Vastuskiri

Dear Tomasz Opaliński,

Thank you for contacting us.

According to the definition of the IUPAC, alkaloids are defined as a group of naturally occurring basic compounds organic, mainly heterocyclic, mostly of plant origin containing nitrogen [Moss, G. P., Smith, P. A. S., Tavernier, D. (1995). Glossary of class names of organic compounds and reactivity intermediates based on structure (IUPAC Recommendations 1995). Pure and applied chemistry , 67 (8-9), 1307-1375]. But „mostly of plant origin containing nitrogen“ does not exclude synthetic compounds. Synthetic compounds of similar structure may also be termed alkaloids [Lewis, R. A., Lewis' Dictionary of Toxicology. CRC Press. 1998, p. 51].

6-methyl nicotine (systematically named 2-methyl-5-[(2S)-1-methylpyrrolidin-2-yl]pyridine; CAS: 13270-56-9) is a synthetic derivative of nicotine (CAS: 54-11-5). Reading definition of nicotine pursuant to TPD Art. 2 (19) as ’nicotine’ means nicotinic alkaloids, we consider that the synthetic 6-methyl nicotine, a nicotinic alkaloid, is ’nicotine’ as defined by TPD.

Kind regards,

Chemical Safety Department

Republic of Estonia Health Board

[email protected]

www.terviseamet.ee

Paldiski mnt 81, 10614 Tallinn

Estonia

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Dear Sir/Madam, 

I would like to draw your attention to the chemical compound – 6-methylnicotine, which is a derivative of nicotine, yet a fully synthetic chemical compound created through chemical synthesis processes, not isolated from the tobacco plant. Due to its synthetic nature, 6-methylnicotine does not meet the IUPAC definition of an alkaloid, which traditionally refers to plant-derived substances. Furthermore, products containing 6-methylnicotine exhibit significantly lower toxicity than those containing nicotine, especially its salts, as confirmed by scientific research. 

Considering these properties, I kindly request confirmation that in your country, 6-methylnicotine is not treated as a tobacco alkaloid, and that its use in any form complies with the applicable legal regulations. I am asking for confirmation that, according to your regulations, 6-methylnicotine is not considered a controlled substance and its use is legal. 

Attached, I am sending detailed documentation regarding this compound and its properties. Thank you in advance for reviewing the materials, and I kindly request an objective respond.

Kind regards,

Tomasz Opaliński

Chemical Documentation Assistant

AK Universe Spółka z o. o.

Aleja Jana Pawła II 61/241

01-031 Warszawa

www.akuniverse.pl