Luk Joossens, Senior Advisor, & Erin Roman, Policy and Communications Manager. Smoke Free Partnership, Brussels, Belgium.

Thirty years ago, the main type of illicit trade was large-scale cigarette smuggling: containers of cigarettes were exported, legally and duty unpaid, to countries where they had no market, and where they then disappeared into the contraband market. More traceability was considered as one of the measures to combat this type of cigarette smuggling.  The aim of Tracking and Tracing (T&T) was to facilitate investigations on illicit tobacco trade.  

The EU has a T&T system for cigarettes and roll your own (RYO) tobacco since 2019 and for other tobacco products (including water-pipe tobacco and heated tobacco products) since 2024. The system has access to billions of data points to monitor the supply chain of tobacco products. For example, as of February 2023, the system held data on 112 billion unique identifiers for tobacco products. Those unique identifiers should reveal when and where the tobacco products were produced, information on their transport across the supply chain, their final destination and the delivery to the final retail outlet.   

Although the EU T&T system has been operational for six years, there is still no report on its effectiveness. An extensive report on the results of EU traceability system would be useful to provide insights on how tracking and tracing assist in the monitoring and investigation of illicit trade. For instance, the report could contain a description of the investigations based on tracking data by Member States and the European anti-fraud office, the outcome of the investigations, the use of checks if products have valid security features to signify that they are genuine,  the access to and the use of the data (customs, finance, health, police, others), the analysis of the tracking data at EU for the measurement of the illicit market, suspicious exports, sudden changes of export patterns of cigarette brands, oversupply to shops and locations near the border of high tax countries.   

In a report commissioned by the European Anti-Fraud Office (OLAF), it was suggested that the T&T system could provide an early warning function. “Regular analysis of T&T data can provide a monitoring function alerting relevant authorities and researchers to notable changes in observed patterns and trends. Conceivably, a system of “red flags” could be set up to automatically trigger notifications of areas that may merit further examination via other analytical methods.”  

Research has shown that econometrics and statistical analysis of the T&T data have the potential to guide enforcement efforts successfully to the areas of illicit traders’ activity by observing suspicious trends of the legal sales at the retail level.  

 At the Smoke Free Partnership, we estimate that by the end of 2025, the EU will have required the affixing of 180 to 200 billion unique identifiers to tobacco products. In an era defined by artificial intelligence and big data, it is rather surprising that these data are not being leveraged to analyse suspicious trends and combat illicit trade 

At the global level, the WHO FCTC Protocol to Eliminate Illicit Trade in Tobacco Products was adopted in 2012 and came into force in 2018. The strongest provision of the Protocol is Article 8 on tracking and tracing. The Protocol established an interim solution for the global information-sharing focal point, in place since September 2023. The purpose of the focal point is to enable Parties to make enquiries and to receive relevant information.  At the Third Meeting of the Parties in February 2024, it was decided that Parties will be required to nominate authorities and individuals who should have access to the system from their territory or region. As Parties are still in the process of designating administrators at the national and regional levels for the global information-sharing focal point, no statistics from the system or qualitative data are yet available.
 

Track and trace is on the agenda of the Fourth Meeting of the Parties taking place in November 2025. While 57% of the Parties reported that they have a T&T system in place, there remains still an urgent need for more technical and financial assistance to set up similar systems in low and middle-income countries, with a special emphasis on independent information technology support at country level. For the Parties who have a T&T system, there is an urgent need to demonstrate that their systems are effective in combating illicit trade. Best practices and more involvement of law enforcement agencies will be key in achieving this aim.  

The EU has a Tracking and Tracing system for tobacco products, but we do not know whether the EU is using the system or whether the data facilitate the investigations. We also do not know either whether all relevant law enforcement agencies (such as the police) have access to the EU data. At the global level, an interim global information-sharing focal point exists, but is still not operational in 2025. More technical and financial assistance, more information on best practices and more involvement of law enforcement agencies are recommended to be discussed at the Fourth Meeting of the Parties.  

Luk Joossens, Senior Advisor, & Erin Roman, Policy and Communications Manager. Smoke Free Partnership, Brussels, Belgium