Product Regulatory Compliance

Gloved hands holding a tray of test tubes
17 September 2024
CHAPTER 5 . OUR SMOKELESS PRODUCTS

Product Regulatory Compliance

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We ensure that all of our Smokeless Products comply with global and national safety standards, where applicable.

BAT-developed Smokeless Products include electronic products and accessories supplied to us, and to our subsidiary companies, by third-party manufacturers. Our supply chain uses material declarations to track and declare specific information about the material composition of its products.

 

To harmonise requirements across the supply chain and to improve economic efficiency, we follow international standards and practices covering the determination of regulated substances. This allows for a global, harmonised approach to the exchange of material composition data, and provides the requirements for material declarations and test methodologies.

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REACH

We ensure that our products and materials supplied to us comply with the EU Regulation on Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), which addresses the production and use of chemical substances and their potential impacts on human health and the environment. Materials used in all product and product packagingrelated applications are assessed against the REACH Candidate List published and updated regularly by the European Chemicals Agency.

 

Electromagnetic compatibility

Electromagnetic interference (EMI), or radiofrequency interference (RFI), may degrade the performance of a circuit or even stop it from functioning.

 

We comply with the International Electrotechnical Commission’s (IEC) standards to provide a presumption of conformity with the protection requirements of Electromagnetic Compatibility (EMC) regulations, covering emission and immunity.

 

International harmonised standards are designed to satisfy the protection requirements of various global EMC approaches, for example, the European Union’s EMC Directive.

 

Our simplest route to compliance is to use standards that cover the whole of the EMC protection requirements of the appropriate product standards, i.e. product-family or dedicated product standards that cover our Heated Products and Vapour Products. For our electronic Heated Products and Vapour Products, the appropriate product standards family is: ‘household appliances and portable tools.’

"We submit our products for independent third-party certification, which provides clear evidence that they comply with the required safety standards."

 

Dr Marianna Gaca

Group Head of Product Regulatory Compliance

Portrait of Dr Marianna Gaca, Group Head of Product Regulatory Compliance

RoHS restrictions

We abide by IEC 63000 regarding the technical documentation for the assessment of electrical and electronic products with respect to the restriction of hazardous substances. Substances restricted under the EU’s Restriction of Hazardous Substances (RoHS) Directive (2011/65/EU) in electrical and electronic equipment (not batteries) include cadmium, chromium VI, lead, mercury, polybrominated biphenyls (PBB), and polybrominated diphenyl ethers (PBDE).

 

All BAT-branded non-electrical and non-electronic Smokeless Products and parts must satisfy the minimum requirements of the legislation, and suppliers should comply with local laws and regulations where the products are sold.

 

Certain RoHS Directive exemptions can be used on our Smokeless Product parts. However, it is expected that alternative, compliant materials will be used where possible.

 

Low voltage safety

The standards that apply to electrical appliances that fall within low voltage regulations - including the EU’s Low Voltage Directive (LVD) voltage limits - also encompass battery-operated appliances at much lower ratings. These include our Heated Product and Vapour Product devices. This ensures safety protection for consumers throughout their likely use.

 

Conformity with the IEC harmonised standards provides a presumption of conformity with the protection requirements of Low Voltage (LV) regulations.

 

Our simplest route to compliance is to use standards that cover the whole of the LV protection requirements of the appropriate product standards. IEC 60335-1 is the core safety standard for our appliances, since it deals with the safety of electrical appliances for household and similar purposes.

 

Wireless (connected appliances)

Wireless regulations are often governed by end market product specific regulations that establish the requirements for all wireless transmitters and receivers, apart from devices used exclusively for military, state security, radio amateurs, and civil aviation. We follow the appropriate regulations, articles and approaches for wireless standards when producing connected products in the Heated Products and Vapour Products categories.

 

Product packaging

The BAT Group’s Product Stewardship Council (PSC) guidelines for packaging help to ensure that product packaging materials do not pose a toxicological risk to the consumer, either directly, or via contamination of the product by the packaging.

 

Substances not to be used as ingredients in packaging materials include but are not restricted to: substances classified as carcinogenic, mutagenic or toxic for reproduction, according to the Provisions of Regulation (EC) No 1272/2008 on classification, labelling and packaging substances and mixtures.