G/TBT/W/524  
23 April 2018 
(18-2514) Page: 1/2 
Committee on Technical Barriers to Trade  Original:  Spanish  
 
  
EUROPEAN UNION - ESTABLISHMENT AND OPERATION OF  
A TRACEABILITY SYSTEM FOR TOBACCO PRODUCTS  
STATEMENT BY THE DOMINIC AN REPUBLIC TO THE COMMITTEE ON  
TECHNICAL BARRIERS TO TRADE, 21 AND 22  MARCH 2018  
The following communication , dated  20 April 2018, is being circulated at the request of the 
delegation of the Dominican Republic . 
 
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1.  By means of document  G/TBT/N/EU/505, dated 1 2 September  2017, the European Union 
provided  notification of  the d raft Commission Implementing Regulation on technical standards for 
the establishment and operation of a traceability system for tobacco products, which provides for 
the traceability of tobacco products from the manufacturer until the last l evel before the retail 
outlet , in accordance with the provisions of Articles 15 and 16 of Directive 2014/40 . The proposed 
Regulation has raised grave concerns in our tobacco industry, due to  the characteristics of the 
sector and the impacts of the Regulation.  
2.  It is important to bear in mind that : 
a. The Dominican Republic is a developing co untry with a small economy that is currently 
undertaking efforts to increase its exportable capacity, which fosters sustainable 
economic growth.  
b. Tobacco is considered  an important export for the Dominican Republic, and generate d 
total earnings of US$764.89  million  in 2016, inclu ding exports of leaf tobacco and 
manufactured tobacco .1 
c. Exports of cigars , cheroots  and cigarillos represent 85.01 % of the total exports of 
tobacco and tobacco products of the Dominican Republic, compared with cigarettes, 
which represent 0 .78%. 
d. The tobacco value chain comprise s agricultural and industrial producers and marketers , 
involving more than  120,000 direct jobs  and benefiting families, with  more than 
300,000  depend ents throughout the national territory . 
3.  In this regard , we would like to point out that Articles 12.3 and 12.9 of the Agreement on 
Technical Barriers to Trade (TBT)  indicate that Members shall give par ticular attention to  the 
special needs of  developing countries in applying  the TBT Agreement and in formulating and 
implementing standards and technical regulations.  
4.  In this regard , the application  of the aforementioned EU Regulation, as proposed, implies high 
costs and procedures that would be difficult to implement, particularly for small and medium -sized 
tobacco producers for whom  the proposed initiatives  would be  virtually unworkable . The proposal 
would therefore significantly affect exports from the Dominican Republic and would jeopardize the 
competitiveness of the sector, as the European Union is the second main export market for cigars 
manufactured in the country.  
                                                
1 TradeMap.org, 15  March  2018. G/TBT/W/524  
- 2 - 
  5.  Furthermore , given that , according to the Europe an Cigar Manufacturers Association (ECMA) , 
the consumption of cigars made by hand and by machine represents only 1.6% of the total 
consumption of tobacco products in Europe, it is considered that the charges associated with  the 
Regulation would be excessiv ely disproportionate  in relation  to the cigar sector . The reason for this 
is that the high cost of the Regulation will have to  be covered by a limited number  of final 
products, in contrast to the cigarette sector, where the cost is covered by the productio n of 
multiple millions of packages.  
6.  In this regard, the aforementioned Regulation is a source of great concern for the 
Dominican  Government and for the business sector, due to the difficulties that enterprises may 
experience if they are unable to fulfil the requirements established in the proposed system . For 
this reason, it is suggested that the proposal be revised and that the exclusion  of cigars from the 
Regulation be considered, or in any case, that alternatives such as the following be considered:  
 Elimina tion of the unique identifier ( UID) system  with pre -authorization through  
time-limited stamps , and replac ement  with a n ordinary single code system.  
 Elimination of the anti -tampering system requirement, given that it is extremely costly 
and difficult  to imp lement.  
 Reduction of the amount of complex authentication elements , as they make the process 
unnecessarily long and rigorous . 
7.  Lastly , in light of the above, we support the statement made by the Republic of Cuba, and we 
express our full readiness to maintain a fluid dialogue with the European Union for the mutual 
benefit of our nations.  
 
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