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<p>HM Revenue and Customs (HMRC) is responsible for implementing the track and trace
system and ensuring compliance with the WHO Framework Convention for Tobacco Control
(FCTC) Protocol to Eliminate Illicit Trade in Tobacco Products. Since the system came
into force on 20 May 2019 and there is a 12 month sell through period for unmarked
stock, HMRC’s approach has been to educate and support businesses as they familiarise
themselves and adapt to the new requirements.</p><p> </p><p>Strict criteria for determining
independence from the tobacco industry is set out in Part 5 of the Tobacco Products
(Traceability and Security Features) Regulations 2019.</p><p> </p><p>If we leave the
EU with a deal, the current arrangements will continue to apply for the duration of
the implementation period. If we leave with no deal, we will suspend the current system
while we develop a stand-alone system as quickly as possible and with the minimal
changes necessary to the current system. This would include retaining the current
independence criteria.</p>
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