MHRA Update Email #9: Deadlines, Presentation, Brand Names and Advertising

This is a re-post of todays email from the MHRA, for the benefit of those who do not receive them.

Medicines and Healthcare Products Regulatory Agency

Hello from the MHRA e-cigarettes team.
Since our last email, we have received over 1000 UK notifications from large and small companies across the world, with more arriving every day. Some companies have reported to us that the process has taken them longer than expected, so we strongly encourage those of you who have not yet started to do so as soon as possible.
To help you with your notification, this email contains guidance on the notification deadline, notifying non-compliant products, product presentations, product brand names, and advertising.
Notification deadline
As stated on our website and in the UK Tobacco and Related Products Regulations 2016 (TRPR) the deadline for notifications for existing products, and the end of transitional periods for producers, is 20 November 2016.
You can find more information on the transitional periods on our website, as well as specific information for producers and retailers of e-cigarette products.  
Product Presentation draft guidance
The Draft Presentation Guidance is our latest advice on the names and presentations of e-cigarettes and e-liquids, which includes guidance on naming and labelling your product. To download, followDraft Presentation Guidance link and click the downward arrow below the picture.
Advice on ‘Product Brand Name’
The non-confidential information in your notification will be published and may be used by consumers to find out about products they want to use.  We have seen some notifications where a generic brand name is the only identifier and the same name is given to several products.  Please make sure each product notified has a unique name as shown on the product you market.  The ‘Product Brand Name’ (item 34 in the data dictionary), in combination with the Product Brand Subtype Name (item 36) if necessary, should be unique for each product notified. This is to enable consumers browsing notifications to find the product they use. 
As an example, name your product [brand] [flavour] [strength] rather than just [brand].  You may also want to add the company name.
We have also seen some notifications where key information such as the name of the product or the size of a refill container has been marked as confidential.  Please restrict confidentiality marking to fields that contain commercially sensitive information and not fields that are widely known in the marketplace. 
Advertising Restrictions
The Committee of Advertising Practice (CAP) and the Broadcast Committee of Advertising Practice (BCAP) are consulting on new rules and guidance in response to changes in the law prohibiting the advertising of some types of electronic cigarettes and e-liquids in some media channels.
Although the legislative position is already set, CAP is seeking views on its proposals to reflect these prohibitions in its Code. CAP and BCAP jointly are seeking views on their proposals for guidance and on whether the content rules they put in place in 2014 remain proportionate. They also seek responses on proposals relating to the acceptability of advertisements for e-cigarette retailers, which do not feature products.
The consultation closes at 5pm on Monday 31 October

Any other queries

As ever, if you have any technical enquires about the e-cigarette notification scheme under the Tobacco Products Directive, or the work of the MHRA, please send them to our official enquiries inbox:
Thank you for your time in reading and sharing this email with your contacts. We look forward to hearing from you.
Kind regards
Mark Wilcox
Campaigns Specialist

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