Tobacco Act Amendments

AmCham Poland submitted comments to Deputy Minister Jarosław Neneman on the draft amendment to the Act on the Protection of Health Against the Consequences of Tobacco Use. While supporting the goal of strengthening market oversight and combating the illicit trade, AmCham raised concerns about two key areas:

1. Transforming the one-time obligation for producers to supply Track & Trace devices into a continuous obligation would shift ongoing operational costs onto producers, covering thousands of independent entities beyond their control. This is seen as disproportionate and risks regulatory uncertainty.
2. A proposed 50–60% increase in UID identifier fees is economically unjustified, given the legal tobacco sector’s significant fiscal contribution and Poland’s role as the world’s second-largest exporter. The increase could weaken competitiveness and impose additional burdens without improving market supervision.

AmCham recommends retaining the current wording of Article 10d(8) and withdrawing the planned UID fee increase.

The position paper is available here.