Labelling and Packaging Methodology
The LABELLING & PACKAGING section of CORE COMPLIANCE relates to aspects such as; external packaging, unit labels, local languages, warning symbols, child-resistant and tamper-evident certifications and safety data sheets.
Misleading / Child-Enticing
Child appealing labelling & packaging is prohibited in almost every market, whether through a regulatory platform or on an ethical basis. There is some debate as to what branding is acceptable. If for example, your flavour name is “Strawberry & Kiwi”, you would be allowed to depict these fruits. However the product must not contain any elements or features that could be seen as enticing to children or mislead consumers as to the nature and intended use of the product.
It is imperative that you do not make any claims that your product is in any way healthier than combustible tobacco or any other vapour product. Not only is this illegal in Europe, it will also open your brand up to legal action should anyone be able to prove otherwise.
Pictograms / Symbols
Warning symbols are the conduit for conveying the potential health risks posed to your consumers. You should conduct a full analysis of your products and identify the warning obligations based on product AND market. There is rarely a one size fits all approach to this problem.
Child-proof / Tamper-proof
Taking the time to undertake some due diligence prior to appointing any suppliers is a positive step. Any reputable supplier will be able to provide you with industry credentials, product safety certification (Child-resistance & Anti-Tamper) as well as any quality management membership.
Safety data sheets
SDS are the first thing any regulator will see, when your shipment arrives at the port of entry. Having your SDS in the appropriate format and language for that country is a legal obligation. With Europe clamping down on non-compliant vapour products, you can be sure that SDS files will be something that many regulators will focus on.
There is no official, regulatory definition of what a ‘nicotine dose’ is but our advice is to use a laboratory that will provide a report on nicotine emissions showing a dose value either per puff or per series of puffs. This value can then be displayed on your product packaging as either ‘mcg’ or ‘µg’. Your packaging should indicate as to whether the value displayed refers to the content within a single puff or series of puffs so that the information is clearly provided to the consumer.
Having the appropriate safety information in the form of a leaflet included in the box or via a peel-out label is mandatory under TPD in Europe.
The leaflet/label must contain all the appropriate instructions and group specific contra-indications health data as well as information for where to report safety concerns around your product.
For more information on CORE COMPLIANCE, please contact us.