FCTC AIT Protocol

The World Health Organisation Framework Convention on Tobacco Control (WHO FCTC) Protocol to eliminate Illicit Trade in Tobacco Products (the ‘Protocol’) covers three main areas:


  • supply chain control;
  • law enforcement; and
  • mutual assistance


Article 6 of the Protocol focusses on the ‘registration or licensing of participants who trade in tobacco, tobacco products and tobacco product manufacturing machinery.’


In February 2016 HMRC launched a consultation on “Tobacco Illicit Trade Protocol – licensing of equipment and the supply chain.”


The TMA response to the consultation is available to view here although in summary the TMA is opposed to the licensing of the supply chain, specifically retail, for the following reasons:


  • illegal tobacco retailers tend to operate outside of conventional supply chains
  • Difficult to enforce such a scheme particularly given the lack of resources
  • The impact that such a scheme would have on legitimate retailers


Instead of licensing the TMA supports the introduction of a light touch registration scheme as is already in place in Scotland and Northern Ireland. A similar scheme is planned for Wales.


We also support a number of other alternatives to the licensing scheme which are outlined in our consultation response.


In December 2016 the Government published a summary of responses to the consultation.


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