There have been so many scare stories lately, and so few actual facts about so called "bans" on snuff, that I've been forced to spend a few hours researching the matter.
All I can find is a fairly straightforward piece of legislation called "The Tobacco and Related Products Regulations 2016", which implements EU Directive 2014/40/EU.
The UK legislation has been around for over six months, and the EU Directive for over two years, so why there should be a panic now, I can only conclude that greedy snuff manufacturers have lied to us all, and tried to cause panic buying in the same way that Unilever has threatened to hike up the price of Marmite etc. to boost sales, blaming exchange rates and Brexit, when in actual fact Marmite is made in the UK and article 50 hasn't even been triggered yet, so there's no reason whatsoever for the pound to be at a 168 year low, especially since we've only been part of Europe for about 40 years...
I'm so irritated that the likes of snuffsnore.co.uk etc. seem to have been behind this scare, along with cheating people out of their loyalty points, that I'm going to go through the whole legislation piece by piece, converting the parts relating to snuff from legalese to plain English - Don't worry, there's only ten parts and most doesn't even apply to snuff.
For those that want a TLDR;
- There are no restrictions whatsoever on pack sizes
- Almost nothing stops you calling your snuff whatever you want to
- There is very little testing involved for snuff manufacturers
- This is basically an information gathering exercise that would at worst take a couple of hours work per product
- Much of this is just consolidating multiple pieces of existing law together
Part 1 is all definitions for the rest of the document, telling you how to interpret certain phrases etc.
Part 2 is all about health warnings, it looks like snuff containers will need to have an indelible warning in the centre of the front and back of the container, covering 30% of each space, in black Helvetica font on a white background with a 1mm black border, for snuff this can be a non-removable label.
Part 3 says you can't sell snuff with vitamins in it, nor stimulants (caffeine, guarana, etc.), nor products that aide nicotine uptake, nor additives that are harmful or increase the harmfulness of tobacco. Plus you can't claim any health benefits for snuff. Oral use tobacco is banned.
Part 4 says that the Secretary of State may ask for studies into the harmfulness of products being sold in future, and needs to be notified when a tobacco product is withdrawn from sale. A list of snuff ingredients needs to be made and sorted by weight, the reason for use needs to be included, as well as whether that material has a safety data sheet (if it doesn't REACh regulations have already made that ingredient illegal to manufacture or import), it's hazard class needs to be included too, but you'd find that on the SDS anyway. Any other health related data available needs to be included.
Here's where I think the confusion comes in, "tar" and nicotine levels need to be measured. As far as I can see here, this information may already exist, since there seems to be plenty of information on this for various brands of cigarettes, but assuming it doesn't (and assuming that some of the ingredients in snuff aren't extra "tar" or nicotine), you'd get quotes from a few universities for all the different tobacco varieties you're using, analyse say 1g of each type, then you can simply say this tin contains 10 times as much or 25 times as much or whatever. I'd expect each test would likely cost a few hundred pounds, but once it's done, it's done (assuming the information isn't already available freely). Plus nothing in the legislation says that manufacturers can't get together and share the expense of the tests if they're using the same varieties of tobacco. Having never bought raw tobacco myself, it might even turn out that the information is available from the supplier, or they know someone that's had the tobacco tested already.
Various sales volume data and market research information needs to be reported, and all the above needs to be sent electronically, otherwise you can't sell the product.
I'd guess that part 4 might cause problems for snuffs manufactured outside Europe, where information about the ingredients isn't readily available.