Tobacco Asia

36 tobaccoasia / Issue 4, 2018 September / October Tobacco Asia The ONLY magazine written and edited for the Asia regional tobacco industry. Read and trusted by industry professionals around the world. Subscribe Now to Tobacco Asia and get a complete view of the tobacco industry. Rates 1 year $45 2 years $80 3 years $105 October Inter Co. Ltd. Interchange 21 Bldg., Room 3225, 32nd Fl. 399 Sukhumvit Road, North Klong Toey Wattana, Bangkok, 10110 THAILAND Tel +66 2 660 3789. Fax +66 2 660 3881 web: www.tobaccoasia.com. Published 5 times a year in full English and Chinese versions. To subscribe visit: tobaccoasia.com or email info@octobermultimedia.com A Veritable Minefield of Regulations The export (and subsequent import into the destination country) of nico- tine and nicotine products classified as hazardous is subject to a plethora of obligations, regulations, guidelines, conditions and, yes, even bans. For international land transport, hazardous substances have to be car- ried out und the regulations stipulated by the ADR Convention ("L'Accord Européen Relatif au Transport International des Merchandises Dangere- uses par Route"). Air cargo is subjected to the rules imposed by IATA, the "International Air Transport Association". Similarly, sea transport is regulated based on the IMDG, "International Maritime Dangerous Goods Code". The ADR, IATA, and IMDG regulations encompass rules on the necessary training of involved personnel and the forwarding company's liability for the transported dangerous or hazardous goods, but also clas- sifications of dangerous goods in accordance with UN recommenda- tions, packaging rules, labeling specifications, documentation rules, and a whole slew more. Then there are, at least as far as Chemnovatic is concerned, the regulations imposed by the European Chemicals Agency (ECHA). "Once a year, we must report on the amount of nicotine ex- ported to countries outside of the EU, including the destination countries, customer names, and other data," details Chemnovatic's co-owner and c.o.o., Bartlomiej Gęca. "And before we can legally export nicotine and nicotine products classified as hazardous materials in compliance with CLP), we must apply to ECHA for a RIN number, which must be done 35 days before the planned shipment date." But, there are countries that do not have signed contracts with ECHA, in which case legal exporta- tion is impossible. "Furthermore, before sending the nicotine abroad, we need to know exactly what type is legal in a given country and what uses of it are permissible if we want to avoid unnecessary problems," Geca says. "In such cases, it's imperative to constantly maintain contact with the customer to quickly react and respond to any difficulties when the customs office questions the shipment." Another issue are specialized taxes that some countries have started to apply on nicotine products. "We also need to consider that fact to not be caught off guard during customs clearance." [Chemnovatic Sp. z o.o. Sp. k.] Chemnovatic's executive team; from left to right: Emil Sołtan, Marcin Ławecki, Bartłomiej Gęca, Marcin Górecki Quality check of nicotine products at Chemnovatic [Chemnovatic Sp. z o.o. Sp. k.] analyzed according to USP and EUP requirements and we can provide quality certificates at any time upon request. Chem- novatic has been focused on quality from the very beginning, which helped us to grow very quickly in just a few years." He adds that such certification is of crucial importance to customers because it assures them of consistently high quality and safety standards. "We know very well that the ingredients we sell to manufacturers have a great influence on their final product qual- ity. The better the quality of their products, the more they can sell. And the more they can sell, the more ingredients they need from us. It is a very simple principle." When new customers approach Chemnovatic with inquiries for nicotine orders, the company involves them in a thorough pro-active discussion. "The more details we have, the easier it will be for us to advice the customer on the proper nicotine type suited to their manufacturing," explains Lawecki. Another important aspect are the legal regulations enforced in any given country where the product is to be marketed. "Often the clients themselves do not know if they can import nicotine into their country at all," Lawecki says. "In such a situation we try to help them by contacting the appropriate authorities to determine what requirements must be met to send the shipment without running into problems." For example, there are countries where a particular variety of nicotine is banned entirely or some of its potential uses are not permitted. (Read more on these legal aspects in our side box.)

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