Section 5: Traceability

Articles in this section · 4

Article R3512-33

French Public Health CodeIn force

Updated 3 Nov 2023

I. - Deactivation of the economic operator identifier code is required in the following cases:

1° Total cessation of the economic operator's activity ;

2° Cessation of activity related to tobacco ;

3° Loss of the status of supplier, approved manufacturer, purchaser-reseller or distributor of tobacco products;

4° Loss of authorised warehousekeeper status.

Deactivation of the economic operator identifier code automatically deactivates the installation identifier codes and the related machine identifier codes.

II. - Deactivation of the facility identifier code is required in the following cases:

1° Permanent cessation of activity relating to the manufacture, storage or marketing of tobacco products ;

2° Relocation of the economic operator's activity.

Deactivation of the installation identifier code automatically deactivates the related machine identifier codes.

III. - Deactivation of the machine identifier code is required in the following cases:

1° Permanent withdrawal of the machine from the production line ;

2° Permanent incapacitation of the machine.

IV. - When the deactivation of an identifier code is requested by an operator in accordance with point 3 of Article 5 of Implementing Regulation (EU) No 2018/574 of 15 December 2017 on technical standards for the establishment and operation of a system for the traceability of tobacco products, the operator shall immediately inform the customs service of its request for deactivation.

Mariela Petrova

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Working with a corporate lawyer in France — Q&A

Any time a strategic decision changes how the company is owned, governed or contractually bound — incorporation, fundraising, M&A, restructuring, shareholder agreements, or major commercial contracts. Earlier engagement always costs less than later remediation.

A notary (notaire) is a public officer who authenticates specific deeds (mainly real-estate transfers and certain family-law acts). A corporate lawyer (avocat) advises on strategy, negotiates and drafts company documents, and represents you in disputes. The two roles complement rather than overlap.

Yes — most of our clients are foreign suppliers, investors or holding entities. We bridge the gap between French law and your home jurisdiction's expectations and deliver everything bilingually.

The SAS (Société par Actions Simplifiée) is the default choice for most international structures: flexible governance, single shareholder allowed, no minimum capital, and works cleanly with foreign holding entities. We assess SARL, SA, SCI on the merits when the situation calls for it.

Yes — communications with a French avocat are protected by the secret professionnel (Article 66-5 of the Law of 31 December 1971). This protection is broader than the common-law attorney-client privilege and applies to written and oral exchanges.

We work on fixed fees for clearly scoped engagements (incorporation, contract drafting, audits) and on monthly retainers for ongoing advisory. Hourly billing is the exception, not the default. You always know the cost before work starts.

Typical timeline is 2–3 weeks from KYC kick-off to RCS registration, assuming standard documentation. Holding-company structures, foreign-shareholder identification or in-kind contributions can extend this — we flag the gating items at the first meeting.

Absolutely. We routinely coordinate with your in-house counsel, expert-comptable or notaire — pragmatic collaboration is the norm, not the exception. We send them everything they need to do their part without duplicating work.

Mariela Petrova

Mariela Petrova

Avocate au Barreau de Paris

Toque #C2396

15+ Years In Corporate Practice

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Communications protected by professional secrecy — secret professionnel de l'avocat, Article 66-5 of the Law of 31 December 1971.

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