Other Packaging and Labeling Requirements
The law requires that all tobacco products for sale in Rwanda must bear health warnings on product packaging.
The law meets FCTC Art. 11 with respect to warnings on unit packaging and labeling of tobacco products.
The law requires that all tobacco products for sale in Rwanda must bear health warnings on product packaging. The definition of “package” includes all packaging used in retail sale, which would include cartons and other outside packaging and labeling.
The law meets FCTC Art. 11 with respect to warnings on outside packaging and labeling of tobacco products.
Ministerial Order No. 20/34 requires warnings to appear in Kinyarwanda and English or Kinyarwanda and French.
The law meets FCTC Art. 11 with respect to requiring health warnings to be in the principal languages of Rwanda.
A requirement that warnings or messages may not be placed where they may be permanently damaged or concealed when opening the pack
The law prohibits printing health warnings “in a place where [they] may be damaged when the packaging is opened.”
The law aligns with FCTC Art. 11 and the FCTC Art. 11 Guidelines in this regard.
A requirement that tax stamps or other required markings may not be placed where they may conceal warnings or messages
The law prohibits health warnings from being obstructed by “other packaging and labeling marks.”
The law aligns with FCTC Art. 11 and the FCTC Art. 11 Guidelines in this regard. The law could be strengthened by giving examples of what is considered “other packaging and labeling marks,” to include tax stamps.
Ministerial Order No. 20/34 requires that packaging “bear a statement of the tar, nicotine and carbon monoxide content in milligrams per tobacco product.” There is no requirement that this “statement” including qualitative or descriptive information about constituents and emissions messages.
To align with FCTC Art. 11 and the FCTC Art. 11 Guidelines, the law should affirmatively require a qualitative statement about toxic elements such as nicotine, tar, and carbon monoxide and should eliminate all yield figures.
Prohibition on the display of figures for emission yields (including tar, nicotine, and carbon monoxide)
Ministerial Order No. 20/34 requires that packaging “bear a statement of the tar, nicotine and carbon monoxide content in milligrams per tobacco product.” However, the order does not contain any further details about where this information is required to be placed.
To align with FCTC Art. 11 and the FCTC Art. 11 Guidelines, the regulations should prohibit the display of figures for emissions yields as these figures can be misleading to consumers.
Plain packaging of tobacco products is not required. The FCTC Art. 11 Guidelines provide that Parties should consider adopting plain packaging measures that restrict or prohibit the use of logos, colors, brand images, or other promotional information on packaging other than brand and product names displayed in a standard color and font style. Plain packaging aims to reduce the appeal of tobacco products, to increase the noticeability of health warnings, and to reduce the ability of the packaging of tobacco products to mislead consumers about the harmful effects of smoking.
Prohibition on misleading tobacco product packaging and labeling including terms, descriptors, trademarks, or figurative or other signs (e.g., logos, colors, brand images that directly create a false impression that a tobacco product is less harmful than other tobacco products)
The law prohibits on tobacco product packaging the use of misleading terms such as “low tar,” “light”, “ultra light”, “mild”, and “ultra.” The law, however, does not extend this prohibition to cover other misleading indicia, such as numbers and colors.
To meet FCTC Art. 11, the law should prohibit not only misleading terms, but also any colors, numbers, signs, or other indicia that imply the same.