FEATURE
FEATURE
Note that all ingredients in the product should be listed on the label where they are used in quantities of 0.1 % or more of the final formulation of the e-liquid . 0.1 % in my opinion is a bit of a joke due to levels of statistical significance , but then the commission and subsequent twisted interpretations have made best attempts at making a mock of the lengths companies need to go through to obtain regulatory status as this potentially reduces big tobacco competition in this sector . Where a flavour ingredient contains several component chemicals , the MHRA considered it acceptable to describe the ingredient on the label by the name of the flavour , for example ‘ strawberry flavour ’. For confidentiality reasons companies may choose to describe individual ingredients used in quantities below 0.1 % of the final formulation by category , for example ‘ other flavourings ’. This advice only applies to product labels , and a full list of ingredients in the flavouring must be included in notifications through the EU-CEG .
Can I take my flavour house to court ? They are not releasing CAS numbers to me and I am legally obliged to provide profile details , as you know . What is your best advice ? Also if this is a magazine question can I remain anonymous ?
Mr Anonymous , Somewhere overseas
Well Mr Anonymous , I suppose you could get a legal team involved , especially if the lack of information stops your company from notification and producing product after November 20th for the European market . I would maybe broach the subject with your flavour house and establish if they own the IP on the formulation you manufacture and sell . Some flavour houses have opened up and started to disclose to us the CAS % levels of inclusion under NDA and transferring via secure FTP upload so do not despair , although slow , things are starting to move and company attitudes are starting to change too .
I ’ ve heard that if you have a tobacco flavour it now needs a new test for TSNA ’ s , however when we completed notification this test was not included , do we have to amend our notification ?
Mr G Green , London
In a nut shell , yes , and this TSNA test has only recently been included as an MHRA requirement . I am almost fearful of by how much these goal posts can keep changing so close to the deadline . I ’ m not the only one thinking that these changes and requests are not legal at this late stage based on our clear deadline of November 20th . The labs are full or filling up at a rate nobody expected and if you were unlucky enough to notify early then these changes in requirement do need to be addressed .
I am struggling to understand what is required for notification regarding Toxicological information , can you summarise what is required for liquids and why ?
Mr J Shah , Manchester
Toxicology is the most important part of the process in my opinion , it basically dictates whether a product is safe for human use and consumption , straight forward when it comes to hardware and extremely complex when we look at liquid formulations . You first need your formulation broken down into its individual component parts and to provide CAS numbers for every ingredient as a start including % levels of inclusion . Once your emissions tests come back from the lab the toxicological research can be completed and signed off per flavour profile . If any red flags are identified , our Tox team will help re-formulate in order to provide an amendment to any notification previously submitted . Hope this helps !
Now having answered a few of your questions , I am back with the nose on the grindstone , the next two months will fly past , I have very little time to myself as it is and I think come Christmas I will be feet up looking at the next round of challenges that face this industry . Keep your questions coming in , I answer all of them even if they ’ re not included in print so do not be shy . I look forward to writing my next Vaporound feature . Stephen @ vapecompliance . com
72 ISSUE 09 VAPOUROUND MAGAZINE