Thoughts Towards ISO 22382 Revision

It is International Standards Organization (ISO) practice to review its standards every five years. So, ISO 22382, titled ‘Guidelines for the content, security, issuance, and examination of excise tax stamps’, which was published in 2018, will now go through this regular review.

The review will be conducted by ISO Technical Committee 292 (Security and Resilience) through its Working Group 4, and thanks to support from the International Tax Stamp Association, I am project leader for this review and subsequent rewriting of the standard.

In preparation for the formal ISO process, I have been talking to stakeholders – revenue agencies and suppliers – to learn their thoughts on the standard, with some very interesting (even thought-provoking) results.

There have been several significant technological developments in the last five years, which are obvious areas for revision. Digital security printing, the smartphone/network interface, unclonable functions and digital seals have all made strides towards greater useability and thus application to tax stamps, requiring expanded or new coverage in the standard.

This also applies to direct marking, where tax information is printed directly onto the product or packaging, such as beer cans.

We will also need to consider whether or how emerging standards, including the EU’s proposed digital product passport, might relate to tax stamps.

More fundamental revisions to the standard have also been suggested, such as removing ‘excise’ from the title because stamps are now used for many consumer goods where the tax is not defined as excise.

Another area of concern that has emerged is that the standard is too technically detailed, which could be off-putting for some revenue agency personnel, so it should focus more on high-level matters. Technical details, it has been suggested, can be covered in annexes, or even in a separate ‘part 2’ of the standard.

I’ve also heard from revenue agencies that they would like more specific guidance on levels of stamp security. They want to know how to grade different security features so they can choose between, say, three degrees of security.

It will be a challenge to arrive at a consensus on what comprises a very secure, rather than a moderately secure, feature or set of features, without referencing specific or proprietary features. There is a parallel in Intergraf’s implementation of ISO’s standards for the management of security printing (ISO 14298), issuing three levels of certification, so this may be worth examining.

I will be continuing this stakeholder consultation process through a workshop at the Tax Stamp & Traceability Forum™ in October, so if you want to learn more about the possible revisions to 22382, or have suggestions for the revised standard, please come to that workshop.

taxstamptraceabilityforum.com