Last updated: May 23, 2025

Key Terms

Heated Tobacco Product

Term Not Defined
Analysis

The law does not contain a definition of “heated tobacco product.” However, the law contains definitions for the terms “substitute” and “imitator.” Both of these definitions are interpreted as being inclusive of heated tobacco products.

For the purpose of this review, we will be using the term “HTP” when referring to a “heated tobacco product.”

Substitute

Term Defined
Definition

"Substitute” means any product marketed or otherwise presented as a partial or total substitute for tobacco products, whether or not such product is suitable for that purpose.

Analysis

The law contains a definition of “substitute.” This definition is interpreted as being inclusive of heated tobacco products.

Imitator

Term Defined
Definition

“Imitator” means any product intended to replace or substitute another product by exploiting its physical properties or consumption characteristics.

Analysis

The law contains a definition of “imitator.” This definition is interpreted as being inclusive of heated tobacco products.

Tobacco and tobacco products

Term Defined
Definition

For this law, when the expressions "tobacco," "tobacco and its derivatives," "tobacco products," "tobacco products and its derivatives," "cigarettes, tobacco or its derivatives," or "cigarette products, tobacco and its derivatives" are used, it shall be understood as "cigarettes, tobacco products, its derivatives, substitutes or imitators and the devices necessary for their operation; among which are Electronic Nicotine Delivery Systems (ENDS), and Electronic Non-Nicotine Delivery Systems (ENNDS), Heated Tobacco Products (HTP) and Oral Nicotine Products (ONP), among others.

Analysis

Law No. 2354 amends Law No. 1335 in such a way as to be inclusive of HTPs (inserts and devices) whenever the terms "tobacco," "tobacco and its derivatives," "tobacco products," "tobacco products and its derivatives," "cigarettes, tobacco or its derivatives," or "cigarette products, tobacco and its derivatives" are used in the original text of Law No. 1335. Therefore, the tobacco control measures set out in Law No. 1335 are applicable to HTPs, including tobacco inserts and devices.