Health Canada, Imperial Tobacco Canada, JTI-Macdonald Corp., Rothmans and Benson & Hedges Inc. meeting: Proposed Tobacco Product Regulations – December 13, 2018
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Meeting to discuss the proposed Tobacco Products Regulations (Plain and Standardized Appearance)
December 13, 2018
Health Canada (HC)
- James Van Loon
- Director General, Tobacco Control Directorate (TCD)
- Saira David
- Director, Labelling and Plain Packaging Office, TCD
- Senior Advisor, Director General’s Office, TCD
- Manager, Labelling and Plain Packaging Office, TCD
Canadian Tobacco Manufacturers’ Council (CTMC)
- Caroline Evans
- Head of Corporate Affairs & Communications, JTI-Macdonald Corp. (JTI-M)
- Eric Gagnon
- Head of Corporate and Regulatory Affairs, Imperial Tobacco Canada (ITCAN)
- Maya Zor
- Legal Counsel, Rothmans, Benson & Hedges Inc. (RBH)
A meeting was held at the request of Imperial Tobacco Canada, JTI-Macdonald Corp., and Rothmans, Benson & Hedges Inc., under the auspices of the Canadian Tobacco Manufacturers’ Council (CTMC) to follow-up on previous discussions with respect to the proposed Tobacco Products Regulations (Plain and Standardized Appearance) (PSA).
The Chair opened the meeting by doing round table introductions.
The Chair reminded participants that this meeting is subject to disclosure as per HC’s Openness and Transparency policies. In the interest of transparency, the department stated that it would be making a record of the meeting publicly available. The handling of information and privacy notice was mentioned and acknowledged.
HC also referred to Article 5.3 of the World Health Organization Framework Convention on Tobacco Control, its international obligation to protect tobacco control policies from the vested interests of the tobacco industry.
The CTMC acknowledged that with a federal election taking place in fall 2019, they are aware of the mandate commitment to implement PSA for tobacco products. The CTMC further stated that they are concerned with their ability to deliver compliant products based on the proposed Regulations pre-published in Canada Gazette, Part I in June 2018, and that they are pushing to the maximum of their ability to be able to comply. To that end, the CTMC raised the following issues:
1. Timing and Implementation:
The CTMC acknowledged that the proposed Regulations would require slide-and-shell packages 6 months after the final Regulations are made. The CTMC stated that 24 months would be needed to be able to transition to slide-and-shell packages only. The CTMC indicated that a full transition to slide-and-shell, including artwork, could be achieved within this time-frame. The CTMC confirmed that investments have been made for slide-and-shell and that they are working and planning under the assumption that the government will proceed with requiring slide-and-shell packages.
The CTMC informed HC that other departments have asked them whether they had considered obtaining slide-and-shell machinery from other suppliers. The CTMC confirmed that there is only one company that has built this machinery before, and that they do not wish to work with suppliers who have no experience with slide-and-shell machinery under tight timelines.
HC stated that the department will do its best to ensure that the industry is informed of the final publication of the Regulations.
2. Technical Concerns:
The CTMC reiterated some of the technical concerns that were observed in the proposed Regulations that were pre-published in Canada Gazette, Part I:
- Insert for slide and shell format: The CTMC observed a discrepancy between the Tobacco Products Labelling Regulations (TPLR) and the proposed PSA Regulations that would impact the King Size 20 format. The CTMC stated that the TPLR calls for an insert for this package format based on its dimensions, but the objective of the PSA Regulations is to have information on the tobacco package.
- Production code/font size & alignment/ length and diameter: The CTMC reiterated their technical concerns with the requirements regarding production codes, font size and alignment, and length/diameter of cigarettes and pack size. HC responded that the concerns were received.
- Consumer contact information on packaging: The CTMC requested a provision that would allow the display of contact information on a tobacco product package, should a consumer wish to submit a complaint or follow-up on a recall.
- Reverse printing: The CTMC requested that the department revisit the requirement for Pantone 448C to be used on both sides of cardboard for a package due to concerns with glue adherence and the clarity of calibration marks on the interior of the packages. The CTMC stated that an unprinted interior would help the industry meet the proposed implementation timeline.
- Implementation timelines: The CTMC proposed a scenario where they could fully comply with the proposed regulations (i.e. artwork only, without the standardization of the cigarettes).
3. New Health Labelling for Tobacco Packaging: Document for Consultation:
The CTMC stated their concerns with the timing for new health labelling for tobacco product packaging, such as the increased complexity and costs for operational planning. The CTMC indicated that they will highlight their concerns in their submission to the consultation on new health labelling for tobacco product packaging.
The CTMC asked whether HC saw any red flags during the meeting. HC thanked the CTMC for raising their concerns, and indicated that the department was working diligently to finalize the regulations. The meeting was then concluded.
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