Smuggling tobacco

Ukrainian Institute for the Future is an independent analytical
center that:
forecasts changes and models possible scenarios for events in
Ukraine;
makes a competent assessment of the Ukrainian events;
formulates specific recommendations for actions;
offers effective solutions;
offers a platform for discussions on current topics.
It is a collaborative project of representatives of Ukrainian business,
politics and the public sector.
Founded in summer 2016.
Published in the frame of the project “Combating Smuggling in
Ukraine and Bordering Countries through Monitoring, Research,
Advocacy and Changing of Public Policy” supported by the PMI
Impact. The views of the authors do not necessarily reflect the
official position of the PMI Impact.

CONTENTS
INTRODUCTION
DEFINITIONS AND TERMS USED
IN THE REPORT
AMOUNTS INVOLVED – HOW
MUCH DOES THE STATE EARN ON
TOBACCO PRODUCTS?
SMUGGLING AND COUNTERFEIT
CIGARETTES – THE MONEY
SLIPPING AWAY FROM THE STATE
RISKS FOR UKRAINE
CONCLUSIONS
03
07
11
15
37
41

3
Introduction
Tobacco products, in particular cigarettes, are a traditional contraband arti-
cle. The reason is plain to see: a great part of the price of the end product is
accounted for excises and taxes. Therefore, depending on the tax policy of dif-
ferent countries, the price of a pack of cigarettes of the same brand may differ
several-fold. It is quite natural that both residents of border territories, who pass
small batches of cigarettes for sale, and representatives of criminal networks
are trying to make money from this.
A large tax component in the price and relatively low cost incentivize another
type of illegal activity – the manufacturing of counterfeit products and/or the
use of tax evasion schemes in the manufacturing of tobacco products.
On the other hand, from the point of view of the state, tobacco taxes are one of
the main sources of replenishment of the treasury. For example, the budget of
Ukraine for 2020 assumed 57 billion UAH of excise tax revenues from tobacco
products produced in the country and another 1.45 billion – from imported ones.
This is 5.9% of the budget revenue or 11% of the total expected tax revenue for
the current year 1
. Besides the abovementioned amounts, we should also add
the factor of attracting foreign currency to the country – the revenues from the
export of tobacco products from Ukraine in 2019 amounted to $497.1 million.

4
TOBACCO SMUGGLING
The FATF report “Illicit tobacco trade” highlights the following threats associ-
ated with the illicit trade in tobacco products (smuggling and counterfeiting):
National governments’ tax losses, which leads either to the inability to finance
social programs, or to transfer part of the tax burden to other sectors in
order to obtain the necessary resources;
Illegal trade, such as smuggling and sale of counterfeit products, leads to an
increase in corruption in governmental authorities, as well as to an overall
increase in the level of crime;
Income flows from the illicit trade in tobacco products are subject to money
laundering;
Legal tobacco manufacturers deal with a loss of market share and a loss of
profits.
Needless to say, the sale of contraband and counterfeit tobacco products
“undermines all attempts to restrict youth access to tobacco products and other
measures aimed at reducing the availability of these products. When retailers
attempt to comply with national legislation and local requirements to prohibit
the sale of tobacco to minors or reduce its availability by other means, sellers of
contraband products are likely to ignore these requirements”. 2
Ukraine is one of the European leaders in terms of the volumes of export
smuggling of cigarettes. At the same time, according to companies that conduct
research on the markets of neighboring countries, it is not so much about the
illegal export of legally domestically manufactured tobacco products, but about
the production of counterfeit products with their subsequent sale both inside the
country and on foreign markets. At the same time, the share of contraband and
counterfeit cigarettes in the domestic market is rapidly growing. Today, almost
seven packs out of a hundred on the Ukrainian cigarette market are counterfeit
or contraband ones.

5
Purpose of this report:
to give the broadest picture of what is happening, including the routes of
movement of goods, the main production and sales patterns;
to estimate losses in certain segments of the market;
to formulate the risks to the state in the area of finance, security, and foreign
policy from the absence of a policy to combat illicit trade in tobacco products;
to offer basic recommendations concerning the development of effective
policies to combat illicit trade in tobacco products.
Respectfully, the group of authors of the Ukrainian Institute for the Future.

7
Definitionsandterms
usedinthereport
The terminology in this report is based on the wording used in the FATF documents,
as well as on the methodology of organizations that monitor the illegal tobacco
market (in particular, KPMG reports).
The legal tobacco market consists of products that are legally produced and sold
on the territory of the country, and official imports. It has two components:
LEGAL DOMESTIC CONSUMPTION. Cigarettes that were legally purchased and
consumed in the country. This data is based on the market sales information
provided by the tobacco industry.
LEGAL NON-DOMESTIC PRODUCTS. Cigarettes and tobacco products purchased in
another country and legally passed through the customs control (and consumed
on the territory of the country). This includes legal imports, as well as products
brought in by citizens either in compliance with established limits or with the
payment of customs duties. Illegally consumed products have a wider range of
options for entering the market. It is common practice to divide this category
of products into three main groups. However, taking into account the Ukrainian
specifics, we have identified another, fourth category:
ILLICITWHITE: cigarettes that are usually legally produced in one country but
smuggled across the border to another country where they are distributed
illegally, without paying taxes;
CONTRABAND (OTHER): cigarettes for which taxes were legally paid in one
country, but then they were transported to another country and resold
without paying taxes. These are mainly cases when the excise tax system
in the country of origin is more profitable than in the destination country.
01
02

8
TOBACCO SMUGGLING
COUNTERFEIT: cigarettes that intentionally copy legal brands, misleading
customers who are certain that they are consuming real products;
SUSPICIOUS BRANDS – cigarettes that may be fakes of brands that are
not available on the market in this country (or own private labels that
are produced and sold without paying taxes or with partial payment). In
Ukrainian reality, it is difficult to prove the fact of forgery, since there is no
fact of filing claims by brand owners and no giving of cigarette samples for
analysis.
And finally, there is another category that is present on the market of any state–
duty-free products. These are cigarettes purchased by the consumer without
paying custom or excise duties. Such cigarettes, for example, can be purchased
in duty-free stores.
In the interest of readability, the term “contraband and counterfeit”, abbreviated
as C&C, is used when illegally consumed products (without detailing by type) are
being evaluated.
03
04

11
First, let’s look at the component of the price of cigarettes in Ukraine. It is shown
schematically in the table below.
Taxes make up 75% of the price of each pack of cigarettes. First of all, this is an
excise tax, as well as a 5% retail tax and 20% VAT. The remaining 25% is shared by
manufacturers, wholesalers, and retailers.
At the same time, they pay income tax on their revenues (or a single tax, if the seller
is a sole proprietor), and pay single social security tax for their employees. And if
there are wage workers – 18% tax on personal income (from the accrued wages).
Therefore, the state additionally receives at least 10% more in the form of taxes from
that 25% of the cost of a pack of cigarettes that are the revenues of manufacturers
and trade organizations.
Amountsinvolved- howmuchdoes
thestateearnontobaccoproducts?
Table 1

12
TOBACCO SMUGGLING
In reality the situation is somewhat different. In 2019, the budget forecasted 56.7 bil-
lion UAH revenue from the excise tax on tobacco products. But the market declined
by 20% in terms of sales volumes. In our opinion, there are three main reasons for
this phenomenon:
Reduction of consumption by the population, which may be the result of a
planned increase in the price of tobacco products. However, this is most
likely not the main factor;
Labor migration – a significant part of potential consumers of tobacco prod-
ucts just left the country. Given the scale of this phenomenon, this factor is
significant in the market decline;
The growth of the share of contraband and counterfeit goods in the
Ukrainian market, which has been going on for the past few years.
As a result, in 2019 the state budget received 43 billion UAH from excise taxes on
tobacco products produced in Ukraine 3
. On the other hand, revenues from excise
taxes on imported tobacco products increased. In 2019, 1.1 billion UAH was received
(while 970 million were forecasted). Consequently, the total revenue from excise
taxes on this category of goods amounted to about 44.1 billion UAH.
Ukraine’s budget for 2020 forecasts 57 billion UAH of excise tax revenues from to-
bacco products produced in the country and another 1.45 billion for imported ones.
This is 5.9% of the budget revenue or 11% of the total expected tax revenue for the
current year 4
. The high standard is based not on the projected growth in consump-
tion, but on an increase in excise rates by 20% per year by 2025 – this is Ukraine’s
obligation under the Ukraine–European Union Association Agreement. Our country is
obliged to bring the excise tax on cigarettes to the minimum rate for EU countries –
90 euros per thousand cigarettes.
Tobacco companies have been consistently among the top ten taxpayers in Ukraine
in recent years. For example, during 9 months of 2019, the four main cigarette man-
ufacturers of the country paid the following amounts of taxes, which were published
in the Rating magazine 5
:
01
02
03

13
*There is no data about JT Ukraine in the Rating magazine table. Tax amounts are calculated
based on statistics for 9 months of 2019.
In total, the four largest cigarette manufacturers in Ukraine paid 48.879billionUAH to
the state budget. All of these manufacturers are among the TOP 15 largest taxpayers
of the country. Three of the four are in the TOP 10: ranked third, seventh and ninth.
In fact, the amount of income from the tobacco industry is slightly higher, since the
TOP 100 largest taxpayers include TOV Vinnikivska Tobacco Factory (31st place in
the ranking with about 1.7 billion UAH of paid taxes), TOV Philip Morris Sales and
Distribution with estimated amount of taxes paid about 0.9 billion UAH.
Therefore, it can be argued that the manufacturing of tobacco products, along with
the extraction of oil and gas, is one of the main sources of tax revenue – market
actors pay at least twice as much taxes as the entire metallurgical complex of the
country combined. Given the specifics of consumption, budget revenues from this
industry are more immune to declines during the crisis – bad habits and addiction to
smoking contribute to the sales of this type of product.
Table 2

15
Smugglingandcounterfeitcigarettes–
themoneyslippingawayfromthestate
Smuggling from Ukraine
It is impossible to make an accurate assessment of the volume of smuggled and
counterfeit cigarettes market in a particular country. At the same time, there are
several ways to roughly estimate it. One of them is the study on empty packs of
cigarettes – most often citizens are offered to exchange their empty pack for a
full pack of cigarettes of a legal brand. Sometimes this process is accompanied by
giving answers to a number of questions – a kind of sociological research. Despite
a fairly large sample of respondents, the data obtained can be considered close to
reality. Further, based on additional research (packs, loose cigarettes), it is possible
to determine which group this sample belongs to – whether it is contraband or
counterfeit, or products purchased in the networks of duty-free stores.
The FATF in its recommendations notes that “it is difficult to estimate the true nature
of smuggling... There are a number of useful and reliable methods for measuring
the level of smuggling, but each of them has limitations. When time and resources
permit, it is best to use several different methods to minimize all methodological
shortcomings”. 6
In this report, we are proceeding from data collected by KPMG, GFK, Taylor Nelson
Sofres Ukraine (Kantar Ukraine), which conduct part of the market researches
commissioned by tobacco companies, as well as data from customs authorities
of Ukraine’s neighboring countries and tobacco control associations in the EU and
Ukraine. This approach allows getting a more complete picture of what is happening
and assess the impact of the illegal trade in tobacco products.
Information from all the above mentioned sources suggests that Ukraine is one
of the main suppliers of smuggled cigarettes to the markets of the European

16
TOBACCO SMUGGLING
Union. According to KPMG Project Stella7
, at least 10% of smuggled and counterfeit
cigarettes in the EU are imported from our country. Thus, out of 43.6billion cigarettes
from the C&C category, 4.2 are of Ukrainian origin. It is difficult to determine the
country of origin of another 9.5 billion, but later in the report we will show that a
significant part of them may have “Ukrainian roots”.
At the same time, Ukraine’s share in the С&С market increased from 0.88% in 2014 to
9.63% in 2018. And this figure is not definitive.
Picture 1

17
The reason for this confidence – data about the most common brands of
contraband and counterfeit cigarettes in the EU markets. For example, in Poland,
the TOP 5 brands include Minsk, NZ (produced at the Grodno tobacco factory),
and such cigarette brands as LD, Compliment and Marvell that are familiar to
Ukrainian consumers. And if the first brand is a legal one, the latter two were not in
Ukrainian retail chains until recently, but at least since 2017, the media has openly
talked about the production of, for example, Compliment cigarettes at a tobacco
factory in the city of Vinniki near Lviv. Moreover, the manufacturer put its logo on
the products, which were detained at the borders of the EU as part of shipments
of contraband.
In Slovakia, the TOP of most popular C&C cigarettes includes Bond Street, L&M, as
well as the above-mentioned Compliment and Jin Ling. The fact that cigarettes of
this brand started being produced in the same Vinniki in 2017 was proudly declared
by the mayor Theodore Hudziak 8
.
It is noteworthy that the same brand is produced at the Baltic tobacco factory in
Kaliningrad. But it is doubtful that cigarettes that made it into Slovakia (in transit
through Poland) were produced by this particular manufacturer.
The C&C Rothmans Philipp Morris and the already mentioned Compliment and Jin
Ling are rather common in Hungary.
In Romania, a significant share of the contraband and counterfeit goods market
is held by Moldovan Ritm, Ashima, Marvell, and Marble cigarettes are also sold
(possibly produced in Ukraine).
In the context of Russia, smuggling flows were traditionally directed both inward
and outward. The assortment varied depending on the cost of a particular brand
of cigarettes (usually a local one). After 2014, Russia has replaced Ukraine on the
market of ORDLO. However, since militants acquired their own production lines,
the process has changed its direction, and today the share of contraband and
counterfeit goods sometimes reaches 30-40% in Russia’s regions bordering
Donetsk and Luhansk regions. Below there is a separate section devoted to illegal
trade in tobacco products in the Donbas.
Let us return to the analysis of the situation on the European market.

18
TOBACCO SMUGGLING
Based on research on tobacco retail in the EU states, Ukraine’s neighboring
countries, it is possible to estimate the scale of contraband shipments from our
country.
* Romanian counties Vaslui and Brăila do not have borders with Ukraine, Tulcea County has no
land border with Ukraine – the border runs along the Danube.
The table intentionally highlights several regions of Romania that do not have a
land border with Ukraine. The situation in the counties bordering Moldova is much
more favorable than in those that have a land border with our country. And the
state of the markets in Suceava and Botoșani counties is close to disastrous for
legal manufacturers – there, due to the “synergy” of the Ukrainian and Moldovan
smuggling flows, the share of legal tobacco products is less than 50% of the total
market volume. This could be called the success of Ukrainian exports, if it were
not about smuggling.
Table 3

19
Where do contraband and counterfeit cigarettes
come from
When it comes to Ukrainian cigarette manufacturers, the four main players in the
market are most frequently mentioned. Once in a while, it is possible to see the
data about the presence of two more plants – in the Zhovti Vody (Dnipropetrovsk
region) and the Vinniki (Lviv region).
But if we take the data from the “Unified state register of equipment for industrial
production of cigarettes”9
as a basis, it is possible to make a startling discovery
that there are at least 11 enterprises in the country that can produce cigarettes.
Names of the majority of these companies will not mean anything even to a person
familiar with the country’s tobacco market. If one tracks the records of equipment
moving, assignments of rights for it, leases of production lines, then it can be
seen that the national tobacco industry, which belongs to Ukrainian companies,
is actively operating. On average, half of the assets change ownership every 2-3
years. For example, a tobacco factory in the Vinniki changed its owner and name
several times. Once it was called Lviv tobacco factory. We could assume that today
it is mentioned in the rating of taxpayers as TOV Vinnikivska Tobacco Factory, but
it is registered in the regional center. But there are two other manufacturers
in the city itself. These are TOV Marvel International Tobacco Group and TOV
Fermentaciyniy Zavod №1. One is registered at the address Zamkovaya street,
building 2-a, the other one is registered at Shevchenko street, building 1-d. Both
buildings are located within the block where the Lviv tobacco factory is situated.
At the same time, Marvel takes a lease on part of the equipment that belongs
to the TOV Fermentaciyniy Zavod №1. Moreover, the equipment used for the
manufacturing by the TOV Vinnikivska Tobacco Factory, TOV Marvel International
Tobacco Group, and TOV Fermentaciyniy Zavod №1 is located at the same address
– Vinniki, Shevchenko street, building 1.
The similar situation is there in the city of Dnipro, where two companies work
together, renting equipment from each other. These are TOV Omaks and TOV Dana-
AS. The same scheme is used by the companies Proekt-17 and TOV Protestas in
Transcarpathia, and by Polissia Agribusiness and Ukrainian Tobacco Production
in the Rivne region.

20
TOBACCO SMUGGLING
The products of most of these manufacturers cannot be found in the retail market
of the country, except for 1-2 brands that offer small quantities of cigarettes for
legal trade.
Law enforcement and regulatory agencies had issues with some of these
manufacturers. Some of them appeared recently – the company was registered
no more than five years ago, and the equipment was granted for use (ownership
or lease) in 2018-19.
It cannot be unequivocally claimed that these companies are engaged in illegal
activities. But the specific approaches of conducting business are, at least,
surprising. As for equipment rentals, it can also be (but we do not claim that this
is so in all cases) a way to steer clear in the event of claims from the state. The
owner of the equipment is not responsible for the possible illegal actions of its
lessee. And, of course, in case of termination of lease payments, the owner can
reclaim it.
On the other hand, at the end of 2019, the SBU uncovered a scheme for evading
excise payments used by manufacturers of cigarettes in the city of Zhovti Vody
in the Dnipropetrovsk region. Searches were conducted, and subsequently, the
finished products were found, and information carriers containing information on
production were seized 10
.
On the other hand, formally, some of these companies produce their own brands
or brands of cigarettes registered in the United Arab Emirates and other offshore
jurisdictions. Moreover, the products can be processed as cigarettes intended
for distribution in duty-free shops. In this case, the first stage in the sale of
finished products is legal, and the excise tax should not be paid – according to the
documents, cigarettes will leave the territory of Ukraine. In other words, there can
be no claims on the part of the state against such manufacturers.
The diagram below shows the locations of companies whose equipment is
registered in the “Unified state register of equipment for industrial production
of cigarettes”, but which either do not sell their products on the domestic
market of Ukraine or sell it in relatively small amounts:

21
It is worthwhile to pay attention to the geographical location of production
facilities. It is logical to locate the plants in such a way that it will help to minimize
the costs of logistics – delivery of goods to the consumer. Plants of legal tobacco
manufacturers are located in the Central part of Ukraine. And most of the “no-
name brands” seek to establish a factory closer to the borders of the country.
Except for the above-mentioned manufacturers, there are many clandestine
workshops that produce and prepack cigarettes on the territory of Ukraine,
and are engaged in the production of counterfeit goods – fakes of famous
brands. Over the past year alone, such cases were discovered by Ukrainian
investigative authorities in the cities of Chernivtsi11
, Akhtyrka (Sumy region)12
, in
the Dnipropetrovsk region13
, and the Rivne region14
. At the same time, in recent
years, the clandestine manufacturing of counterfeit products has seen a trend
towards the selection of “non-confrontational” brands for counterfeit. Previously,
mainly well-known brands were forged, which entailed, in addition to a criminal
investigation itself, a lawsuit from the rights holder.
Unknown cigarette manufacturers in Ukraine

22
TOBACCO SMUGGLING
Now, clandestine manufacturers prefer either brands of cigarettes that go as
contraband to foreign markets (Belarusian NZ, Minsk) or little-known brands
from offshore jurisdictions, as well as brands of similar clandestine and semi-
clandestine manufacturers from Ukraine – Marble, Marvel and the like. Due to this,
even if the fact of production of counterfeit cigarettes is detected, there will be no
claim from the rights holder.
However, all of the above mentioned is true primarily with regard to smuggling
from Ukraine. At the same time, according to KANTAR research15
, both counterfeit
and contraband are actively entering the Ukrainian market. The total share of
C&C products in the country, according to the results of 2019, amounts to 6.6%.
The most “popular” brands of contraband and counterfeit cigarettes are already
mentioned Compliment, Marvell, Marble, and Belarusian brands NZ and Marshall.
The name of the latter factory surprisingly coincides with the name of one of the
small manufacturers of tobacco products in the Dnipropetrovsk region.
However, the concentration of contraband and counterfeit goods in the retail
market of Ukrainian regions is not proportionate. More than 70% of C&C products,
according to Kantar research, are sold in five regions of the country – Odesa,
Khmelnytskyi, Kharkiv, Dnipropetrovsk and Zaporizhzhya.
About 45 billion cigarettes were legally sold in the country, which (including 6.6% of
contraband) is 93.4% of the total volume. Thus residents of Ukraine smoke about
48.18 billion cigarettes per year. Therefore the volume of contraband amounts to
3.18 billion cigarettes.
In order to generate data on the market share of tobacco products, let’s take
information about the population in these regions. Let’s assume that the
distribution of cigarettes does not have regional differences (that is, everyone
smokes approximately the same amount of cigarettes). And thus dividing the total
volume of the legal market by the percentage of the population of the regions in
relation to the total number of residents of the country, we get quantitative data.
It is easy to calculate the volume of contraband, having a total figure and the
percentage of sales in individual regions.
Then, comparing legal/illegal sales, we get unpleasant figures.

23
Each of these regions has its own specifics, but it is worth emphasizing that in this
case we are talking not only about smuggling, but also about a significant share of
C&C products in the domestic market, that is, losses for the state budget of our
country. According to Kantar, in 2019 the state received fewer taxes than was due
because of unpaid direct taxes (excise taxes, VAT), and this shortfall amounted to
more than 4.7 billion UAH.
Below there is an approximate scheme of the routes of distribution of C&C
products to foreign markets (from Ukraine), as well as of the smuggling flows
going into our country:
Table 4
Smuggling and counterfeit cigarettes in Ukraine. Routes

24
TOBACCO SMUGGLING
There are four main routes by which smuggling gets into Ukraine. This is a
channel from Belarus, the southern smuggling triangle, which includes Moldova,
Transdniestria (we consider it as a separate region solely in the context of
smuggling), ORDLO and the Russian Federation. On most of these routes, the
movement of C&C products has two directions – there are flows of Ukrainian
(according to the place of production) cigarettes, which go to the markets of
neighboring countries, and there is a reverse process. There is a clear imbalance
in the smuggling in the case of Belarus and the ORDLO – more smuggled cigarettes
enter Ukraine, than leave it.
Below, we will consider each of the channels using the example of the “base” region
the smuggling is aimed at.
Important notice: in this section, the so-called PMR or Transdniestria is considered
as a separate region. This is not a political position. Transdniestria is an integral
part of Moldova. However, the specifics of conducting business, organizing border
controls, and regulating the turnover of tobacco products in this territory differ from
the ones on the territory of Moldova, as well as from the Ukrainian ones. Therefore,
it is reasonable to consider this territory separately.
Odesa is a large seaport town, and the Odesa region borders Romania and Moldova,
including Transdniestria. Moreover, the territory of the region is heterogeneous,
divided into several micro-regions. This region is one of the centers of seasonal
tourism. The climate is suitable for growing tobacco and this crop has been cultivated
there for at least the last few decades. On the territory of Moldova, there are legal
(and not only) productions that prepare tobacco raw materials that can also be
purchased for cash.
There are three legal manufacturers of tobacco products in the region – Tutun
CTC in Chișinău, TOV Inter-Tabac in the Moldovan city Tvardiţa (located on the
border with Ukraine) and Orhei tobacco factory (International Tobacco). Moldovan
manufacturers have their facilities for growing tobacco and preparing compositions
for cigarettes (fermentation, cutting raw materials).
TheOdessasmugglinghubandthe«blackhole»ofthePMR
01

25
The cigarettes, presumably made in Moldova, ended up in different EU countries,
including Spain and Germany. The same products enter the market of the Odesa
region – these are mainly brands from the lower price range, cigarettes without
a filter such as AstrA, AstrU, Prima, Dymok and the so-called “Soviet” brands, for
example, Stolichnye.
TOV Imperia Tabak from the Odesa region (located in the village Liubashivka), which
has registered equipment for the production of cigarettes, does not have its own
brands distributed on the territory of the country. According to the type of business
authorized, it does not produce tobacco products, but only grows tobacco, and is
engaged in wholesale trade of tobacco, grain, and animal feedstuff 16
.
Reportedly, at least two enterprises that manufacture tobacco products operate
on the territory of the unrecognized PMR. These data are confirmed by reports in
the Moldovan press, as well as in interviews with specialists working in the tobacco
sector. One of them is directly associated with the Sheriff company. Even the Russian
press, Kommersant in particular, which sees the separatist activity in Moldova in a
positive light, drew attention to the specifics of the region’s tobacco business back
in 201117
. In addition, since as early as 2005 (23.01.2005 № 1 (00025), the order of the
Customs Committee of the PMR, which secured the status of the Sheriff company as
of a specialized importer of tobacco products, has been in effect.
Transdniestria, due to the lack of control over production by the official authorities
of Moldova and poorly guarded borders, has become a smuggling hub for the
entire region. This includes the supply of smuggled cigarettes to the Ukrainian and
Moldovan markets and then to the EU markets. The SBU18
and State Tax Service
regularly conduct raids and make arrests, although this remains to be mostly “one-
off events”. The scale of this phenomenon is evidenced by the facts given in the first
series of reports on smuggling, made by the Ukrainian Institute for the Future (2019),
as well as public accusations against Ukraine by the Moldovan Prime Minister Maia
Sandu regarding the scale of illegal trade of Kyiv and Tiraspol19
.
Moreover, cigarette manufacturers in the territory of the PMR while “working”
for the Ukrainian and Moldovan markets, often produce fakes under brands of
Moldovan manufacturers – even cigarettes of the cheap segment. This allows to
avoid excessive attention from tobacco TNCs that are willing to protect their income,
including by suing manufacturers of counterfeit goods.

26
TOBACCO SMUGGLING
Khmelnytskyi region does not have land borders with the territories of other
countries, but a significant place in the tobacco market of the region is occupied
by contraband and counterfeit goods. Every fourth pack of cigarettes purchased
in the region is of illegal origin. At first glance, the situation is paradoxical, since
there are no “shady” manufacturers in the region, and the region is not a major
transport hub. However, if you pay attention to the clothing and wholesale markets
operating in Khmelnytskyi, the patterns of purchases of local buyers, the situation
becomes more clear.
The market in Khmelnytskyi is a traditional shopping destination for Belarusian
smallentrepreneurs.Itservesasanintermediarybetweenportcities(andmarkets)
and the seller from the Republic of Belarus. And due to this, there is a large amount
of transport coming from the territory of the neighboring state, mainly minibuses
and buses. In many ways, this is why Belarusian cigarettes occupy a significant
place in the market. These are, on the one hand, products of the Grodno tobacco
factory – NZ, Minsk and others brands. On the other hand, there are cigarettes
produced at the factory of the Belarusian company Tabak Invest20
, owned by the
oligarch Pavel Topuzidis, who is on familiar terms with Lukashenko21
. In the early
and mid-noughties, his tobacco factory tried to enter (and quite successfully)
the legal Belarusian market of tobacco products with its own brands. Moreover,
the supermarket chain received the same as the company’s flagship brand of
cigarettes – Corona. The alikeness of logos and names was a good way to promote
both products. However, by 2010, Tabak Invest had almost stopped production of its
own brands and began cooperation with international brands. In particular, today
the company’s facilities produce brands of cigarettes belonging to the JTI group
of companies 22
.
Belarus is a leader in supplying smuggled cigarettes to the EAEU and EU countries,
specializing primarily in the so-called “white smuggling”: transactions within the
country are legal, taxes are paid. And the movement of goods across the border
is already the seller’s responsibility – the state washes its hands of it. At the
same time, the system’s resources enable it to effectively restrict the inflow of
contraband to the domestic market.
02Khmelnytskyi,Belarusandsmuggling

27
Ukraine, and the Volyn region in particular, is more of a transit zone for the flow
of Belarusian cigarettes. And the situation with the Khmelnytskyi region is an
exception to the rules, due to the presence of a large number of Belarusian carriers
specializing in the delivery of goods from neighboring countries (sometimes also
using smuggling schemes).
However, with the increase in excise taxes on tobacco products and the absence
of effective control on the border of the country, Ukraine risks becoming a
destination country for Belarusian smuggled cigarettes.
There is another aspect to this problem – starting from 2017-18, copies of Belarusian
brands appeared in Ukraine and Poland. This may be the result of the work of one
or more, so far small, illegal manufacturers. Once again, brands chosen are brands
that will not initiate an investigation and there will be no complaints from major
market players.

28
TOBACCO SMUGGLING
Three Eastern regions – Dnipropetrovsk, Kharkiv and Zaporizhzhya – account for
more than 50% of the distribution market of contraband and counterfeit products.
We can also add the Donetsk and Luhansk regions, where the work of Kantar
monitoring groups is rather limited, given the quite understandable reasons.
Accordingly, the share of counterfeit and contraband there is not lesser than, for
example, in the Dnipropetrovsk region.
On the one hand, the Dnipropetrovsk region has its own cigarette manufacturers,
which have already had issues with state authorities. However, market analysis
and the increasing role of illegal products suggest that a significant part of
the smuggled goods in this region is produced in the Russian Federation or the
territories of Donetsk and Luhansk regions controlled by the militants.
This is a relatively new situation that arose in 2015-16 – since the so-called LPR
and DPR launched their own tobacco production. And by the end of 2017, the
smuggling of tobacco products from ORDLO became apparent. The data on the
SBU and Prosecutor General’s Office raids over the past few months can serve
as an example:
19.12.2019 – the seizure of a consignment of smuggled cigarettes from ORDLO
near Volnovakha 23
;
a consignment of counterfeit goods from ORDLO was seized on its route to the EU.
The volume in monetary terms – about 15 million UAH 24
;
15.01.2020 – the scheme of weekly (!) supply of cigarettes from Luhansk to the
territory controlled by Ukraine 25
;
16.02.2020 – a joint operation of the SBU and the Prosecutor General’s Office,
which resulted in the discovery of several warehouses of cigarettes from ORDLO
on the territory of Ukraine. Cigarettes worth about 20 million UAH were seized 26
;
13.03.2020 a car with smuggled cigarettes was detained at the Mayorske
checkpoint 27
.
03TobaccoEastor$300milliontomilitants

29
But back in 2014-15, the so-called LPR and DPR did not have their own production
of cigarettes. Today, the region is the largest supplier of contraband and
counterfeit goods both to the territory of Ukraine and to the Russian Federation.
For illustrative purposes, we present the key data in the form of an infographic.
Militants’ tobacco industry – competition for markets
At the initial stage of the ATO, the tobacco market of the so-called DPR and LPR was
saturated mainly with products of Ukrainian and Russian companies. Moreover, at
the end of 2015, the share of Russian suppliers started getting bigger. Nevertheless,
selling cigarettes is good business: according to various estimates, the market
capacity of ORDLO is from 190 to $220 million. Just a simple example, the supply of
cigarettes and tobacco products from Russia to ORDLO in 2017, according to the
LIGA.net, amounts to about $70 million. This number is twice bigger than the price
of coking coal supplied to metallurgical enterprises in the region.
Tobacco war in the Donbas

30
TOBACCO SMUGGLING
But in 2017, a Donetsk tobacco factory was already operating in the so-called DPR.
A little later, capacities of the Hamadei company joined up. This company moved
to Kramatorsk at the beginning of the ATO, but later was registered as a taxpayer
in the so-called DPR.
At the turn of 2016 and 2017, Luhansk launched own production – there was a
pompous inaugural ceremony of the Luhansk tobacco factory, which had
equipment imported from Russia.
During the same period of time (2016-17), the DPR and LPR began the process of
active competition for the market. On the one hand, local manufacturers were
replacing Russian imports. The process, by the way, became easier after in 2018,
the Japanese JT Tobacco bought out the Rostov factory Don-Tabak and stopped
the legal shipment of products to ORDLO.
On the other hand, Donetsk and Luhansk “tobacconists” actively fought for the
market with each other. It is noteworthy that in 2017, the most structured law
enforcement body of the so-called LPR was... the Customs Committee. In Donetsk,
the potential of the customs service was “ramped up” just as quickly. Customs
control between the “republics” was strengthened and draconian restrictions
were imposed on the movement of alcohol and tobacco products.
Of course, these, shall we say, “customs officers” had control over the border with
the Russian Federation as well. But their work there had, and has, rather declarative
nature – tobacco from ORDLO is actively supplied to the Russian border territories.
Even in Rostov-on-Don, the share of illegal (contraband) tobacco exceeds 29% of
the market volume. And the names of the brands Khortytsia (the brand belongs
to Hamadei) and White sun (produced both in Donetsk and Luhansk) speak for
themselves.
But, in addition to their own brands, tobacco factories in non-controlled territories
are actively engaged in the production of counterfeit products – fakes under the
brands of well-known manufacturers. And since 2019, a new process has begun –
forgery of fakes – the use of names of contraband and counterfeit cigarettes that
are popular on the Ukrainian market.

31
It was 2017 that became a turning point in the supply of smuggled cigarettes to
the Ukrainian territory. Since then, the share of contraband and counterfeit on the
market of Dnipropetrovsk, Zaporizhzhya, and Kharkiv regions has been steadily
growing. As noted above, we can assume that similar processes are taking place
in the liberated territories of Donetsk and Luhansk regions.
Now let’s try to estimate the volume of the market, taking the figure of $190
million per population of a maximum of three million people (if we are to believe
the data of the separatists) as a starting point. There was an audit in the
territories of Donetsk and Luhansk regions controlled by Ukraine, as well as in the
Dnipropetrovsk, Kharkiv and Zaporizhzhya regions, conducted under the guidance
of Dmytro Dubilet, which totaled 10.8 million. That is, the volume of the tobacco
market in this region amounts to at least $680-700 million per year. At least 15%
of this amount is already “in the hands” of manufacturers from ORDLO. That is,
every year, Ukraine gives the militants at least $100 million by not hindering the
smuggling of cigarettes to its territory. Furthermore, it loses money on taxes from
manufacturers, retail chains, and small entrepreneurs. At the same time, we should
not forget the corruption element – smuggling and distribution of contraband are
often associated with bribes, protection racketeering and similar things.
Thus, the total loss to the country’s economy (taxes + lost market share) amounts
to at least 2.35 billion + 2.5 billion = 4.85 billion UAH measured in prices of the end
of 2019. The real losses are higher – because we should add the market volumes
of the controlled part of the Donetsk and Luhansk regions with a concentration
of military tobacco consumers there to the Kantar statistics on the foregone
tax revenues. Therefore, the total costs estimated at 6 billion UAH per year do
not seem to be improbable. And that’s without taking into account the market of
ORDLO. The presence of Ukrainian manufacturers on that market is a topic for
another discussion.

32
TOBACCO SMUGGLING
Schemes for transportation of contraband
The schemes for transportation and delivering contraband and counterfeit
tobacco products to the end consumer are usually quite complex and have several
intermediaries. This allows key figures of criminal networks to avoid excessive
attention from law enforcement agencies. It can be summed up as follows:

33
Over the past four years in Ukraine, the dealings between contraband/counterfeit
assembly points and small-scale wholesale warehouses can be conducted without
direct acquaintance of the participants of the scheme – trade in counterfeit
cigarettes online is rather popular.
The same scheme is starting to become popular in retail, which guarantees a certain
level of security to the seller if the consignment does not exceed two blocks of
cigarettes (20 packs).
The most important problem in the fight against tobacco smuggling is the choice of
the stage at which it is possible to stop the activities of criminal groups. The first
such stage is the moment of crossing the border, because if we are talking about
“white smuggling”, then all the previous stages are legal.
The prevailing opinion in the media is that the movement of tobacco products across
the state border is carried out in relatively small consignments – up to several
hundred packs. This scheme exists and is divided into four types:
Illegal movement across the state border outside border inspection posts
and customs control posts. This is the area of responsibility of the State
Border Guard Service of Ukraine. It is a risky mechanism for its participants,
but it is workable for residents of border territories who are familiar with the
specifics of the border services of neighboring countries. Such activities are
usually carried out by small criminal groups that include citizens of several
countries.
“Legal” movement across the border, using primarily “jackets” scheme. In
this case, the goods for export are divided into small consignments that comply
with restrictions on the quantities allowed for carrying across the border and
passed to several citizens. This scheme is widespread and has support in
border areas. During a sociological survey conducted by the Institute for the
Future in the fall of 2019, respondents were asked: “Imagine the scenario: you
are at the border crossing and a fellow passenger offers you to put goods that
are subject to quantity restrictions (for example, cigarettes, alcohol, amber,
etc.) in your luggage (the amount of goods is within the limits specified by the
rules of import/export) and asks for help to transport, passing it off as your
own. What would you do?”
01
02

34
TOBACCO SMUGGLING
Responses given by residents of border regions have distributed as follows:
That is, more than 28% of citizens are ready to participate in the “jackets” scheme
under certain conditions, and only 2.6% would help customs officers to stop an
attempt to transport contraband.
Illegal movement is an attempt to hide tobacco products in a vehicle, in
baggage that is being transported, or by attaching them somewhere around
the body (body packing).
Baggage – sending tobacco products as baggage (or by mail) to another
country in small wholesale consignments..
At first glance, these product movement patterns are predominant. If we assess the
second and third schemes, “jackets” and “body packing”, then in terms of the number
of participants in the process of moving goods these mechanisms are widespread.
However, according to the volumes of goods that enter the market, these are not the
main ways to move contraband across the border.
The main method is large-scale smuggling, which is described by FATF experts as
follows: “Large-scale smuggling that involves the transportation of over one million
cigarettes in each shipment.
03
04

35
This is the average number. Smugglers buy consignments consisting of 10,000
cigarettes broken down into 50 cartons, containing 10 packs of 20 cigarettes each.
Buying in such large volume allows for the negotiation of purchase price for the
initial importer and the middle market receiver.
It is possible to send such shipments using cargo or river transport. The paradox of
the Tulcea County in Romania can serve as an indirect confirmation of the validity
of the thesis about the predomination of the large-scale smuggling. Without having
a land border with Ukraine or Moldova, this region has an extremely low number of
smuggled and counterfeit cigarettes, even compared to the average for Romania.
The situation is similar in Maramureș County, which has checkpoints for citizens, but
lies outside the main routes of cargo transport.
The third argument that demonstrates the validity of this assumption is the results
of research within the Selec project conducted in 11 countries of Southern Europe 28
.
The authors of the study analyzed data from the border guard services and customs
services of selected states, the results of special operations of the police and other
investigative agencies aimed at curbing the trade in C&C products on the domestic
market. In more than 93% of cases, contraband is transported along the land border
by road. The share of C&C cigarettes transported across the border by rail is less
than 1%. Illegal movement outside border and customs checkpoints accounts for
about 5% of the total volume of contraband.
If we take a look at the extended data on the cigarettes transported by motor
transport, trucks and vans carry more than 90% of the contraband, and passenger
cars – about 4%. The rest is transported in passenger buses.
However, in the Danube Region, there may be another scheme for moving large
quantities of tobacco products to the EU markets. It became known coincidentally –
thanks to the Parallel tugboat, which was officially heading for Skadovsk and run into
a gale. A barge had detached from the tugboat and was later washed up on shore
at the Odessa dock. It was loaded with cargo – five million packs of cigarettes 29
.
This gives grounds to assert that there is a channel for transporting large wholesale
shipments of contraband and counterfeit goods by river transport to the territory of
the states of the Danube river basin.

37
RisksforUkraine
Any illegal trade has three main factors of influence.
Economic – the country is losing money. What is meant here is, on the one
hand, the loss of budget revenues by the state, since illegal trade is not
taxed. On the other hand, illegal trade hinders the development of bona fide
manufacturers, as they cannot compete with smuggled products in terms of
prices, for example.
In Ukraine, if we are referring to C&C products on the domestic market, we
are talking about losing control over at least 6.6% of the tobacco market. If
it continues, the direct losses from the non-payment of excise taxes and VAT
will amount to about 4.7 billion UAH. In fact, the amount is large, since the
loss of market share by legal manufacturers means a decrease in production
volumes and, as a result, the loss of part of the employees’ wages. This also
includes the revenues of retail chains, wholesale suppliers, and entrepreneurs.
Therefore, the total budget losses from the deprivation of these taxes can be
estimated at the amount of 5-5.5 billion UAH. If we estimate the losses in the
form of “foregone taxes” + “loss of market share by legal manufacturers”, then
the country’s economic losses increase to at least 10-11 billion UAH annually
(taking into account the loss of the ORDLO market).
Corruptive. The distribution of large quantities of contraband and counterfeit
goods involves corrupt relations with representatives of state authorities
and law enforcement agencies both locally and at the country level. In the
context of the war in the Donbas, the presence of smuggling flows going
through the demarcation line, carries risks of corruption spread among some
of the military personnel involved in the Joint Forces Operation, traffic police
and police on the ground. Given the specifics of the region, such phenomena
should be treated not just like purely corrupt practices but like political risks.
Money laundering and the shadow economy. The revenues generated from
the C&C’s trade in tobacco products are in the shadow. They pass through
money laundering mechanisms, and this destroys the country’s financial
system and, in turn, encourages corruption.
01
02
03

38
TOBACCO SMUGGLING
The FATF documents contain the assumption that revenues from contraband and
counterfeit cigarettes may be used, among other things, for terrorist financing. The
situation in Ukraine confirms this thesis – the country is giving part of its market and
is not preventing smuggling from ORDLO and thus substantially handles financing to
terrorists from the so-called LPR and DPR in the amount of about $300 million per
year.
The same is true for trade with Transdniestria. Smuggling, and smuggling of
cigarettes in particular, is a way to support the economy of the separatist region,
reducing the likelihood of a conflict settlement on the terms of Moldova.
These factors are extremely important, because against a backdrop of economic
crisis, which leads to a decline in income of the population, and the simultaneous rise
in legal tobacco products prices, the consumer will look for a cheap alternative. This,
in our case, will be counterfeit and contraband products. Including goods smuggled
from the territory of ORDLO.
Speaking about the smuggling of tobacco products from Ukraine, it is worth
mentioning the wave-like growth in volumes over the past five years. The total
amount of losses from foregone excise taxes is estimated at 10 billion euros in
the EU. At least 1 billion of which are losses caused by smuggling from the territory
of Ukraine. It is obvious that this is primarily related to neighboring countries. The
increasing economic losses and the growth of the market share of contraband
make them wonder about the real ability and desire of official Kyiv to fight against
smuggling and counterfeiting. On the one hand, Ukraine sends positive signals in the
form of the plan to combat counterfeiting developed by the Government of Ukraine.
The Honcharuk government endorsed the decision to introduce an “electronic excise
stamp”30
, which, according to the plan, was to be launched no later than May 1, 2020.
They said that with the help of it the population can check the products for legality.
The idea is good – people will be able to make a conscious choice and not buy
counterfeit goods. Perhaps, the consumption of low-quality alcohol will decline. This
might become a barrier for counterfeit cigarettes, which by the results of 2019 took
about 0.7% of the total market volume. What remains unclear is what to do with
contraband, which accounts for 5.9% of the market.

39
Anti-tobacco organizations also note the fact that the country fell short in efforts
to ratify the decision to join the WHO Protocol to Eliminate Illicit Trade in Tobacco
Products since 201731
. The relevant draft law was prepared and approved by the
Government32
. Since we are talking about the ratification of an international
agreement, it was the President who had to submit the bill to the Verkhovna Rada.
However, the administration of President Poroshenko returned the bill twice. The
office of President Zelensky “started working on a document” – the bill has not yet
been submitted to the Parliament.
Such examples, as well as the evidence of factories producing counterfeit goods,
create additional tension in bilateral relations. The accumulation of such conflict
topics that seem to be “small”, can lead to a stable negative background in Ukraine’s
communication with neighboring countries.

41
Conclusions
Thinking about the conclusions, it is worth paying attention to two key facts that
can significantly facilitate the fight against illegal trade in tobacco products in the
future.
The attractiveness of counterfeit and contraband goods in the eyes of
consumers will grow, at least until the end of 2020. Accordingly, consumers
will pay more attention to the price of the final product, which will remain
at the same level or will increase against the backdrop of increasing excise
taxes. As a result, the smoker will face a choice: quit smoking (not everyone
would go for it), switch to lower-quality cigarettes, or look for products of
similar quality, but at a lower price. Naturally, if there is a counterfeit, the
smoker will not pay attention to the presence of an excise stamp on a pack
of cigarettes. He will pay attention to the price.
This creates prerequisites for the increase in counterfeit manufacturing
and volumes of contraband supplies to Ukraine.
Quarantine and the associated decrease in the mobility of citizens, the fall
in cargo transportation. Cessation of the movement of citizens across the
border makes it impossible to move contraband in small batches in their own
cars or using the “jackets” scheme. The closure of some border checkpoints
destroys the usual supply chains of contraband. Therefore, statistics on the
market of C&C cigarettes in Ukraine and neighboring countries for February-
May 2020 is a unique tool for analyzing the mechanisms of movement of
contraband and counterfeit goods. Comparing the share of C&C products
on the market, their assortment, regional characteristics and comparing
these data with data for other periods, with the facts of operation/stoppage
of individual “shady” manufacturers makes it possible to get information
about the mechanisms of the entire chain – from the manufacturer to the
consumer. And, of course, to develop effective mechanisms to combat the
illegal trade in tobacco products.
01
02

42
TOBACCO SMUGGLING
When it comes to general recommendations, the key message is the joint work
of various structures. The production of counterfeit goods is in the area of
responsibility of the police, SBU, SBI and public prosecutor’s office. Movement
of goods across the border, depending on the scheme, may be in the area of
responsibility of the customs service, or border guard services. Finally, money
laundering and cover-ups must be investigated by the anti-corruption and financial
intelligence agencies.
Particular attention should be given to the scheme for deflecting the blows from
equipment for the production of cigarettes. According to current legislation, if the
manufacturer used a leased production line, it most likely will not be withdrawn
or destroyed, but will be returned to the owner. Then it is a mere formality to
register a new legal entity and lease the line to it. In Ukraine, it is necessary to
change the legislation in a way that would allow confiscating the equipment used
to manufacture counterfeit goods. As well as to seize (confiscate) the vehicles
involved in transportation of these goods.
Tracking transactions for the purchase of raw materials for the production
of cigarettes can become an additional control measure and/or source of
information for analyzing the situation. It is necessary to change the legislation in
terms of determining what the fermentation of tobacco is, which products can be
considered raw materials for the production of cigarettes. There also should be a
system for monitoring the import of raw materials from abroad.
As for the “jackets” scheme (the movement of cigarettes by citizens in small
consignments through official border checkpoints), this activity is outside the area
of responsibility of both the State Border Guard Service and the State Tax Service.
Purchasing any number of legal tobacco products by a citizen on the territory of
Ukraine is legal. And this is certainly true for purchases being made in the duty-
free shops. The export of any quantity is legal. Therefore, the scheme of “jackets”
is a problem of the customs authorities of the neighboring country.
However, such information may become a subject for a trade-off in the fight
against smuggling as a phenomenon. The adjacent party is also reluctant to share
information about, for example, VAT refunds paid to Ukrainians when they register
goods for export. And this is, most often, an indication of smuggling of goods to
Ukraine.

43
In this case, information about goods items that pose a problem for the neighboring
party can be “exchanged” for information about goods items that are of interest
to Ukrainian services.

44
TOBACCO SMUGGLING
Посилання
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2
FATF Illicit Tobacco Trade 2012, p. 21 https://www.fatf-gafi.org/media/fatf/
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3
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zavdalo-zbytkiv-derzhavi-na-30-mln-hrn/

45
13
https://censor.net.ua/ua/photo_news/3170541/pravoohorontsi_vykryly_
nezakonne_vyrobnytstvo_tsygarok_na_dnipropetrovschyni_vylucheno_produktsiyi_
na
14
https://ua.korrespondent.net/ukraine/4152508-pidpilne-vyrobnytstvo-syharet-
vyiavyly-u-dvokh-oblastiakh
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v-ukrayini-6-hvilya-2019
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summu_15_mln_grn_pytalis_perepravit_iz_dnr_v_strany_evrosoyuza_sbu_foto
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vvozu-kontrafaktnyh-sigaret-iz-lnr
26
https://www.5.ua/ru/rehyoni/prokuratura-razoblachyla-masshtabnuiu-
kontrabandu-syharet-yz-ordlo-208414.html

46
TOBACCO SMUGGLING
27
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kontrafaktnymy_syharetamy_na_25000_hrn_961992
28
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https://www.048.ua/news/2221013/kontrabanda-veka-pod-odessoj-
priparkovalas-barza-iz-rossii-s-5-millionami-pacek-sigaret-video
30
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31
https://www.who.int/fctc/protocol/illicit_trade/protocol-publication/en/
32
https://www.kmu.gov.ua/news/249781408

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