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Tracking and tracing the tobacco industry: potential tobacco industry influence over the EU’s system for tobacco traceability and security features
  1. Allen William Andrew Gallagher1,
  2. Anna B Gilmore1,
  3. Michael Eads2
  1. 1Tobacco Control Research Group, Department for Health, University of Bath, Bath, UK
  2. 2Sovereign Border Solutions, Cape Town, South Africa
  1. Correspondence to Allen William Andrew Gallagher, Health, University of Bath Department for Health, Bath BA2 7AY, UK; a.a.gallagher{at}


Background Subsequent to the transnational tobacco companies’ (TTC) history of involvement in tobacco smuggling, the Illicit Trade Protocol (ITP) requires that tobacco tracking and tracing (T&T) systems be established independent of the industry. In response, TTCs developed a T&T system, originally called Codentify, promoting it via an elaborate set of front groups to create a false impression of independence. The European Union (EU) is one of the first and largest jurisdictions to operationalise T&T. We explore how industry efforts to influence T&T have evolved.

Methods Analysis of tobacco industry documents, policy documents, submissions to a relevant consultation and relationships between the tobacco industry and organisations proposed by it and approved by the European Commission to provide a data repository function within the EU’s T&T system.

Findings 17 months after TTCs sold Codentify to Inexto and Philip Morris International claimed Inexto was independent, leaked documents suggest TTCs and Inexto continued to have a financial and operational relationship. Inexto’s meetings with TTCs, engagement with EU Member States and promotion of industry-favoured technical standards suggest TTCs influenced Inexto’s activities, using the company to undermine EU T&T. The EU’s T&T system appears to be inconsistent with the ITP due to its ‘mixed’ governance and seven of eight organisations approved as data repository providers having pre-existing industry business links.

Conclusions TTC’s efforts to maximise their control and minimise external scrutiny of T&T systems seriously limit attempts to address tobacco smuggling. Countries implementing T&T should be alert to such efforts and should not replicate the EU system.

  • illegal tobacco products
  • public policy
  • tobacco industry documents
  • tobacco industry
  • surveillance and monitoring

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  • Contributors All authors conceived the idea for the study. AWAG and ABG developed the research design. AWAG produced first draft and all authors edited.

  • Funding AWAG & ABG acknowledge the support of Bloomberg Philanthropies Stopping Tobacco Organizations and Products project funding (

  • Disclaimer The opinions expressed are those of the authors’ alone.

  • Competing interests None declared.

  • Patient consent for publication Not required.

  • Provenance and peer review Not commissioned; externally peer reviewed.

  • Data availability statement All data relevant to the study are included in the article or uploaded as supplementary information.

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