EU-CEG for cigar makers outside the EU

Who is responsible for submitting

The Directive requires manufacturers and importers of tobacco products to report product information to the competent authorities of each Member State where they intend to place the product on the market. Responsibility lies primarily with the manufacturer if it is established in the EU, primarily with the importer if the manufacturer is outside the EU and the importer is inside it, and jointly with both if both are outside the EU.

An importer is the owner of, or person with the right of disposal over, products brought into the EU. Placing on the market means making products available to consumers in the EU, including by distance sale.

Directive 2014/40/EU, Articles 2(37)-(40), 5(1), 23(1) Source

Getting a Submitter ID through EU Login

EU-CEG is open only to companies with a Submitter ID. The steps are: create an EU Login account, download and complete the Commission's Submitter ID request form with supporting official documents (for example a company registration certificate), and send it to the Commission. Assignment can take several days, and a separate identifier for transmissions follows.

A consultant or other third party may submit on a company's behalf, but registers using the manufacturer's or importer's company details, and the manufacturer or importer stays responsible for the data. The Commission charges no fee for using EU-CEG.

European Commission, EU-CEG step-by-step guide and FAQ Source

Sending the data: eTrustEx or system-to-system

There are two ways to transmit. The standalone option uses a free Commission XML creator to build the notification and then uploads the XML files through the eTrustEx web platform for DG SANTE. Larger submitters can use a system-to-system e-Delivery connection, which the Commission's IT service sets up after the Submitter ID is assigned. Files are limited to 100 MB.

The electronic format for tobacco product data is set by Commission Implementing Decision (EU) 2015/2186.

European Commission, EU-CEG step-by-step guide and FAQ Source

What a product notification contains

For each product, by brand name and type, the submitter reports all ingredients and their quantities in descending order of weight, with the reason each is used, its REACH registration and CLP classification status, and relevant toxicological data. Emission levels are reported where the Directive sets them (the tar, nicotine and carbon monoxide ceilings apply to cigarettes) and, for other products such as cigars, other emissions where available.

Submitters must also provide available market research on consumer preferences, and must report annual sales volumes per brand and type, in sticks or kilograms, per Member State. Trade secrets can be flagged as confidential, but Member States decide what they publish.

Each product gets a TP-ID in the format submitter ID-year-product number (NNNNN-NN-NNNNN), where the year is when data were first submitted.

• Ingredient list with quantities, purpose and toxicology
• Emissions data where applicable or available
• Market research and annual sales volumes
• TP-ID for each product

Directive 2014/40/EU, Article 5(1)-(6); EU-CEG FAQ Source

Timing: before placing on the market, and six months for novel products

Information on a new or modified tobacco product must be submitted before it is placed on the market. Changes in composition that affect the reported information must also be notified.

Novel tobacco products, meaning products outside the listed categories such as cigarettes, cigars, cigarillos and pipe tobacco, must be notified six months before the intended placing on the market, with a detailed description, instructions for use, ingredient and emissions data, and available studies. Cigars and cigarillos are named categories, so a traditional cigar is not a novel product.

Directive 2014/40/EU, Articles 2(14), 5(1), 19(1) Source

National fees and rules vary

The Commission does not charge for EU-CEG, but the Directive lets Member States charge manufacturers and importers proportionate fees for receiving, storing, handling, analysing and publishing submitted information. Fees, deadlines and some labelling and distance-selling choices are set nationally, so each target market must be checked separately.

Member States may also prohibit cross-border distance sales of tobacco to consumers. Those that allow them require the retailer to register in the destination country (and, for EU retailers, in the country of establishment) and to run an age verification system at the time of sale.

Directive 2014/40/EU, Articles 5(8), 18 Source

Cigar-specific points: flavours, warnings and track and trace

Cigars are exempt from the Directive's ban on characterising flavours, which applies to cigarettes and roll-your-own tobacco, unless the Commission withdraws the exemption for a category. Member States may also exempt smoking products other than cigarettes, roll-your-own and waterpipe tobacco from the information message and combined picture warnings. Where they do, each unit packet and outer package still carries the general warning ("Smoking kills - quit now" or "Smoking kills", as the Member State chooses, with a reference to cessation services) on the most visible surface covering 30 percent, plus one Annex I text warning on the next most visible surface covering 40 percent, with higher percentages in multilingual Member States.

Since 20 May 2024 the EU traceability system and the security feature requirement apply to all tobacco products, including cigars and cigarillos. Each unit packet must carry a unique identifier, applied before import for products made outside the EU, and all economic operators up to the first retail outlet must record movements. The EU importer must register non-EU manufacturing facilities and machines with a Member State ID issuer. Products made or imported before 20 May 2024 without the marking could stay in circulation until 20 May 2026.

Directive 2014/40/EU, Articles 7(12), 9, 11, 15(13), 16(3); Implementing Regulation (EU) 2018/574, Articles 6, 16, 18 Source