Product requirements for novel tobacco products may differ depending on if it is a smokeless tobacco product or of a tobacco product for smoking. It is still you as a manufacturer or importer that are responsible to ensure that the product are compliant with the product requirements.
Product requirements on smokeless tobacco products
Product requirements on tobacco products for smoking
Additional requirements for heated tobacco products
There will be additional product requirements for heated tobacco products. These includes additional prohibited additives and a prohibition on characterising flavour. The Commission Delegated Directive (EU) 2022/2100 states that these provisions must be applied from 23 October 2023. Please not that these rules is proposed to enter into force in May 2024 in Sweden.
Commission Delegated Directive (EU) 2022/2100 (eur-lex.europa.eu)
Heated tobacco products must not contain:
- Flavourings in any of their components such as filters, papers, packages, capsules or any technical features allowing modification of the smell or taste of heated tobacco products or their smoke intensity.
- Tobacco or nicotine in filters, papers or capsules.
Prohibition of heated tobacco products with a characterising flavour
It is prohibited to provide heated tobacco products with a characterising flavour on the Swedish market. Characterising flavour is a clearly noticeable smell or taste other than one of tobacco, resulting from an additive or a combination of additives, including, but not limited to, fruit, spice, herbs, alcohol, candy, menthol or vanilla, which is noticeable before or during the consumption of the tobacco product.
The prohibition of heated tobacco products with a characterising flavour does not exclude the use of additives which are essential for the manufacture of the product provided those additives do not result in a product with a characterising flavour and do not increase to a significant or measureable degree the addictiveness, toxicity or the carcinogenic, mutagenic or toxic to reproduction properties of the product.
There is a procedure that we use when determining whether or not heated tobacco products has a characterising flavour:
Determination of characterising flavours in tobacco products (health.ec.europa.eu)