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HM Revenue and Customs (HMRC) takes the restrictions in the World Health Organisation Framework Convention on Tobacco Control (FCTC) very seriously. These require that the development, implementation and enforcement of tobacco policies as part of public health policies should be protected from the influence of the tobacco industry.
Codentify is a system, developed and introduced by the major tobacco manufacturers on their own initiative through the Digital Coding and Tracking Association (DCTA). HMRC played no part in the development or introduction of the system nor did HMRC require that it be introduced. Codentify codes already feature on packs and are there regardless of any HMRC use of them. The trial HMRC is undertaking is to see whether these existing codes could help officers in the field to authenticate products and help tackle illicit tobacco. No other companies currently provide such codes.
The use of Codentify by HMRC is not part of an exercise to evaluate the wider use of potential tools available on the market. Any such exercise would be undertaken in the context of the implementation of the EU Tobacco Products Directive track and trace security feature requirements, which will be implemented by May 2019 for cigarettes and hand-rolling tobacco.
The European Commission is still considering, with Member States, proposals for new pan European security features and track and trace systems, and has yet to determine any technical specifications. HMRC are not evaluating Codentify as a track and trace tool or potential security feature; the aspects of the system being used are entirely separate from the requirements of the Directive.
The use of Codentify is not a formal pilot and there will not be reports or results to publish. Instead the trial will identify the strengths, weaknesses and usefulness of using Codentify to HMRC as an authentication tool in the field. HMRC will review this later in 2016. Some resource has been spent providing access to the system and training officers in the use of the tool. However, this has been minimal and has not been separately identified. The Department of Health leads on public health policy and has been consulted on this initiative. HMRC sees no conflict between its current use of the Codentify system and FCTC requirements.