.,.AMENDED+, AMENDED TEXT
H.E. SULEIMAN AL SULAYYEM
MINISTER OF COMMERCE
MINISTRY OF COMMERCE
RIYADH
SAUDI APA21A
YOUR EXCELLENCY,
AS IMPORTERS AND MANUFACTURERS OF CIGARETTES SOLD
IN THE KINGDOM
OF SAUDI ARAB I A, WE UNDERSTAND THAT PURSUANT TO
THE ARAB GULF
STATES HEALTH MINISTERS' COUNCIL RESOLUTION NO. L
OF JANUAPY,
1986 THE CIGARETTE IMPOPT SPECIFICATION, SASO
362/82, HAS BEEN
AMEJ,IDED.
THIS SPECIFICATICN FURTHER REDUCES TAP AND
NICOTINE LEVELS AND
CHANCES THE PLAC5MENT AND EXPLANATION OF THE
WARNING LABEL.
IT ALSO IMPOSES A TOTALLY NEW REQUIREMENT THAT THE
MONTH ALONG
WITH THE YEAR OF MANUFACTURE MUST APPEAR ON THE
PACKAGE.
WE PESPECTFULLY EYPPESS OUR STRONG RESERVATIONS
ABOUT THESE SIG-
NIFICANT POLICY CHANGES AND REQUEST THAT THESE
IMPORTANT MATTERS
BE REVIEWED PRIOR TO THE DATE WHEN THEY WILL
BECOME EFFECTIVE.
WITH REFEZENCE TO THE PROVISION IN THE
SPECIFICATION REQUIRING
THE MONTH OF MANUFACTURE ON THE PACKAGE, WE ARE
CONCERNED ABOUT
THIS POLICY DECLARATION WHICH PLACES CIGARETTE
PRODUCTS IN THE SAME
CATEGORY AS PERISHABLE FOOD PRODUCTS. THIS WILL
CONFUSE
CONSUMERS AND CAUSE BUSINESS PROBLEMS FOR US AND
THOUSANFS OF SMALL
TRADERS IN THE KINGDOM. TOBACCO PRODUCTS ARE NOT
AT ALL SIMILAR TO
FOOD PPOC4_1CTS W1FICH CAN SPOIL QUICKLY AND
BECOME UNFIT FOP HUMAN
CONSUMPTION. IN ADDITION, NO OTHER GOVERNMENT HAS
IMPOSED SUCH
A LABELING REQUIzEEMENT ON TOBACCO PRODUCTS.
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BATCo document for Province of British Columbia 2
November 1999


WITH REGARD TO THE AMENDMENT IN THE SPECIFICATION
WHICH WILL CAUSE
A SUDDEN, SHARP REDUCTION IN THE MAXIMUM TAR AND
NICOTINE LEVELS,
IT 15 SUGGESTED IN THE SCIENTIFIC LITERATURE THAT
SUCH A POLICY C'~-N
CAUSE A RADICAL CHANGE IN THE WAY SOME INDIVIDUALS
SMOKE THAT WOULD
NOT BE ACCEPTABLE TO PROPONENTS OF THIS POLICY.
FOR EXAMPLE,
SMOKERS CAN TAKE MORE PUFFS, INHALE MORE DEEPLY,
SMOKE MORE
CIGARETTES OR EVEN PIP OFF THE FILTER BEFORE
SMOKING THE
CIGARETTE.
SOME SMOKERS WILL SEEK TO DETAIN THEIR PREFERRED
PRODUCTS FROM
COUNTRIES WHICH 00 NOT IMPOSE SUCH LIMITATIONS.
ONLY EGYPT AND
FINLAND IMPOSE SUCH LEGAL LIMITS AND THEIR
REQUIRMENTS ARE NOT
SO SEVERE AS THOSE IN THE GCC MEMeZP STATES.
THE CIGARETTE MANUFACTURING TECFNOLOGY BY WHICH
SUCH TAR AND
NICOTINE REDUCTIONS ARE ACHIEVED AND MAINTAINED
WITH HIGH QUALITY
PRODUCTION CONTROLS IS NOT COMMONLY USED
THROUGHOUT,THE
TOBACCO INDUSTRY. FOR EXAMPLE, OVEP ONE HALF OF
THE
TO~ACCO PRODUCTS MANUFACTURED IN THE WORLD EACH
YEAR
APE PRODUCED BY COMPANIES OWNED AND OPERATED BY
GOVERNMENTS. A SIGNIFICANT NUMBER OF THESE
GOVERNMENT
OWNED COMPANIES WILL EXPERIENCE GREAT DIFFICULTY
IN EXPORTING
PRODUCTS WHICH COMPLY WITH THESE MAXIMUM TAR AND
NICOTINE
LEVELS. THIS RAISES IMPORTANT TRACE QUESTIONS.
THE SECOND PAGE OF THE ENGLISH TEXT SHOULD REMAIN
AS APPROVED.
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BATCo document for Province of British Columbia 2
November 1999