Document 19
For the attention of
Thank you in advance for forwarding my email to him.
With best regards,
Dear
,
My name is
I had the pleasure of meeting you on November 15
when the country visit to Romania for "Systems of Traceability and Security Features for
Tobacco Products" took place.
At that moment in time I addressed during the Q&A session a couple of questions
you were very kind to answer. The most important for us was the one referring to where
to be allowed to keep stock without UIs until depletion for a time frame of 12 months
from 20 of May 2019.
From the point of view of track& trace and considering the article 37
"Transitional provision: 1. Cigarettes (...) that were manufactured in the Union (...) before
20 May 2019 and not marked by means of unit level UIs in accordance with Article 6
may remain in free circulation until 20 May 2020." if a producer is allowed to keep in
the fiscal production warehouse for that respective year 20 May 2019 - 20 May 2020
until the stock is depleted products without codes for us it is perfect.
Your answer was that as long as the fiscal production warehouses are on the EU
territory (of course, our production facility fits this rule) the products without UIs can be
held there until depletion of the stock from the track&trace point of view.
Unfortunately we are now waiting for an official answer from our fiscal
authorities, because if by "may remain in free circulation" for them it does not necessarily
mean in a fiscal production warehouse (by definition free circulation means all taxes
paid, in the case of a production warehouse the VAT and excises are not paid so the
products are not from their point of view already in free circulation). I know you are in
the Health and Food Safety Directorate so a fiscal advice or opinion will not be taken into
consideration by our Fiscal authorities but could you please maybe advise where to ask?
This is so very important for any producer of cigarettes in Europe, I know other
producers from the European market do not seem to ever consider this as being an issue
but we are going to act solely on a written answer from our fiscal authorities, so an
opinion from an European entity would be highly appreciated.
With best regards,