Track and Trace – Requirements when you are an Importer

As an importer purchasing tobacco products from countries outside the EU with the intent to market in Denmark, you must be registered in the traceability system and be assigned an Economic Operator ID (EO-ID).
You must register all your facilities involved in the trade of imported tobacco products, for example, a warehouse or distribution center. Each facility is assigned a unique Facility Identifier (FID) upon registration.
You must also register production machines and specify their capacity. Machines and machine components are assigned a Machine Identifier (MID).

In addition, you must record financial transactions, such as invoices and payments, as well as information about suppliers, recipients and cross-border movements of the tobacco products. These records must be kept and made available to the relevant authorities for at least 5 years.

As an importer of tobacco products into the EU, you are responsible for registering your suppliers outside the EU with the Danish ID issuer, and with ID issuers in other countries where you, as an importer, intend to market tobacco products.
This is because manufacturers outside the EU and their facilities and machines must have ID numbers in the same way as if production were within the EU, in order to ensure the traceability of imported tobacco products.

You must ensure that your company has equipment capable of scanning tobacco products and transmitting information to the EU register (Secondary Repository). The equipment must be able to record the timing of activities such as the application of ID numbers, aggregation, and dispatch of tobacco products. The information is considered successfully transmitted once you have received confirmation from the system.

As an importer, you are responsible for ensuring that all tobacco products are marked with Unique Identifiers (UIs). The Unique Identifier must be issued by the Danish ID Issuer and must begin with either LEWL2 or QCPSQR.

In accordance with the Commission Implementing Regulation (EU) 2018/574, “all tobacco products” include: Cigarettes, Cigars, Cigarillos, Roll-your-own tobacco, Pipe tobacco, Waterpipe tobacco, Tobacco for oral use, Nasal tobacco, chewing tobacco, Novel tobacco product and Other (product placed on the market before 19 May 2014).

The following information must be reported within 24 hours after handling the tobacco products:

• Application of ID numbers (unique identifiers) to unit packets
• Application of ID numbers to aggregated packaging (multipacks)
• Receipt of tobacco products in a business
• Economic transactions, such as issuing the order number, issuing the invoice, and receipt of payment

The following information must be reported within the last 24 hours before the event (and no later than when the event occurs):

• Dispatch of tobacco products from a facility
• Transloading of products

Note: These 24-hour deadlines apply to all economic operators until 20 May 2028. After this date, most information must be reported no later than 3 hours after the event has taken place.

If you experience issues with the registration system, you should contact the ID issuer Persequor ApS (PSQR). This can be done via the contact details in the registration system at https://issuerdk.psqr.eu or by email at issuerdk-support@psqr.eu

If you experience issues reporting the movements of tobacco products, you should contact Dentsu, the operator of the EU Secondary Repository.

If you have questions about the tobacco products traceability system, you should contact the Danish Business Authority, Market Surveillance Department.

You can do so by e-mail to mo@erst.dk  or by phone at +45 3373 2000.