Health Canada and Rothman Benson & Hedges meeting: Proposed Tobacco Product Regulations – July 31, 2018

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Subject:

Meeting to discuss the proposed Tobacco Products Regulations (Plain and Standardized Appearance)

Date:

July 31, 2018

Participants:

Health Canada (HC)

  • Saira David
    • Director, Labelling and Plain Packaging Office, Tobacco Control Directorate (TCD) (Chair)
  • Manager, Plain Packaging (TCD)
  • Policy Analyst, Plain Packaging (TCD)

Rothman Benson & Hedges (RBH)

  • Maya Zor
    • Legal Counsel, Rothman Benson & Hedges

Introduction:

A meeting was held at the request of Maya Zor, Rothman Benson & Hedges (RBH), to discuss the proposed Tobacco Products Regulations (Plain and Standardized Appearance).

The Chair opened the meeting by reiterating HC's international obligation to protect tobacco control policies from the vested interests of the tobacco industry. In addition, in the interest of transparency, the Chair stated that it would be making a record of the meeting publicly available.

RBH stated that the meeting would focus on issues of concern with complying with the proposed Regulations

Subjects:

1) Placement of Brand Name

RBH mentioned that while mocking up a cigarette package the designers at RBH found that the brand names placed on the front panel would overlap with the common name and net quantity required by the Consumer Packaging and Labelling Regulations. RBH recommended that HC require the brand name to be centered in the remaining space on the front of the package. HC stated that it would look into the issue and address it if needed.

RBH also stated its concerns with putting the brand name on the sides of the packaging as there currently are long brand names that could not fit on the sides, especially if placed next to other markings, such as toxic emissions statements, tax stamps or bar codes. RBH's recommendation was to allow brand names to be up to 14pt font rather than exactly 14pt font.

2) Tracking Numbers on Packaging

RBH pointed out that each of the members of the major cigarette manufacturers in Canada were bound by Comprehensive Agreements with the federal, provincial and territorial governments to provide identifiers on their packaging. RBH was concerned that the current regulations, while permitting markings required by other Acts and Regulations, would not permit these markings under the requirements of its agreement.

HC stated it would clarify how the terms and requirements of the regulations address the requirements of the comprehensive agreement.

Conclusion:

RBH thanked HC for the opportunity to discuss technical elements of the proposal.

HC indicated that information submitted through the public comment period will be considered and that future meeting requests regarding the proposed regulations should be directed to James Van Loon and/or Saira David.

The meeting was then concluded.

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