There is no scientific basis justifying this requirement, which would in Requirement to provide annual returns on addition consist an unnecessary and sales data potentially unviable burden for smaller manufacturers. Fontem agrees that in principle manufacturers and importers of should be subject to disclose product content and composition so as to enable consumers to make informed choices. Requirement to disclose product content and composition However, e-cigarette manufacturers should still be able to protect trade secrets e.g. ingredients used as part of the flavour should be collectively categorised as flavourings to maintain confidentiality. Only ingredients of high quality should be used in e-cigarettes and e-liquids. As a minimum all ingredients must be food grade or comply with the standards outlined in the European/ United States Pharmacopeia. E-cigarette flavour variability should be Regulations concerning ingredients (eg, permitted, but no flavour should be nicotine content and/or flavours) marketed or designed to appeal primarily to minors e.g. bubble-gum, milkshake, cotton candy. Ingredients should be permitted for use in e-liquids subject to toxicological risk assessment. There is no scientific basis justifying this requirement, which would in Requirement for annual testing of product addition consist an unnecessary and composition potentially unviable burden for smaller manufacturers. Such a ban will prevent retailers from raising awareness of e-cigarettes and discourage current smokers from trying e-cigarettes, which in turn will lead to a much lower uptake rate Prohibition on free distribution and awards associated with sales among smokers. This effect is undesirable in light of the growing evidence and consensus that are less harmful than smoking.
Requirement to provide annual returns on sales data There is no scientific basis justifying this requirement, which would in addition consist an unnecessary and potentially unviable burden for smaller manufacturers. Requirement to disclose product content and composition Fontem agrees that in principle manufacturers and importers of should be subject to disclose product content and composition so as to enable consumers to make informed choices. However, e-cigarette manufacturers should still be able to protect trade secrets e.g. ingredients used as part of the flavour should be collectively categorised as flavourings to maintain confidentiality. Regulations concerning ingredients (eg, nicotine content and/or flavours) Only ingredients of high quality should be used in e-cigarettes and e-liquids. As a minimum all ingredients must be food grade or comply with the standards outlined in the European/ United States Pharmacopeia. E-cigarette flavour variability should be permitted, but no flavour should be marketed or designed to appeal primarily to minors e.g. bubble-gum, milkshake, cotton candy. Ingredients should be permitted for use in e-liquids subject to toxicological risk assessment. Requirement for annual testing of product composition There is no scientific basis justifying this requirement, which would in addition consist an unnecessary and potentially unviable burden for smaller manufacturers. Prohibition on free distribution and awards associated with sales Such a ban will prevent retailers from raising awareness of e-cigarettes and discourage current smokers from trying e-cigarettes, which in turn will lead to a much lower uptake rate among smokers. This effect is undesirable in light of the growing evidence and consensus that are less harmful than smoking.
all_submissions_91-120.docx