Undefined key terms or ambiguous definitions can undermine the application of other substantive provisions of a law. A definition of “tobacco product” should be provided in accordance with the FCTC definition.
Any product entirely or partly made of the leaf tobacco as a raw material which is manufactured to be used for smoking, sucking, chewing, or snuffing. (FCTC Art. 1(f))
Having no definition for this key term makes it difficult to interpret and implement the packaging and labeling requirements. This can hamper application and implementation of FCTC Art. 11 and the FCTC Art. 11 Guidelines.
A definition of “outside packaging and labeling” should be provided in accordance with FCTC Art. 11(4).
Any packaging and labeling used in the retail sale of the product. (FCTC Art. 11(4))