Overview of the Track & Trace (“T&T”) System under the EU TPD and IAs

The new T&T system is provided under Article 15 of the Tobacco Products Directive (2014/40/EU) or TPD.

The European Commission implementing regulations (collectively, the Implementing Acts or “IAs”), which entered into force on May 6, 2018, set out further details for the T&T system.


The T&T system requires the application of a track and trace code called a “unique identifier” (UI) to packs, cartons and shipping cases that are either manufactured in the EU or imported into the EU market. All economic operators from manufacturing up until and including the last economic operator (EO) before the first retail outlet will need to track all packs by recording the entry, intermediate movements, and final exit of the packs in their possession. The tracking information is collected by scanning the UIs and then transmitting them to third-party databases (called the “repositories system” under the IAs).


The effective date of implementation of this new system is May 20, 2019 for cigarettes, make-your-own and roll-your-own tobacco. For other tobacco products (including cigars, cigarillos), the implementation date is May 20, 2024.