Vastuskiri

Dear Sir/Madam,

Thank you for your e-mail.

Notifications submitted before 31.12.2024 and found non-compliant are listed here:
Non-compliant products as of 31.12.2024

https://www.terviseamet.ee/kemikaali-tooteohutus/tubakatooted

Products with IDs (given below) are non-compliant in accordance with the Tobacco Act § 8¹. 

Requirements for ingredients of electronic cigarettes

(2) The nicotine-containing and nicotine-free liquid shall not contain the following substances:

4) substances that pose a risk to human health in heated or unheated form, except for nicotine;

Products with the IDs:

01900-17-03008

01900-17-18006

01900-17-06008

01900-17-12008

01900-17-18008

01900-17-12006

01900-17-06006

01900-17-03006

These products contain an ingredient 2-Furanmethanol (CAS nr 98-00-0) that is suspected to be carcinogenic.

Products with IDs (given below) are non-compliant in accordance with the Tobacco Act § 81. 

Requirements for ingredients of electronic cigarettes

(2) The nicotine-containing and nicotine-free liquid shall not contain the following substances:

5) flavourings, except for the taste and smell of tobacco and menthol.

Products with the IDs:

01900-17-03043

01900-17-18043

01900-17-06043

01900-17-12043

These products contain an ingredient coffee absolute (CAS nr 8001-67-0). Please provide an explanation and appropriate evidence that the flavouring coffee absolute contained in the notified products does not impart the prohibited flavouring characteristics to tobacco related products. If evidence cannot be provided, please correct or withdraw the notifications.

Please inform us which products that comply with the requirements of the Tobacco Act Pharm-lux will continue on the Estonian market.

As of 01.01.2025, notifications are subject to state fees and annual charges.
More information:  

https://www.terviseamet.ee/kemikaali-tooteohutus/tubakatooted#muudatused

https://www.terviseamet.ee/kemikaali-tooteohutus/tubakatooted#riigiloivud-ja-tasud

To keep a notification published, the state fee must be paid. No fee is required for non-compliant products. Notifications that do not comply with the requirements of the Tobacco Act are not published on the website of the Health Board, and notifications that have been published but do not comply with the requirements are deleted.

Invoices are not issued automatically. If you need one, please send a written request with the relevant notification(s). If you have submitted sales data, the fee for assessment of the sales data will be added to the same invoice.

Kind regards,

Chemical Safety Department

Republic of Estonia Health Board

[email protected]

www.terviseamet.ee

Paldiski mnt 81, 10614 Tallinn

Estonia

Hello,

I've received a lot of emails from you regarding the EU-CEG declaration and the fees to be paid. I have questions.

In one email, you told me that a list of products is non-compliant because they have flavors other than tobacco and mint. All the products on the list are tobacco and mint flavors. There are even products without flavoring. So I don't understand. What are you basing your decision on determining that a flavor is non-compliant?

Could you provide me with the list of prohibited ingredients?

You say that the products are placed on the non-compliant list. Where can I find this list?

In other emails, you asked me to pay annual fees and/or amendments. You say that no invoice will be issued. Why? A company must be able to justify all its expenses.

Also, you asked me to pay for products that you told me were non-compliant and placed on the non-compliant list. Why pay for non-compliant products?

Best regards

Clément Laurent

Chimiste

Pharm-lux

Eliquid-France®

http://www.eliquid-france.com/

05 46 55 02 12