Main responsibilities under Article 15 TPD

The TPD stipulates that all economic operators involved in the trade of tobacco products, from the manufacturer to the last economic operator before the first retail outlet, record the entry of all unit packets into their possession, as well as all intermediate movements and the final exit of the unit packets from their possession. This obligation may be complied with by the marking and recording of aggregated packaging such as cartons, master cases or pallets, provided that the tracking and tracing of all unit packets remains possible.

Recording product movements at aggregated packaging level is intended to alleviate the operational burden on economic operators (in particular wholesalers and distributors), who would otherwise need to scan each unit packet that is being handled. Aggregated-level UIs can either be requested from the competent ID issuer, or self-generated by the economic operator, based on prescribed international standards.

Each manufacturer and importer will have to transmit the traceability information they have recorded to the primary repository contracted by them. All other economic operators (e.g. wholesalers and distributors) will transmit traceability information via the router.

Transportation between different facilities is also subject to a clear set of rules: each dispatch and arrival will have to be recorded and reported to the repositories system, up to the point of dispatch to the first retail outlet, i.e. the first place in retail where the products will be made available to consumers.

Therefore, each economic operator in the tobacco supply chain should take steps in preparation to ensure that they are able to comply with the above requirements by May 20, 2019.

Click here for distributors and wholesalers responsibilities under Article 15 TPD.

Click here for manufacturers responsibilities under Article 15 TPD.

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