tobacco products, the point of diversion - if applicable -. It allows for monitoring and controlling the movement of tobacco products and their legal status. This information is: the date and place of manufacture, the manufacturing unit, the machine used to manufacture the tobacco products, the production shift or time of manufacture, the name of the first purchaser who is not affiliated with the manufacturer, the invoice number, the order number and payment status, the market in which the product is intended to be sold at retail, the description of the product, the storage and shipping of the product if applicable, the identity of any known subsequent purchaser and the intended route, the date of shipment, the destination, the point of departure and the consignee. In accordance with Article 8.4.2, information relating to the date and place of manufacture, the manufacturing unit, the description of the product and the market on which the product is intended to be sold at retail must form part of the unique identification mark.

The Protocol's tracking and tracing system obligations require the establishment of an international tracking and tracing regime within five years of the Protocol's entry into force, with a "global focal point for information exchange" within the FCTC Secretariat; parties will also be required to establish national/regional tracking and tracing systems.

• Avoiding Tobacco Industry Interference

The Protocol clearly states that the obligations assigned to a Party shall not be carried out by or delegated to the tobacco industry (Article 8, paragraph 12). Furthermore, Article 8.2 states that the tracking and tracing system is “Party-controlled” and Article 8.13 states that each Party shall ensure that its competent authorities, when participating in the tracking and tracing regime, do not interact with the tobacco industry and those representing the interests of the tobacco industry except to the extent strictly necessary for the implementation of this Article.

Tobacco manufacturers have developed their own traceability system called Codentify, which results in a visible code printed on tobacco packaging. Codentify was originally developed, owned and patented by Philip Morris International and licensed free of charge in 2010 to its three main competitors (British American Tobacco, Imperial Tobacco and Japan Tobacco International). In 2016, the technology and copyright of Codentify were transferred to a new company, called Inexto, with the aim of displaying independence from the tobacco industry in order to meet the obligations of the Protocol.[3].

With the exception of the European Union, most Parties have not provided specific information on tobacco industry interference in their respective reports submitted to the FCTC Secretariat pursuant to Article 32 of the Protocol. An internal tobacco industry document on Codentify suggests that the industry has developed a strategy to circumvent the independence requirements of Article 8[4]The document states that tobacco companies would license Codentify's technology free of charge in a specific market to "credible" third-party vendors who would, in turn, promote Codentify on their behalf.[5]The Tobacco Control Research Group (TCRG) at the University of Bath has compiled a list of third parties that have promoted Codentify, including ATOS and FractureCode.[6]. For governments, it remains difficult to determine which companies are defending the interests of the tobacco industry or are truly independent. This is why the EU has adopted criteria for assessing independence in the context of track and trace system operators.[7].

The EU says its system operates completely independently of industry[8]-[9], but one key criterion is missing. Despite EU guidelines on independence, TCRG research found that seven of the eight organisations approved by the EU as data repository providers had pre-existing commercial links with industry, which in some cases specifically involved the Codentify system.[10]One of the criteria missing from the EU rules is that data storage service providers and unique identifier generators must not have had any previous links with the development of the tobacco industry's tracking and tracing solutions for at least five years.[11].

The organisations that generate the unique identifiers may be linked directly or indirectly to tobacco manufacturers within the EU system. Atos, for example, is the company that generates the unique identifiers in the Netherlands.[12]. This problem exists in other EU countries. In 2016, the Bundesdruckerei, responsible for unique identifiers in Germany, conducted a pilot project on traceability with major tobacco manufacturers.[13].

Tobacco industry interference also exists in other regions - traceability systems in Burkina Faso[14], in Senegal[15], in Mali[16] and in Ecuador[17] are managed by tobacco manufacturers. Ecuador previously used a system managed by a company, Sicpa, which offers an independent system. But the country has adopted new legislation that specifies that from April 1, 2022, the importer or manufacturer is responsible for implementing a system of authentication, tracking and tracing of cigarettes. Chad[18] and Ivory Coast[19], both of which had traceability legislation based on Codentify, are currently reviewing their systems. Senegal also intends to equip itself with a new traceability system[20].

An additional way to circumvent the Protocol's restrictions on industry interference is through the software needed to generate unique identifiers. Inexto, which focuses on software, says: Inexto is a leading provider of software and services for authentication, secure serialization, track and trace, and production volume verification. Our technology already secures more than 100 billion products per year.” In the court case concerning the tender for the tracking and tracing system in Pakistan, Inexto has forwarded documents in which the company claims that “Inexto has provided or supported our software with track and trace or digital verification systems with integrated code databases in over 35 countries »[21]. (These 35 countries include EU countries Burkina Faso, Ghana and Ivory Coast, as well as third countries such as Mexico and the Russian Federation).

The initial Codentify code was developed so that tobacco manufacturers could access the data stored in the database[22]. Providing software to generate unique identifiers may be the easiest way for companies to access traceability data. In a digital world, adding features to software gives companies many control options.

In the EU system, tobacco companies pay for and choose auditors who must monitor the activities of databases and report irregularities in access. External auditors must be approved by the European Commission, but their names and reports are not made public. Inexto’s claims that it provided the software for the EU system should not be taken for granted, but require independent scrutiny.[23]. The auditors of the European system, appointed by the tobacco manufacturers, probably do not check whether the software of the unique identifiers was developed without the intervention of the tobacco industry or whether it was provided by Inexto.[24]It is not part of their mandate and is not in their interest to carry out such checks since they have been appointed by the tobacco manufacturers.

Tobacco industry interference in the generation of unique identifiers can be avoided by not entrusting this task to the tobacco industry, or to a third party company acting on its behalf. Furthermore, there should be no use of software provided by tobacco companies and their subsidiaries. Software for generating unique identifiers could come, for example, from specialized agencies such as the United Nations International Computing Centre (UNICC). UNICC is already working with the Secretariat of the Framework Convention on Tobacco Control on the development of the global focal point for information sharing.

• Status of the tracking and tracing system within the Parties

Tracking and tracing systems exist in both Parties and non-Parties to the Protocol. In the Russian Federation, for example, a tracking and tracing system for tobacco products was established in 2019.[25]. The Russian Federation is a party to the FCTC but not yet to the Protocol. In this study, only the monitoring and tracing systems of the Parties to the Protocol were examined.

As of May 2023, 67 Parties have ratified the Protocol. According to the classification used by the World Bank, 28 Parties to the Protocol are high-income countries, 15 are upper-middle-income, 14 are lower-middle-income, and 10 are low-income.[26]The first global progress report found that the current level of implementation of the Protocol in almost all low- and lower-middle-income Parties was rated as low by Parties during the reporting period.[27]. In 2021, a specific survey by the FCTC Secretariat on tracking and tracing systems found that twenty-three Parties reported having implemented a tracking and tracing system, while five Parties reported that they would implement a system within the next two years. Most Parties reported that it took between two and five years to plan and implement a tracking and tracing system. Not all Parties responded to this survey.[28].

Information on the characteristics of existing tracking and tracing systems in Parties remains limited. Better knowledge and further assessment of current systems could lead to better practices and facilitate the establishment of tracking and tracing systems for future Parties to the Protocol. Based on publicly available information, such as responses to the survey on tracking and tracing systems, reports submitted by Parties to the Meeting of the Parties (MOP)[29] to the Protocol and the overall progress report on the implementation of the Protocol[30], thirty-seven existing tracking and tracing systems were identified among the Parties and are classified into the following categories:

(a) Tracking and tracing systems based on the EU system :

EU, Austria, Belgium, Croatia, Cyprus, Czech Republic, France, Germany, Greece, Hungary, Lithuania, Latvia, Luxembourg, Malta, Netherlands, Portugal, Slovakia, Spain, Sweden + UK (outside EU, but largely based on EU regulations) (Total: 20 Parties).

(b) Tracking and tracing systems based on tax stamps:

Saudi Arabia (De La Rue), Brazil (Ceptis based on Sicpa technology), Egypt[31] (Authentix), Kenya (Sicpa), Mauritius[32] (Holistic India), Pakistan (Authentix, MITAS corporation & AJCL)[33]-[34], Togo (Sicpa)[35], Türkiye (Sicpa), Ghana (De La Rue)[36], Qatar (From The Street)[37]-[38]. (Total: 10 parts).

(c) A variety of other systems, including systems for which there is insufficient public information to classify them:

Burkina Faso (Inexto), Comoros, Ecuador (managed by the tobacco industry), Iraq, Islamic Republic of Iran, Mali (National Tobacco and Match Company of Mali, Sonatam), Senegal (managed by the tobacco industry), (Total: 7 Parties).

(d) No system or no information in the database on the implementation of the Protocol:

Benin, Cape Verde, Costa Rica, Eswatini, Fiji, Gabon, Guinea, Madagascar, Moldova, Mongolia, Nicaragua, Nigeria, Niger, Paraguay, Rwanda, Serbia, Seychelles, Sri Lanka, Turkmenistan, Uruguay. (Total: 20 Parties).

e) Under preparation and not yet fully operational:

Chad, Congo[39], Ivory Coast, Gambia (Sicpa)[40], Kuwait (From the Street), India[41], Panama and Samoa. Norway and Montenegro should develop a monitoring system based on EU regulations. (Total 10 Parties)

• The effectiveness of traceability systems at national and regional levels

Tracking and tracing systems should operate at the national, regional and global levels. The objective of the Protocol is to have a global system based on national and regional systems. Tracking and tracing systems should facilitate investigations into illicit trade in legally manufactured cigarettes, not illegally manufactured and unmarked cigarettes. The focus is on controlling legal trade, but illegal manufacturing is not entirely excluded from the scope. Better control of the supply chain (transport, storage facilities and retailers) could help combat illegally manufactured cigarettes.

• National systems

The global system does not yet exist, but the effectiveness of national tax stamp regimes is well described in the literature. The 2011 IARC Handbook on the Effectiveness of Tax and Pricing Policies for Tobacco Control[42] and the World Bank's 2019 report on combating illicit tobacco trade[43] examined the effectiveness of improved tax stamp-based traceability systems in California, Washington State, Brazil, Ecuador, and Kenya. They appear effective within limits. The World Bank report's chapter on Kenya is very positive about combating illicit cigarette trade in the domestic market.[44]. National tax stamp systems focus on tax revenue collection, improved tax administration and supply chain control at the national level. The traceability system works well at the national level, but needs to be improved to work at the global level.[45]-[46]The export market is generally excluded from tax stamp regimes, unless the export market requests it.

The Philippines, a non-Party to the Protocol, recently extended the use of revenue stamps to exports.[47]In Kenya, tobacco products intended for export do not bear revenue stamps, but are marked in accordance with the legislation of the importing country.[48]. Packages falsely exported and re-imported into Kenya can therefore be easily spotted on the Kenyan market.[49]. Revenue stamp programmes generally focus on individual packages and not on other external packaging such as cartons, crates or pallets. As such, revenue stamp systems are not consistent with the obligations of the Protocol. The provisions of the Protocol apply to the export market, free zones, duty-free sales and transit trade and require unique identification also on the external packaging of all tobacco products.

• Regional systems

The EU Traceability System is a regional tracking and tracing system for tobacco products. The system has been operational since May 2019 and stored data on 112 billion unique tobacco product identifiers as of February 2023.[50]. So far, no report on the effectiveness of the EU traceability system has been published.[51].

In a survey of EU member states[52], some countries said that the requirement to place a unique identifier should significantly limit the possibility of introducing illicit products onto the EU market.

Two EU countries added that the traceability system was a powerful tool for national authorities investigating smuggling and other crimes. Another EU country considered the traceability system to be useful to some extent, due to the improvement of the databases in place. However, not all EU countries consider the traceability system to be useful in reducing illicit trade and detailed information on how the EU system actually works is lacking.

A detailed report on the results of the EU traceability system would be useful for the EU and other regions. For example, a description of the investigations based on trace data conducted by Member States and the European Anti-Fraud Office, the results of the investigations, the analysis of data at EU and Member State level to measure the illicit market, suspicious exports, sudden changes in export patterns of cigarette brands, oversupply in shops and locations close to the border of high-tax countries would provide useful insights into how tracking and tracing helps to monitor and investigate illicit trade.

• Evaluation criteria for tracking and tracing systems

A global tracking and tracing system could help secure the supply chain and facilitate investigations into illicit trade in tobacco products, if enough Parties have a tracking and tracing system covering all Protocol obligations, based on robust data, without interference from the tobacco industry, with access to unique identification marks outside the jurisdiction and mutually recognizable data.

• Do enough Parties have tracking and tracing systems?

The Protocol currently has 67 Parties - a number that is probably sufficient to operate, but not enough to resolve all investigations into illicit trade worldwide -. It was not expected that all Parties to the FCTC would become Parties to the Protocol. However, more Parties are still needed to meet the objectives of the text. In particular, some Parties to the FCTC, such as the main countries where cigarette manufacturers and producers are located, free zone countries, and countries of origin of illicit cigarettes, are not included. It is also of concern that the number of tracking and tracing systems in place among Parties is low, estimated at 37 out of 67 Parties (55 %). Ten other Parties have a system under development.

In the Convention Secretariat's report on financial resources and assistance mechanisms, Parties indicated that they needed technical assistance and resources to establish a tracking and tracing system, " with most Parties recognising that once tracking and tracing systems are in place, these could help to cover some of the costs of implementing and maintaining the implementation of the Protocol »[53].

Low-income and lower-middle-income countries, in particular, reported challenges in implementing the Protocol and establishing a tracking and tracing system.

• Degree of coverage of all obligations arising from the Protocol

There are several criteria to consider in assessing compliance with the Protocol. First, does a Party have a cigarette tracking and tracing system in place or under development? Second, does this system apply only to cigarettes or also to other tobacco products? The Protocol applies in principle to all imported and manufactured cigarettes, whether intended for domestic consumption or export (Article 8, paragraph 2) but the coverage of the traceability market may vary. In Mauritius, revenue stamps do not apply to exports, duty-free sales and free zones.[54]. The EU traceability system applies to exports and cigarettes for use in Member States, but in the case of imports, the system only applies to cigarettes destined for or placed on the EU market (Article 15(1) of the EU Tobacco Products Directive) and not to cigarettes imported in transit. It is not possible to tackle the illicit tobacco trade without monitoring and controlling export practices, including products in free zones.[55]. Information is needed on whether traceability systems cover imports, exports, transit trade, duty-free sales and free zones.

The Protocol applies to all outer packaging of cigarettes (single packets, cartons, cases and pallets). During international transport, cigarette packets are part of a larger outer packaging. This requires a unique marking on all packages and a link between the different markings. Without aggregation links between packets, cartons, cases and pallets, all pallets would have to be opened and all cigarette packets individually scanned. With aggregation, all the packets contained within a pallet need only be scanned by scanning the unique identifier. As such, the Protocol does not require aggregation, but in practice, aggregation is necessary to recreate the movement of goods throughout the supply chain. Thirty-three Parties responded in their respective reports submitted to the Convention Secretariat, in accordance with Article 32 of the Protocol, that the system applies to all outer packaging of cigarettes[56].

• Guaranteed interoperability?

Interoperability refers to the essential capability required for different products or computerised systems to connect and exchange information with each other. Traceability systems are based on unique identifiers affixed to cigarette packs. The unique identifiers should allow access to key information (date, location, manufacturer, brand description, destination) at the time of capture and to more detailed information through a link to the database. The exchange of data at the international level should take place through the global focal point for information exchange, upon request of a Party, on the basis of a unique identifier applied to an individual pack. Without access to the unique identifier, there is no way to establish a link to the database or the global focal point for information exchange.

Unique identifiers are accessible if they are human-readable or included in an open standard data carrier, such as a QR code. Unique identifiers are sometimes invisible and included in the tax stamp. The content of the unique identifier may be encrypted or coded. In these conditions, access to the data and unique identifiers is only possible for authorised agents at national level, via a national or regional application or device, and not for agents outside the jurisdiction. In the EU, unique identifiers are both human-readable on packages and included in open data carriers.

The key information contained in the unique identifier is, however, available in coded form and is only accessible to authorised EU officials. For a global traceability system to function, it is necessary to know whether the unique identification codes/marks and the key information they contain (date, place, manufacturing unit, destination market and product description, Article 8.4.2) will be recognised beyond the original jurisdiction. It would be useful to have an up-to-date library of unique identification codes, their structure and images. It would also show how the unique identification codes are affixed to packaging, including whether the marking systems are stand-alone or combined with a tax stamp.

At a later stage, the Parties should decide on the use of international standards for data structuring and encoding when sharing data through the global focal point for information exchange. So far, the Parties can decide for themselves how they record, structure and encode data in their national or regional database. However, when data exchange between the Parties is organized, international standards for data formatting, messaging and electronic data exchange will be necessary to ensure interoperability.

• The need for reliable data

Reliable data requires a range of control measures, some of which are outlined below:

• Provide that identifiers on packages are unique (non-sequential, non-predictable and non-reproducible), irremovable (e.g. via an anti-fraud device) and secure (with a high-quality set of security features) generated by a third party independent of tobacco manufacturers.
• Have control equipment at the point of manufacture or throughout the supply chain to scan and record the unique identifier and to verify the anti-fraud devices and the application of the unique identifier on each package, cartridge, case and send it in real time to the national or regional database.
• Report all product transactions in the supply chain in real or near real time to the national or regional database.
• Select independent auditors by national authorities to monitor the software and the generation of unique identification codes, without interference from the tobacco industry, to monitor the application of unique identification codes at the place of manufacture and access of data to the national or regional database.

©Generation Without Tobacco

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[1] Joossens L, Merriman D, Ross H, Raw M. The impact of eliminating the global illicit cigarette trade on health and income. Addiction. 2010;105(9):1640-1649. doi:10.1111/j.1360-0443.2010.03018.x [2] Goodchild M, Paul J, Iglesias R, Bouw A, Perucic AM. Potential impact of eliminating illicit trade in cigarettes: a demand-side perspective. Tob Control. 2020. doi:10.1136/tobaccocontrol-2020-055980 [3] Gilmore A, Gallagher A, Rowell A. The tobacco industry's elaborate attempts to control a global track and trace system and fundamentally undermine the Illicit Trade Protocol. Tobacco Control 2018 doi: 10.1136/tobaccocontrol-2017-054191. [4] Hill M. Digital Tax Verification (DTV) Codentify, the industry standard, 2010. [5] Gilmore A, Gallagher A, Rowell A. The tobacco industry's elaborate attempts to control a global track and trace system and fundamentally undermine the Illicit Trade Protocol. Tobacco Control 2018 doi: 10.1136/tobaccocontrol-2017-054191. [6] Gallagher AWA, Gilmore AB, Eads M, Tracking and tracing the tobacco industry: potential tobacco industry influence over the EU's system for tobacco traceability and security features, Tob Control, 2020;29:e56-e62. [7] Commission Implementing Regulation (EU) 2018/574 of 15 December 2017 on technical standards for the establishment and operation of a traceability system for tobacco products, Official Journal of the European Union, L 96, 16.4.2018, p. 7-55. [8] Borkowski, F., & Twomey, C. (2019). European Union: Confronting Illicit Tobacco Trace: An Update on EU Policies. In: Confronting Illicit Tobacco Trade: a Global Review of Country Experiences. WBG Global Tobacco Control Program Washington, DC: World Bank Group. [9] European Commission, Final Report: Support Study to the report on the application of Directive 2014/40/EU, Brussels, May 2021. [10] Gallagher AWA et al, ibid. [11] Framework Convention Alliance, Policy Briefing, Why the EU tracking and tracing system works only for the EU, https://www.fctc.org/wp-content/uploads/2019/07/FCA-Policy-Briefing_Why-the-EU-tracking-and-tracing-systems-works-only-for-the-EU.pdf. [12] https://ec.europa.eu/health/sites/default/files/tobacco/docs/tt_id_issuers_en.pdf [13] Gallagher AWA et al, ibid. [14] Republic of Burkina Faso, Joint Decree No. 2015-0356/MICA/MEF of 28/12/2015 establishing a system of authentication, monitoring, traceability and tax verification of tobacco products manufactured or imported into Burkina Faso, based on codentify standards. [15] Republic of Senegal, Interministerial Order establishing a system for monitoring and tracing tobacco products, May 4, 2021. https://assets.tobaccocontrollaws.org/uploads/legislation/Senegal/Senegal-TT-Intermin.-Order-national.pdf [16] Republic of Mali, Interministerial Order No. 2019-1184/MCC-MEF-MDIPI/SG of April 17, 2019 establishing a system for monitoring and tracing tobacco products manufactured and imported into Mali, Official Journal of the Republic of Mali, May 10, 2019, pages 510-511. https://sgg-mali.ml/JO/2019/mali-jo-2019-14.pdf [17] Servicio de Rentas Internas (SRI), Ficha Tecnica, Para proveedores del servicio de identificación, marcación, autentificación, rastreo y trazabilidad fiscal, Gobierno de la Republica del Ecuador, Quito, 2021. [18] Order 234 of December 28, 2015 establishing a system of authentication, monitoring, traceability and digital tax verification of certain consumer products, manufactured or imported into the Republic of Chad, based on the Codentify solution. [19] Interministerial decree of August 17, 2016. http://clucod.org/Ressources/docs/ARRETE_INTERM.pdf [20] Ba O, Senegal's experiences in the process of ratification/accession to the Protocol to Eliminate Illicit Trade in Tobacco Products and its national implementation, February 15, 2023, Sali, Senegal. [21] Inexto, Certificate of statement to Federal Board of Revenue in Islamabad, 23/9/2019, Lausanne [22] US Patent application, publication, US 2014/0122353A1,1 May 2014 [23] Inexto, Certificate of statement to Federal Board of Revenue in Islamabad, 23/9/2019, Lausanne [24] European Commission, Guidelines on annual audit reports to be submitted in accordance with Article 15(8) of Directive 2014/40/EU in the context of the EU traceability system for tobacco products, 2020/C 167/01, Official Journal of the European Union, 15/5/2020. [25] Official website of the Chestny ZNAK state track & trace system. https://chestnyznak.ru/en/ [26] FCTC/MOP/2/8, Financial resources and mechanisms of assistance: progress in developing the Protocol implementation assistance strategy, 17 June 2021 [27] FCTC/MOP/2/10/REV.1, Performance and Progress report, August 20, 2021. [28] FCTC, Collection of information on tracking and tracing systems Supplementary information for MOP2. [29] Article 8 Illicit Trade Protocol– WHO FCTC Implementation Database [30] https://untobaccocontrol.org/downloads/fctc/protocol-gpr/Protocol-Global-Progress-Report.pdf [31] How the Arab Republic of Egypt recovered millions in lost tobacco excise taxes. https://authentix.com/wp-content/uploads/2020/04/Case-Study-SPS-Egypt.pdf [32] Reconnaissance International, Tax stamps & Traceability: a market and technical update, Hexham, 2020. [33] Tax Stamp & Traceability News, Pakistan get green light to implement Track & Trace, August 2021. [34] Delegation of Pakistan, Overview of track and trace system in Pakistan, Power Point Presentation, Geneva, October 24, 2022. [35] Africa Times, Tracking scheme a turning point for Togo's economy and public health, 21 July 2021.https://africatimes.com/2021/07/21/tracking-scheme-a-turning-point-for-togos-economy-and-public-health/ [36] De la Rue, Annual report 2022, Hamshire. Page 9, www.delarue.com [37] Tax Stamp & Traceability News, Qatar and Bahrain to start using tax stamps, August 2021 [38] Ban on cigarettes, tobacco products without tax stamps goes into effect, The Peninsula Qatar, February 1, 2023. [39] Faapa, The Authentix company is committed to guaranteeing the traceability of petroleum products, January 11, 2023. https://www.faapa.info/blog/la-societe-authentix-sengage-a-garantir-la-tracabilite-des-produits-petroliers/ [40] Jallow M, Conteh F, Gambia Signs Agreement with SICPA To Boost Revenue, Foroya, 27 February 2023. [41] Ross H, Joossens L, Tackling illicit tobacco during COVID-19 pandemic, Tob. Induc. Say. 2021;19(June):47 DOI: https://doi.org/10.18332/tid/137086 [42] IARC handbooks of cancer prevention. Effectiveness of Tax and Price. Policies for Tobacco Control. Volume 14, Lyon, 2011. [43] Confronting Illicit Tobacco Trade: a Global Review of Country Experiences: Confronting Illicit Tobacco Trade: a Global Review of Country Experiences (English). WBG Global Tobacco Control Program Washington, DC: World Bank Group. http://documents.worldbank.org/curated/en/677451548260528135/Confronting-Illicit-Tobacco-Trade-a-Global-Review-of-Country-Experiences [44] Confronting Illicit Tobacco Trade: a Global Review of Country Experiences: Confronting Illicit Tobacco Trade: a Global Review of Country Experiences (English). WBG Global Tobacco Control Program Washington, DC: World Bank Group. http://documents.worldbank.org/curated/en/677451548260528135/Confronting-Illicit-Tobacco-Trade-a-Global-Review-of-Country-Experiences [45] WHO technical manual on tobacco tax policy and administration, Geneva, 2021. [46] Sovereign Border Solutions, FCTC Protocol to Eliminate Illicit Trade in Tobacco Products, Guidebook on Implementing Article 8: Tracking & Tracing, Commissioned by Framework Convention Alliance, Ottawa, 2019 [47] Tax Stamp & Traceability News, Philippines to remove tax stamp exemption on exports, March 2021 [48] The Excise Duty Act, 2015, Kenya Gazette Supplement No. 181 (Acts No. 23), Nairobi, 6th November, 2015. [49] Confronting Illicit Tobacco Trade: a Global Review of Country Experiences: Confronting Illicit Tobacco Trade: a Global Review of Country Experiences (English). WBG Global Tobacco Control Program Washington, DC: World Bank Group. [50] https://health.ec.europa.eu/tobacco/product-regulation/systems-tobacco-traceability-and-security-features_en [51] European Parliament, Answer given by Ms Kyriakides on behalf of the European Commission, 15/2/2023, Parliamentary question - E-004053/2022(ASW). https://www.europarl.europa.eu/doceo/document/E-9-2022-004053-ASW_EN.html [52] European Commission, Final Report: Support Study to the report on the application of Directive 2014/40/EU, Brussels, May 2021. [53] FCTC/MOP/2/8, Financial resources and mechanisms of assistance: progress in developing the Protocol implementation assistance strategy, 17 June 2021 [54] Convention Secretariat, Technical Webinar, Tracking and Tracing of Tobacco Products, July 8, 2021. [55] Joossens L, Raw M, From cigarette smuggling to illicit tobacco trade, Tobacco Control 2012; 21:230-4. [56] Article 8 Illicit Trade Protocol– WHO FCTC Implementation Database National Committee Against Smoking |