Vastuskiri

Dear Erika Frigo,

In the meaning of the Tobacco Act, nicotine pads are products related to tobacco products and the Tobacco Act does not establish an obligation to notify. Pursuant to subsection 1 of § 18 of the Tobacco Act, a notice of economic activities must be submitted for engaging in the sale of tobacco products in the following areas of activity: retail trade, wholesale trade, catering. The obligation to submit a notice of economic activities shall also apply to products related to tobacco products. (subsection 5 of § 18 of the Tobacco Act).

Excise duty must also be paid to the Tax and Customs Board in accordance with the Alcohol, Tobacco, Fuel and Electricity Excise Act.

The labelling and packaging of the product must meet the requirements of the CLP Regulation (https://eur-lex.europa.eu/legal-content/ET/TXT/?qid=1524226676976&uri=CELEX:02008R1272-20180301). The requirements are provided in Title III of the regulation. The information on the label must be the same as the information in section 2.2 of the safety data sheet.

In addition, we would like to draw your attention to the fact that according to Article 45 and Annex VIII of the CLP Regulation, a notification about chemicals that are classified as hazardous must be made via the European Chemicals Agency's Poison Centre portal. More information is available on the website of the Health Board https://www.terviseamet.ee/et/kemikaaliohutus-tooteohutus/kemikaalikaitlejale/clp/fälliktust-segust-teavitamine and on the website of the ECHA poison centres https://poisoncentres.echa.europa.eu/et/home .  

Additional information can be found on the following websites:

The Chemicals Agency's guide in English: https://echa.europa.eu/guidance-documents/guidance-on-clp

The European Chemicals Agency’s guide: Guide on labelling and packaging in accordance with Regulation (EC) No 1272/2008.

The European Chemicals Agency’s guide: Instructions for preparing safety data sheets.

CLP user support ([email protected]) answers additional questions regarding the aspects regulated by the CLP Regulation.

Best regards

Mikaela Pakosta

Chief Specialist

Department of Chemical Safety

[email protected]

Republic of Estonia

Health Board

+372 794 3500

[email protected]

www.terviseamet.ee

Paldiski mnt 81, 10614 Tallinn

Estonia

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