Vastuskiri

Hello

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.

However, 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 25 of the CLP Regulation, the package must have a UFI code, the use of which has been notified through the portal of the European Chemicals Agency's Poison Centres based on Article 45 and Annex VIII of the CLP Regulation. 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.  

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

Kind 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

This e-mail is confidential and meant for use by the person named in the letterhead. Any use in any way or copying of it by a person not marked as the addressee thereof is prohibited. If you have got this e-mail by mistake, please notify of it the sender without delay and delete the received e-mail together with all its attachments.

 Dear Sir/Madam,

1. Is there a requirement to notify Nicotine pouches in your country?

2. If these products do need to be notified, through which route do we need to notify them?

3. Is there any further information you can provide me with in regards to this matter?

I look forward to hearing from you.

Thanks