B.A.T. SOUTHAMPTON TEL: 07C!-779?15 L7f2'7-7Q,-7i58 -40-003 P.05
Tobacco Alralm Groan I!aar_r
Snb*ect: Group Additives and Product CgmtljQ=t Usage
Background and Context
The Group has to-date followed a consistent policy to ensure that products sold meet
not only specific legal obligations, but that where external standards differ frorn one
geographic region to another, it seeks to emure that the highest relevant scientific
standards are applied across all operations.
In the case of components of cigarette manufkture and additives used in the product.
the regulations concerned with their use can vary considerably. They range from the
relatively clear position that exists in several European Countries (Germany. France
and UK) to the requirement for disdosure to, but without specific control by
gavcsjunent as in the case orthe 'USA. The position is fbrther complicated, with some
countries having an absence of tiny controls on components and additives used in
cigarette manufacture leaving the anus of responsibility for their use to the
manufactul er
In recent years there has bccn increasing interest by govcrnmeots and regulators to
focus on the issues of product safety in many sectors of industry but notably in the
areas of food processing. pharmaceuticals. Uvours, agrochanicals and tobacco and
cigarette mainsfacture. It is proposed that the Group should establish a system to
ensure that it is strategically positioned to be abit to respond rapidly and efrectively to
future government and regulatory demands and be able to defend its use of specific
components of cigarette manufacture and additives, both by amount and if necessary at
the level of the brand.
In view of the fact that a single sourced Group product can be sold in an array of
export markets, there is a rupit cincnt to be vigilant in ensuring that products, as a
Minimum, comply with local regulations with responsibility for product composition
clearly identified. In addition, the responsibilities for product compliance and product
composition for products manufactured by third parties and marketed by the Group
need to be delineated
A review of Group policy has been undertaken and a series of elements proposed that
will allow the Group to continue to most its legal obligations and responsibilities and
be rciponsive to an evolving regulatory framework which respects operating group
autonomy and Proprietary brand considerations
stnternerit or policy
1. 11he Group confirms its position that all products should conform to the highest
relevant and scientifically supportable standards, regardless of where
MA and sold. This includes the definition and control of the additives
applied to the Product and the componeitts used in their manufacture.
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2. The Group policy requires that additives used have been subject to scrutiny and
review and therefore have a demonstrated basis of support for their use. Whilst
the ahn is uniformity of approach, difrererim in specific national legislative
requirements my pre"it world-wide consistaiuy o(brands and additive use.
3. A simple central register of all items used in the Group products and
identifiable by brand will be maintained by BATCo's Additive and Matcdals
Guidance Panel (AMGP) on a confidential basis. Initially this will be focused
on tobacco additives and their maximum potential use level in Group products
and extended as soon as practicable to cover all other components used in
product manuflicture
BAT companies witch arc selling brands under Ucence wiH be entitled to the
necessary informaiion contained within the register to ensure that the brands
they are selling comply with local regulations on additives.
No brand specific data maintained on the register will be disclosed to an
operating company without prior approval of the brand owner. The chain of
communication and appiovd process should be clearly identified in advance as
part of Group policy.
A sub-file of the Register will cover those products owned by diii d parties but
sold, distributed and/or mAnufactured by Group companies.
4. The key technical stuff of the Group will review on an on-going basis the
composition of the Register and draw attention to any inconsistencies in the
application of'Group policy.
S. Each Group Company represented at the TSG will be responsible 'or
maintaining its individual brand records on additives and components.
6. Group Companies will be responsible for ensuring that the substances used in
its products are recorded on the Central Register. Any new substance to be
introduced into commercial products must be notified the BATCo ANIGP to
ensure the register is kept up-to-date.
7. An annual report will be madc to the TSG by the Chairmati of BATCo's AXIIGP
to include:
0i a review of additive and component issues drawing attention to any
significant deviations from Group policy such that specific advice can
be given and action t nken if appropriate.
(H) the numbers and weight of substances used by Group Companies by
product chiss (cigarette, RYO, pipe and cigars).
It has bccn established that BATCF and Souza Cruz agree in principle to the
development of a central register and maximum additive use levels. The subject is
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e.r- T. SOUTHAMPTON TEL: 0703-779715 07&77,01-98 NO
currently under review within B&W who, to-dstc@ have only agretd to provide
information on the composite US industry annual retrospective lisL
G.,&. Read/ T. Cy. Mitchell
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BATCo document for Province of British Columbia 23 April 1999