The Head of Legal at Philip Morris Bulgaria discusses the misconceptions surrounding personal data, the role of technology, and the need to translate legal requirements into everyday practice.
The law unequivocally prohibits the sale of tobacco and nicotine products to minors. Nevertheless, the data show that preventing minors from accessing these products remains a significant challenge. Alongside enforcement and sanctions, awareness, training, and practical tools to support retailers are playing an increasingly important role.
We spoke with Mariya Marinova, Head of Legal at Philip Morris Bulgaria, about the legal aspects of the issue, common misconceptions surrounding age verification, and the potential of technology to support effective compliance with the rules.
In the context of Philip Morris Bulgaria’s “No Compromises” campaign, why is the issue of minors’ access to tobacco and nicotine products so important from a legal perspective?
One thing must be absolutely clear to everyone: Bulgarian law prohibits the sale of all tobacco and nicotine products to anyone under the age of 18. This rule is unequivocal and is intended to protect minors from products designed exclusively for adult consumers.
Despite the clear legal framework, the data show that significant challenges remain in practice. According to the 2023 Global Youth Tobacco Survey (GYTS) for Bulgaria, 63.7% of underage smokers were not prevented from purchasing cigarettes because of their age, while 46.2% of children aged 13–15 who smoke purchased cigarettes directly from a retail outlet. This means that although clear rules are in place, the challenge lies in ensuring their consistent and effective enforcement.
This is precisely why initiatives such as “No Compromises” are important. They help improve understanding of the legal requirements and support their implementation in everyday retail practice. The campaign focuses not only on the existence of the prohibition, but also on the very real responsibility to ensure that it is observed in every individual sales transaction.
One common misconception is that asking a customer to show an ID document may breach personal data protection rules. What is the actual legal position?
This is one of the most widespread misconceptions we encounter. The reality is that visually checking an identity document for the sole purpose of verifying a consumer’s age does not constitute the processing of personal data, provided that the information is not copied, recorded, or stored.
In this context, asking a customer to show an ID document when there is doubt about their age is fully consistent with the legal requirements. Moreover, such a check is an important practical tool that helps retailers fulfil their obligation not to sell tobacco and nicotine products to minors.
In practice, a lack of sufficient clarity on this issue often leads to hesitation at the point of sale. One of the objectives of the “No Compromises” campaign is therefore to give retailers the confidence that they can lawfully refuse to sell tobacco and/or nicotine products to a customer when they have doubts as to whether that person is 18 or older. In such cases, it is up to the customer to decide whether to present an identity document to confirm that they are of legal age.
How can innovation, technology and even AI contribute to better implementation of age-verification requirements?
Technology can be an important ally in efforts to restrict minors’ access to products intended exclusively for adults by enabling a faster, more reliable and more consistent age-verification process.
At Philip Morris Bulgaria, we are working on the implementation of a digital age-verification tool in partnership with Evrotrust. A solution of this kind has the potential to support retailers by reducing the subjective element in the process and providing an additional level of assurance for both retailers and consumers.
It is important to emphasise, however, that digital solutions and artificial intelligence do not replace human responsibility. They are tools that can help ensure that this responsibility is exercised more effectively, more consistently and with less uncertainty in everyday practice.
Are legal sanctions sufficient to address the problem?
Sanctions are an important part of the regulatory framework because they send a clear message that the sale of tobacco and nicotine products to minors is unacceptable. They serve as a deterrent and demonstrate that violations of the law have real consequences.
At the same time, experience shows that sanctions alone are not sufficient to achieve sustainable results. Long-term change requires a combination of enforcement, awareness, education, and both individual and collective responsibility. When people understand why a particular rule exists, they are significantly more likely to comply with it consistently.
This is why the “No Compromises” campaign combines communication, training and practical tools to support retailers.
From a legal perspective, what would success for the “No Compromises” campaign look like?
True success is achieved when compliance with the law is regarded as a natural part of every retailer’s professional conduct. When age verification is carried out consistently and without hesitation, we begin to see meaningful change in practice.
Our goal is to support the development of a culture in which protecting minors is viewed as a shared societal responsibility rather than merely a formal legal requirement. That would mean that the legal framework is underpinned by genuine understanding, accountability and consistent behaviour among everyone involved in the process.
Learn more about the campaign here: No Compromises