There has been and continues to be much debate about the changing legislation around tobacco sales, whether at UK or European level.

Retailers rightly and legitimately have strong views about the dark market, plain packaging, proxy purchases, the sale of smaller packs of cigarettes (10-packs) and menthol variants. These debates are at various stages and are well documented.

However, there is one aspect of the proposed EU legislation that has remained hidden deep in the small print and has far-reaching consequences for wholesalers. Article 14 imposes a requirement that all tobacco “movements” by transport or wholesale companies into, within and out from their business must be recorded uniquely for each individual unit, ie outer of 200 cigarettes.

The wholesale trade suffers enormously from illegitimate activity in both tobacco and alcohol, and is absolutely committed to any actions to curtail it. In moves unthinkable in many sectors, the FWD has worked closely with government and HMRC in proposing new controls, specifically the current proposals for wholesaler registration. These controls will impose significant costs on wholesalers, but we reluctantly accept them if they help to control criminal activity.

The new EU proposals are the precise opposite - this is legislation for its own sake, and will contribute nothing to the fight against smuggling, while imposing enormous cost on wholesalers. They will require each outer to be lot marked with a unique identifier, and every receipt, movement and sale to be recorded, stored and audited. Effectively, every outer must have a unique bar code, which must be recorded on invoices, with auditable records of all movements.

The set-up costs are huge, with changes to wholesale EPoS systems only one part. Ongoing recording and overseeing will also add personnel costs.

The real problem with all this red tape is that it has zero benefit in controlling the illegitimate trade. There is no leakage from legitimate trade into the black market in the UK, because there is no benefit in it - we have the highest costs in the EU, and unlike alcohol, trading in under-bond tobacco is not permitted.

This is legislation for its own sake, which because it affects a relatively restricted interest group is likely to pass into law so that Brussels can claim to be “doing something” - despite HMRC agreeing that these measures will be useless in the UK.

Time is short and we need MPs and MEPs to understand and fight these lunatic proposals. David Cameron claims to be the enemy of red tape burdens on business. Now is the time for him to show wholesalers that he means it.

Steve Parfett is chairman of AG Parfett & Sons