Last updated: January 6, 2026
Key Terms
Heated Tobacco Product
"Heated tobacco" means a tobacco product specifically designed to be heated, which releases an aerosol containing nicotine and other substances, inhaled by users through the mouth.
For the purpose of this review, we will use the term “HTP” when referring to a “heated tobacco product.”
Tobacco Product
"Tobacco products" means products that can be consumed and consist, even partly, of tobacco, whether genetically modified or not.
HTPs, which are made of tobacco, fall within the definition of “tobacco products.” We interpret the definition of “tobacco products” to cover HTP inserts. However, it is unclear if the definition covers HTP devices themselves.
Smoking
"Smoking" refers to the lighting, inhalation, or holding of any tobacco product, including electronic cigarettes and water pipes (hookahs).
“Smoking” includes “inhalation" and "holding any tobacco product.” HTPs are tobacco products. Therefore, the use of a HTP is considered smoking.
Novel Tobacco Products
"Novel tobacco products" mean those tobacco products which:
a) do not fall into any of the following categories: cigarettes, roll-your-own tobacco, pipe tobacco, waterpipe tobacco, cigars, cigarillos, chewing tobacco, nasal tobacco or tobacco for oral use; and
b) are placed on the market after the entry into force of this law.
The definition of “novel tobacco products” is significant because novel tobacco products include HTPs and, therefore, are subject to disclosure requirements.
