Key Terms

Last updated: May 15, 2026

Heated Tobacco Product

Term Not Defined
Analysis

The law does not define “heated tobacco product.” However, heated tobacco product inserts and electronic tobacco heating devices are covered by the definition of “tobacco product.”

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

Tobacco product

Term Defined
Definition

“Tobacco product”:
(a) means a product comprised in whole or in part of tobacco such as tobacco leaves and any extract of tobacco leaves containing, made, manufactured or derived from tobacco that is intended for human consumption, whether chewed, smoked, absorbed, dissolved, inhaled, snorted, sniffed or ingested by any other means, or comprised mainly of nicotine;
(b) includes any component, part or accessory of a tobacco product such as cigarette papers, tubes, filters, electronic tobacco heating devices and waterpipe, shisha or hookah; and
(c) includes a cigarette.

Analysis

Heated tobacco product inserts are made from tobacco leaves and, therefore, fall under the definition of “tobacco product.” In addition, the definition of “tobacco product” specifically includes “electronic tobacco heating devices.”

Smoking

Term Defined
Definition

“Smoking”, with its grammatical variations, means puffing or inhaling and expelling the smoke of any tobacco product and includes the holding of, or control over, any ignited tobacco product.

Analysis

The law defines “smoking” to include “inhaling” any tobacco product. Because HTPs are tobacco products and the act of HTP use includes inhaling, existing smoking restrictions are interpreted to apply to HTPs.