Location and Size of Warnings / Messages on Unit Packaging
50% of Front, 50% of Back, 17% of Side(s)
Rotation
Uncertain
Number of Warnings / Messages Authorized to Be Displayed at Any Given Time
12
Length of Rotation Period
Uncertain
Analysis
Law No. 121/2021 adopts the packaging and labeling rules contained in the EEC Technical Regulations on Tobacco Products. The Technical Regulations require picture and text warnings to cover at least 50% of the front and back of the package, and a text warning on contents and emissions to cover 17% of the side of the package. Each EEC member state submits proposed warnings to the EEC for approval. The approved warnings for Kyrgyzstan are contained in EEC Decision No. 18 of 2016. There are 12 warnings, which presumably must be in circulation simultaneously. However, the regulations do not specifically state that each warning must appear an equal number of times across brands and products, nor does it specify how frequently warnings must be updated.
The law meets FCTC Art. 11 and aligns with the FCTC Art. 11 Guidelines with respect to location, size, and content. However, to fully align with FCTC Art. 11 and the FCTC Art. 11 Guidelines, the law should explicitly require the 12 warnings to rotate on a regular basis or appear equally across brands and products in a given year. The law should also require updating of warnings every 12 to 36 months.
Location and Size of Warnings / Messages on Unit Packaging
65% of Front, 65% of Back, 17% of Side(s)
Rotation
Not Required
Number of Warnings / Messages Authorized to Be Displayed at Any Given Time
1
Length of Rotation Period
Not Applicable
Analysis
Law No. 121/2021 requires each consumer package of naswar to contain a warning about the dangers of naswar occupying at least 65% of the two main sides of the package. The warning must be in the state language on the front side and the official language on the reverse side. In addition, the law requires the following qualitative (descriptive) constituents and emissions message on 17% of the side of the package: “Contains systemic poisons, and carcinogenic and mutagenic substances." All of smokeless tobacco products, other than naswar, are banned.
The law meets FCTC Art. 11 and aligns with the FCTC Art. 11 Guidelines with respect to size and location. However, to more fully align with FCTC Art. 11 and the FCTC Art. 11 Guidelines, the law should require picture warnings in addition to text, require multiple warnings, and require rotation of these warnings, including updating every 12 to 36 months.
