EU Tobacco Traceability – Six Years On and Still No Evaluation

In a recent blog post at bmj.com ¹, Luk Joossens, Senior Advisor, and Erin Roman, Policy and Communications Manager at Smoke Free Partnership, shared their concerns that the tobacco traceability system implemented across the EU in 2019, as part of the Tobacco Products Directive (TPD) has yet to be officially evaluated in terms of its effectiveness in combating illicit trade. In fact, different sources have claimed illicit trade in Europe to be on the rise rather than decreasing.

Joossens and Roman describe how the traceability system has, over the past six years, produced vast amounts of data on tobacco products. As of early 2023, it had generated 112 billion unique identifiers, each linked to a product’s origin, transport history, destination, and point of retail. By the end of 2025, this number is expected to reach 180-200 billion identifiers.

The authors say a comprehensive evaluation of the system would show whether, and how EU authorities (customs, tax, health, police) are using the traceability data to investigate suspicious trends, such as unusual export patterns, oversupply near member state borders, or invalid security features. Indeed, the European Anti-Fraud Office had already suggested, five years ago, that the system could serve as an ‘early warning’ tool, triggering red flags for further investigation.