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Saatja: Nathalie Darge <[email protected]> Saadetud: 21.11.2023 14:23 Adressaat: <=?Windows-1252?Q?Maarjo_M=E4ndmaa?=>; <"Riina Sikkut">; <"Heli Laarmann">; <"Aive Telling">; <"SM Info"> Koopia: Sipos, Tamas <[email protected]> Teema: Urgent request on recent Amendment to Implementing Regulation (EU) 2018/574 on technical standards for the establishment and operation of a traceability system for tobacco products Tähtsus: Kõrgeim Dear Mr. Maarjo Mändmaa, dear Mrs. Riina Sikkut, dear Mrs. Heli Laarmann, dear Mrs. Aive Telling, Tobacco Europe, its members, and Philip Morris Products S.A. are writing to you with regard to the recent Amendment to the Tobacco Product Directive (TPD)s Implementation Regulation 2018/574 of 1st March 2023 which has introduced changes to the EU traceability requirements which need to be implemented as of 21st December 2023. Some of these changes particularly impact ID issuers, which among other things will need to update the interfaces, details and processes by which manufacturers and importers of tobacco products will have to order Unique Identifiers to be applied to the products. Importantly, please note that Tobacco Europe, its members and Philip Morris Products S.A. have contacted All Soft Corp (formerly Allexis) to provide a detailed overview of the changes in procedures for the ordering of Unique Identifiers and to ask when the new environment would be ready for testing. All Soft Corp explained that they are still in a process of sorting out the necessary administrative formalities with competent authorities and therefore they are not able to provide a clear timeline. In the attached letter, we are sharing some of our concerns, specifically on the fact that, since the changes as result of the Amendment need to be operational by December 21st, 2023, it will be impossible to order compliant Unique Identifiers in case the Estonian ID issuer is not ready with implementation of the required adaptations before this date. We would therefore kindly request to the Tax and Customs Board of Estonia to clarify no later than Friday November 24th , 2023 whether all necessary arrangements with the Estonian ID issuer will be finalised on time (before December 21st 2023) to ensure that manufacturers can continue to order Unique Identifiers without any disruptions . We would appreciate your feedback, notably in the case this situation is not expected to be resolved on time, especially as the manufacturers will need to understand whether they can source Unique Identifiers from ID issuers in the EU member states where products are manufactured or should seek further guidance from the European Commission on possibility to use another ID issuer in case of imported products. More detailed explanation is included in the attached letter. We are looking forward to hearing from you at your earliest convenience. Yours sincerely On behalf of Tobacco Europe Nathalie Darge Managing Director NATHALIE DARGEDIRECTOR Address: Av. de Cortenbergh, 120B-1000 Bruxelles Tel. &#43;32 2 319 27 65M. &#43;32 490 57 81 49 EU Transparency Register:1496873833-97 On behalf of Philip Morris International Tamás Sipos External Affairs Director Tamás Sipos External Affairs Director T: &#43;41(79)8225374 E: Avenue de Rhodanie 50 1007 Lausanne Switzerland Delivering a Smoke-Free Future Brussels, 21st November 2023 Dear Tax and Customs Board of Estonia, The recent Amendment to the Tobacco Product Directive (TPD)’s Implementation Regulation 2018/574 of 1st March 2023 (the “Amendment”) has introduced changes to the EU traceability requirements which need to be implemented as of 21st December 2023. The technical details of the changes have been further specified in the new Technical Specifications 2.0 (the “Specifications”) and the Data Dictionary released by the Secondary Repository operator on 21st September 2023. Some of these changes particularly impact ID issuers, which among other things will need to update the interfaces, details and processes by which manufacturers and importers of tobacco products will have to order Unique Identifiers to be applied to the products. Tobacco Europe1, its members and Philip Morris Products S.A. have contacted All Soft Corp (formerly Allexis), which has been appointed as Estonian ID issuer to inquire by when they would implement the necessary changes, to provide a detailed overview of the changes in procedures for the ordering of Unique Identifiers and to ask when the new environment would be ready for testing. All Soft Corp explained that they are still in a process of sorting out the necessary administrative formalities with competent authorities and therefore they are not able to provide a clear timeline. Since the changes as result of the Amendment need to be operational by December 21st, 2023, it will be impossible to order compliant Unique Identifiers in case the Estonian ID issuer is not ready with implementation of the required adaptations before this date. For example, when placing an order for codes from manufacturers, the ID issuers will be required include the human-readable unique identifier. Failure to provide this identifier in the response will result in the EU Router withholding delivery to the manufacturers. This may result in a significant business disruption as it will disable manufacturers from the ability to manufacture and bring products into Estonia. In view of the above, we are kindly asking the Tax and Customs Board of Estonia to clarify, not later than November 24th, 2023, if all necessary arrangements with the Estonian ID issuer will be finalised on time before December 21st 2023 so that manufacturers can continue to order Unique Identifiers without any disruptions. In case this situation is not expected to be resolved on time, please inform manufacturers whether they can source Unique Identifiers from ID issuers in the EU member states where products are manufactured or should seek further guidance from the European Commission on possibility to use another ID issuer in case of imported products. Should you have any questions with regards to this issue, we remain at your disposal. Respectfully, Nathalie Darge Director, Tobacco Europe Tamás Sipos Director, Philip Morris Products S.A 1 Tobacco Europe AISBL is the umbrella organisation representing the three largest tobacco and nicotine products manufacturers, namely British American Tobacco, Imperial Brands and Japan Tobacco International.