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Are you facing problems and seeking answers to your questions? You will find them here.
Legislative questions
Each economic operator, including retailers, may have only one identification code. Only one facility identification code may be issued for each facility.
No, an already-registered economic operator cannot be re-registered.
No, it is not necessary to notify the provider of the Track&Trace solution to the issuer of the codes (STC). The obligations related to the notification of the provider of the primary storage location to the European Commission that is placed on the manufacturer and the importer are described in Annex I, Part A of the Commission Implementing Regulation (EU) 2018/574 on technical standards for the establishment and operation of a traceability system for tobacco products (hereinafter Regulation (EU) 2018/574). The requirements for the contract on storage of data with the provider of primary storage are defined in Commission Regulation in delegated powers (EU) 2018/573 on the key elements of the agreements on storage of data, which should be concluded within the tobacco products Track&Trace system.
In the official inspections, CAFIA inspectors will access the information entered under the unique identifiers of the tobacco products in order to inspect the recorded data. This may be done at any stage of manufacturing, distribution, or sale, including at retail outlets. Track&Trace inspection will be a standard component of the inspection of tobacco products at the inspected operators. It should not entail a greater burden for retailers.
No, after 20 May 2020 it will not be possible to place cigarettes and tobacco for hand-rolled cigarettes on the market without unique identifiers. The transition period ending 20 May 2020 stipulated in Article 37 of Regulation (EU) 2018/574 during which it is possible to leave specified tobacco products that are not marked by unique identifiers in free circulation will apply only to cigarettes and tobacco for hand-rolled cigarettes made in the EU or imported into the EU prior to 20 May 2019.
According to Section 13f(4) of Act No 110/1997 Coll., the manufacturers of tobacco products are obligated to provide importers and distributors of tobacco products with the necessary equipment to enable the recording of the purchase, sale, warehousing, transport, and other handling of tobacco products, equipment capable of reading and transferring the recorded data in electronic format to the secondary storage. Provision of financial compensation for acquisition of the necessary equipment fulfils the objective mentioned in the stipulation,s and this method does not contravene the applicable legislation. The Working Group of the European Commission for the Track&Trace of tobacco products also confirmed that payment of financial compensation is an acceptable alternative to provision of the necessary equipment.
The problems of such compensation are discussed on the portal https://ontrack.sgs.com/cs-CZ/, where it is possible to register compensation requirements and also obtain additional information about all the conditions and rules of this process.
Methodology questions
Yes, transfer of the tobacco products between shops after their first placement on the market for the final consumer (i.e. tobacco products were placed at the disposal of the final consumer) is possible. If the transfer of tobacco products between the first retail shop in which the tobacco products were first placed on the market for the final consumer and other retail shops, this movement of the tobacco products need not be entered in the Track&Trace system. The events are entered in the system only up to the moment when the consignment is sent to the first retail shop.
The movement of withdrawn tobacco products must be recorded and submitted to the Track&Trace system. The report may contain unique identifiers either at the unit or group packaging level. Tobacco products to be withdrawn from the retail shops and delivered to the distributor must be recorded as received consignments after takeover by the distributor in the warehouse (within 3 hours after the event).
The sale of tobacco products to final consumers is already no longer an item for reporting in the tobacco product Track&Trace system.
It depends on the company and how it organises the sale of tobacco products to its customers, regardless of whether this concerns the retailer or final consumer. It is possible to establish an internal sale in a retail shop and then continue to sell the cigarettes as the first retailer of the tobacco products to the final consumer without needing to send information to the tobacco products Track&Trace system.
It depends on the company and how it organises the sale of tobacco products to its customers, regardless of whether this concerns the retailer or final consumer. It is possible to establish an internal sale in a retail shop and then continue to sell the cigarettes as the first retailer of the tobacco products to the final consumer without needing to send information to the tobacco products Track&Trace system.
The procedure for sending messages is regulated by 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 (hereinafter ‘Regulation 2018/754’). The structure of the data fields is given in Annex II and the requirements for recording the information is stated in Chapter VI of this Regulation. On 21 February 2019 the operator of the secondary storage Dentsu Aegis Network Switzerland AG supplied providers operating primary storage locations, issuers of identifiers, and economic operators with access to the list of specifications necessary for the exchange of data with the secondary storage location, router, and common data glossary to be used by the primary storage and the router. These documents will correspond to the data exchange mode.
The tobacco products to be returned from a retail shop and delivered to the distributor must be recorded as received consignments after takeover by the distributor in the warehouse (within 3 hours after the event). Information on the receipt of tobacco products is entered into the system according to Chapter II(3)(3.4) of Annex II to Regulation 2018/574. The field ‘Product return’ shall carry the value ‘1’. This need not concern a supplier who initially supplied the tobacco product to the retailer.
If a loss of tobacco products is ascertained, the economic operator should in substantiated cases contact the CAFIA, Ministry of Agriculture, or EC who have access to the secondary storage and are authorities able to use the provided data to obtain the Track&Trace data with the given unique identifiers. The contact data shall be provided to the economic operators on the CAFIA website. Input of the acquired unique identifiers into the Track&Trace system fulfils the obligation to request the deactivation of the unique identifiers according to Article 32(6) of Regulation 2018/754.
Information on the dispatch of a tobacco product from a facility must be submitted within 24 hours prior to the occurrence of the event. It shall be assumed that the information about this event was duly handed over after receipt of positive confirmation from the primary storage or router. The tobacco products can then be dispatched at this time.
No, such a requirement is not stipulated in the legislation.
Technical questions
If the unique identifier at the group packaging level is generated directly by the economic operator, a code must be generated for the individual unit in compliance with the ISO/IEC 15459-1:2014 or ISO/IEC 15459- 4:2014 standards or their newest equivalents. If the unique identifier at the group packing level includes the identification code of the economic operator, this is the same identification code that was obtained during registration with the issuer of the identifiers.
This will be an alphanumeric code with a maximum length of 20 characters.
The database will be accessible only to registered economic operators. At present negotiations are in progress with the supplier of the system to identify a possible solution for this requirement.
The economic subject’s identification code will be issued for an indeterminate period. In the event of a termination of operations, the registered economic operator will notify the issuer of the code (STC), which will cancel the registration of the economic operator by sending a message as stipulated in Chapter II(1)(1.3) of Annex II of Regulation (EU) 2018/574.
The registration process relies on registration through a deputy – an already-registered manufacturer/distributor will enter their buyers, and these buyers will also enter their own buyers. From the viewpoint of Regulation (EU) 2018/574, the registration process is configured to issue a code within two business days. However, during the registration process the registered operator must actively cooperate (e.g. confirm or add obligatory data, confirm the activation link). The basic registration information is described on the STC website, Track&Trace.
The unit packages of cigarettes and tobacco for hand-rolled cigarettes made in the EU or imported into the EU after 20 May 2019 must be marked with identifiers. For all other tobacco products, the T&T must be implemented by 20 May 2024. The transition period ending 20 May 2020 stipulated in Article 37 of Regulation (EU) 2018/574 during which it is possible to leave specified tobacco products that are not marked using the unique identifiers may be left in free circulation will apply only to cigarettes and tobacco for hand-rolled cigarettes made in the EU or imported into the EU prior to 20 May 2019.
The unique identifiers at the level of unit packaging may be ordered by manufacturers and importers during May 2019.
The unique identifiers at the level of unit packaging may be ordered by manufacturers and importers during May 2019.
An economic operator that sells tobacco products to both the final consumer and distributes them to retailers for resale will carry a single economic operator identification code, but will have one equipment identification code for sale to retailers (distributor role) and may have an internal retail shop with a different identification code for the equipment that can be used to transfer tobacco products from the wholesale facility and from which it is possible to sell goods to the final consumer.
This depends on whether the economic operator is capable of integrating its own code from their warehousing system into the sole identifier at the level of the group packaging. In such a case, dual scanning will not be necessary.
Traceability is related to all tobacco products, including the individual packs.
In the event of dual input of the same unique identifier, an automatic message should be sent to the economic operator from the secondary storage location in order to allow for cancellation of the initial message (stated in Chapter II(5) of Annex II of Regulation 2018/574).
Registration is done on the STC website (URL link to the portal).
We are currently preparing a technical specification that should be available on these pages on 31/10/2023, and at the same time, STC is preparing a modified test environment according to the new decree, to which all registered entities in TT will have access.
For more information about the changes and connection to secondary storage here – https://eu-secondary.dentsuaegistracking.com/
