Trade in tobacco and related products in the European Economic Area (EEA)
On March 10, 2026, the government issued the Ordinance "EWR-Tabakerzeugnisverordnung" (LR 947.102.251). It serves to implement the European Tobacco Directive 2014/40/EU together with its implementing acts. This regulation governs the obligations of EEA economic operators who trade in the products in question.
The following are prohibited:
a) the cross-border sale of tobacco and related products by distance selling ;
b) the placing on the market of :
- Chewing tobacco and tobacco for oral use;
- novel tobacco products
Natural or legal persons domiciled or resident in Liechtenstein who commercially exchange tobacco products (cigarettes, cigars, roll-your-own tobacco, rolling tobacco, etc.), herbal smoking products (e.g. herbal cigarettes) or electronic cigarettes with or without nicotine with partner countries of the EEA (EU, Norway, Iceland) require a permit from the ALKVW. The exchange of goods does not require physical contact with the goods, but can also be purely monetary (e.g. Liechtenstein company buys tobacco products in a third country or an EEA country and then places them on the market in another EEA country).
No authorization is required for economic operators who only trade in tobacco and related products in the Swiss-Liechtenstein customs union or with third countries and no EEA contact.
A fee must be paid to the ALKVW to apply for a permit. The fee is CHF 6000 and must be paid into the following account before the application is processed:
Account holder
Liechtensteinische Landesverwaltung
Amt für Finanzen
Äulestrasse 38, Postfach 684
FL-9490 Vaduz
Bank details
Liechtensteinische Landesbank AG, FL-9490 Vaduz
BIC: LILALI2XXXX
CHF-Konto: IBAN LI31 0880 0000 0203 2880 0
When transferring the fees, the following details must be given in the purpose field :
No. 470.431.03.02, name and address of applicant and PEID number (legal entity)
The fee serves to cover the administrative costs associated with the application review and will not be refunded even if the permit is refused. An application for a permit must be submitted to the ALKVW at least 6 months before the intended start of operations. The list of approved businesses is published on the ALKVW website and updated at regular intervals.
Applicants must prove by submitting suitable documents that
- a certified quality management system for ensuring the compliant handling of tobacco and related products is applied ;
- a self-monitoring concept in accordance with Art. 14 of the Ordinance "EWR-Tabakerzeugnisverordnung" (LR 947.102.251) is in place;
- suitable premises and facilities are available; and
- the company employs a responsible person who exercises direct supervision and has the necessary expertise and experience.
Self-monitoring includes documented procedures to demonstrate that:
- the composition, labeling and packaging of tobacco and related products comply with the requirements of the Regulation;
- the composition and labeling of tobacco and related products placed on the market are subject to risk-based laboratory analysis and testing (sampling and analysis plan);
- a system is established and maintained to collect information on any suspected adverse effects of tobacco and related products on human health.
- the traceability and authentication of tobacco and related products is ensured at all times at all marketing stages;
- effective systems are in place to ensure the recall and withdrawal of defective products, in particular those that are dangerous and therefore harmful to health; and
- the ALKVW and other competent enforcement authorities are informed immediately in the event of the recall or withdrawal of products.
Manufacturers and importers report the prescribed, product-specific information to the European Common Entry Gate (EU-CEG) of the country in which the products are placed on the market. For tobacco products, herbal smoking products and electronic cigarettes with and without nicotine placed on the market in Liechtenstein, the product information must be reported to the EU-CEG at least 6 months before the intended placing on the market. For products already on the market, the notification must be made no later than 6 months after the Regulation enters into force, i.e. no later than 11.09.2026
The notification obligation also applies to all variations and all subsequent changes to a tobacco product or related product. For each individual notification, an annual fee of CHF 2500 must be paid to the account below.
Account holder
Liechtensteinische Landesverwaltung
Amt für Finanzen
Äulestrasse 38, Postfach 684
FL-9490 Vaduz
Bank details
Liechtensteinische Landesbank AG, FL-9490 Vaduz
BIC: LILALI2XXXX
CHF-Konto: IBAN LI31 0880 0000 0203 2880 0
When transferring the fees, the following details must be given in the purpose field : No. 470.431.03.01, Submitter ID and Product ID
Payment must be made no later than 4 weeks after the product information has been published. Registered products for which the fee has not been paid are considered to be illegally marketed and will be confiscated by the ALKVW for a fee.
Every year, an update notification must be submitted for every product that is placed on the market in Liechtenstein. The type of update notification must be specified in the "General Comment" field.
General information on the EU-CEG and assistance with the registration and notification process can be found here:
The products notified by economic operators for which the notification fee has been paid are published monthly on the ALKVW website, in compliance with business confidentiality requirements. Publishing does NOT confirm the legality/completeness of the notification or the marketability of the notified products. Marketability is checked by the ALKVW on a random basis.
The information must be provided in German or English.
The ALKVW and the notifier themselves have access to the data. The non-confidential data is published on the ALKVW website for the information of market participants and consumers.
According to Art. 5 (3) and Art. 20 (2) of Directive 2014/40/EU, manufacturers and importers are obliged, in addition to the notification of all ingredients, to include toxicological data on the ingredients and emissions of the product that are produced when heated, in particular with reference to their effects on the health of consumers when inhaled and taking into account, in particular, any addictive effects.
Any chemical ingredients of tobacco or related products are also subject to EU Regulations (EC) 1272/2008 (CLP) and (EC) 1907/2006 (REACH). Consequently, toxicological data must fulfill the requirements stated therein. Furthermore, studies should comply with the OECD principles of Good Laboratory Practice (GLP) and any other internationally recognized and validated methods to ensure the quality and validity of the data. All available information on the toxicity of each chemical ingredient and each emission should be made available in readable form (preferably as a pdf file in English or German) in the EU CEG. The specific focus should be on local and systemic toxicity of each ingredient or emission in relation to the respective type and duration of exposure (e.g. long-term inhalation). In addition to all underlying studies, a hazard assessment, such as in the form of a DNEL (Derived No Effect Level) or similar, including decisive parameters for its derivation (initial values (POD), uncertainty factors, etc.), should be included.
Manufacturers and importers who place tobacco products and related products (herbal smoking products, electronic cigarettes with and without nicotine) on the market in Liechtenstein are obliged to provide the ALKVW annually by 31 May of the following year:
a) the sales volume data per brand and type of product (in units or kilograms) for the previous year;
b) product-specific information on the preference of various consumer groups, the type of sale and summarized reports on market studies carried out.
The notification must be made to the EU-CEG.
Manufacturers and importers are obliged to equip tobacco products that they place on the Liechtenstein EEA market with security and identification features. This obligation applies to the Liechtenstein market from July 11, 2027.
Identification features
All tobacco product packages must bear a unique identifier that is indelibly printed or affixed and cannot be removed. It must not be concealed or separated, not even by tax stamps or price tags. All economic operators involved in trade in tobacco products in the EEA, from the manufacturer to the last economic operator before the first point of sale, must record the transfer of all packs into their possession, all intermediate movements and the final disposal of the packs from their possession in an electronic traceability system. EEA market participants in Liechtenstein are responsible for their own integration into the digital traceability system (repository system).
The ALKVW is the national administrator for the repository system. It has the corresponding access rights to the data stored in the repository system.
Identifiers are subject to a fee and are provided by the issuing authority designated by the respective EEA member state. Manufacturers and importers of tobacco products purchase the necessary number of unique identifiers from the issuing authority of the EEA member state that is the intended market for the tobacco products. The government will designate the issuing authority responsible for the Liechtenstein market in due course. An identification mark for the Liechtenstein market currently costs costs of CHF 2.
Security features
All tobacco product packages placed on the market must bear a tamper-proof security feature consisting of visible and invisible elements. The security feature must be indelibly printed or affixed and must be impossible to remove or alter, and must not be covered or separated, even by tax stamps, price tags, or other legally required elements. The security feature serves to verify the authenticity of packaging by the competent inspection authority.
The security feature for the Liechtenstein market must use the following combination of authentication elements:
a) Guilloche (open);
b) optically variable printing ink (open);
c) UV printing ink (semi-concealed);
d) Microprint (semi-concealed);
e) molecular taggant (concealed).
At least one of these authentication elements must be provided by an independent third party. Manufacturers and importers of tobacco products must inform the ALKVW annually by June 1 at the latest which authentication elements originate from independent providers. The independence of the provider must be proven by submitting an EEA-compliant declaration of independence.
Tobacco products and related products must comply with the labeling requirements of the Ordinance "EWR-Tabakerzeugnisverordnung" (LR 947.102.251).
Every pack and outer packaging of tobacco products for smoking must display
- the general warning "Rauchen ist tödlich — hören Sie jetzt auf",
- the information message "Tabakrauch enthält über 70 Stoffe, die erwiesenermassen krebserregend sind."
For packs and outer packaging of smoking tobacco products, the combined health warning must include the following information on smoking cessation support programs:
On each unit packet and outside packaging of tobacco products for smoking, the images of combined health warnings set out in three groups in Annex II to Directive 2014/40/EU shall be alternated annually, starting in 2026 with images from group 1 followed by images from group 2 in 2027 and images from group 3 in 2028. The change of group shall take place on 20 May of the following year.
For packages and outer packaging of tobacco products for smoking—with the exception of cigarettes, roll-your-own tobacco, tobacco for water pipes, and heated tobacco products—combined health warnings with images may be omitted provided that one of the text warnings listed in Annex I to Directive 2014/40/EU is affixed to the general warning under Article 18 paragraph 2 letter a) of the Ordinance "EWR-Tabakerzeugnisverordnung" (LR 947.102.251), one of the text warnings in Annex I to Directive 2014/40/EU is applied. In this case, the general warning must include a reference to the above-mentioned smoking cessation support programs.
Packs and outer packaging of electronic cigarettes and refill containers - if they are nicotine-free products - must bear the following health warning: "Dieses Produkt enthält Nikotin: einen Stoff, der sehr stark abhängig macht. Es wird nicht für den Gebrauch durch Nichtraucher empfohlen".
Packs and outer packaging of electronic cigarettes and refill containers - provided they are nicotine-free products - must bear the following health warning: "Der Gebrauch dieses Produktes kann gesundheitliche Schäden verursachen."
Each packet and outer packaging of herbal smoking products shall bear the following health warning: "Das Rauchen dieses Produkts schädigt Ihre Gesundheit."
Products that do not meet these requirements can still be placed on the market until March 11, 2027, provided they were manufactured correctly before March 11, 2026 (tobacco products and herbal smoking products) or September 11, 2026 (electronic cigarettes) under the old legal situation.
Publications
Links
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Systems for tobacco traceability and security features
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EU Common Entry Gate (EU-CEG) - Public Health - European Commission
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Providing information on tobacco products, e-cigarettes and refill containers - The EU Common Entry Gate (EU-CEG)
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