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13 December 2018

Detailed new guidance has been produced for governments implementing secure track and trace systems to tackle tobacco fraud, most notably to meet the requirements of the World Health Organisation’s Protocol to Eliminate Illicit Trade in Tobacco Products. The Protocol is an extension of WHO’s Framework Convention on Tobacco Control (FCTC) and came into force in September 2018.

To encourage compliance with the FCTC Protocol, the International Tax Stamp Association (ITSA) has produced an advisory note to ensure that the secure, non-removable identification markings required by the new measures remain capable of providing the high level protection the provisions specify and remain free from intervention by the tobacco industry.

The ITSA guidelines are based on best practice ISO standards and are intended to support and expand on the recently released expert technical report on tracking and tracing commissioned by the FCTC.

The advice draws on the recently published ISO 223821 for tax stamps, as well as other standards designed to prevent fraud and ensure a robust, secure track and trace system.

Nicola Sudan, General Secretary of ITSA, said: “The FCTC Protocol is seen as an international blueprint for the regulation of tobacco production and distribution and promises to be a game- changing move in eliminating widespread criminal activity.

“However, ITSA members are deeply concerned that the EU did not take these best practice standards into account when it finalised its own regulations and guidance on security elements for marking tobacco products.

“As a result, there is now considerable disquiet that the resulting obligatory provisions under the EU Tobacco Products Directive are weak and could be undermined by unscrupulous operators and manufacturers.

“To ensure full compliance with the Protocol, the recommendations we are making are based on established and effective international standards and are intended to expand on the expert technical report published by the FCTC.”

In terms of the Protocol requirements for secure identification markings, ITSA recommends that guidance from ISO 166782 should be used to incorporate unique authentication elements within the markings to prevent the risk of unique codes being copied, re-originated or re-used. This can be achieved by incorporating an intrinsic physical security layer into the code or by having a physical security layer sitting next to it.

In addition, ITSA suggests that ISO 129313 provides useful guidance on the role of overt and covert features that should be used to ensure the security of the authentication features.

As well as the markings themselves, ITSA also points out that the supply chain associated with security features, authentication devices and materials must be entirely independent from the tobacco industry and protected against infiltration by unscrupulous operators.

In this respect, the whole system of sourcing of security technologies and raw materials, along with their transportation, warehousing and inspection, must be secure in the same way that companies using printing processes to produce security features are required to comply with ISO 142984 to ensure their integrity.

More than 150 jurisdictions around the world use tax stamps as a means to counter smuggling, counterfeiting and tax evasion on tobacco products. As tax stamps are also explicitly mentioned in the Protocol as a means of implementing the unique markings required for tobacco products, ITSA recommends that ISO 22382 is used to make them secure and well-protected, so that they in turn can protect the tobacco goods on which they are applied and the associated excise revenues.

Nicola Sudan said: “With these new guidelines we are calling on EU governments and other Protocol parties around the world to ensure they take full account of ISO standards and set requirements in their jurisdictions which are robust and which will be effective in practice.”

The WHO FCTC Protocol is an international treaty that came into force in September 2018 and requires those governments that have ratified it to implement a track and trace system for tobacco products by 2023. More details are available at

How to Make Unique Identifiers for Tobacco Track and Trace Secure and Independent from the Tobacco Industry: A Standards-Based Approach


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