Although I have stated in my Warning label plan to the FDA that these will be non-removable, I am hoping consumers will be able to remove them easily after purchasing. We will of course have to move the printing position of our labels on all new cans to accommodate new warning labels in the mean time....... All packaging must have labels after August 10, 2018 and there are other labels required which no one is talking about........"Contents" and "for sale in US only"....
And there's this too:
Leaf tobacco (i.e., whole leaf or parts) that has been prepared solely by mechanical processing that involves no chemical, additive, or substance other than potable water is to be uniquely identified by providing the following information: the type (e.g., burley, bright, oriental) the variety the cure method (e.g., flue, fire, sun, steam, air) and heat source (e.g., propane,wood)a description of any recombinant DNA technology used to engineer the tobacco.We consider the cure method and curing heat source necessary to uniquely identify tobacco-derived materials because these factors change the tobacco composition by altering endogenous constituents (e.g., sugars) and, in some circumstances, adding exogenous constituents (e.g., from partially pyrolyzed organic matter), thus resulting in a distinctly different tobacco material.
Similarly, we believe that tobacco derived from recombinant DNA technology (e.g., tobacco mosaic virus RNA vector) is intrinsically distinct from unmodified tobacco and that a description of the modification and technology used is, therefore, necessary as part of the identification. FDA requests that you further identify the leaf tobacco with any internal identification number(e.g., SKU, product code) used within your company to reference the ingredient.
Tobacco that has been processed with any chemical, additive, or substance other than potable water is to be reported as described in section III.
D.3.c below. Each type of leaf tobacco used in a tobacco product is to be reported as a separate ingredient. For example, if you purchase a tobacco leaf blend or reconstituted tobacco for use in manufacturing a tobacco product, you are to report the blend or reconstituted tobacco as described in section III.
D.3.c The manufacturer responsible for assembling the blend or reconstituting the tobacco is to submit ingredient lists for its tobacco products and, in doing so, reporting
each type of leaf tobacco used in the blend as described in this section.
Under section 904(a)(1)
of the FD&C Act, you must report ingredients by quantity by brand and subbrand. Under section 904(d) and (e), FDA is required to publish a list of harmful constituents
by quantity in each tobacco product by brand and subbrand. FDA intends to rely on consistent reporting from manufacturers and importers to publish this list in a manner that is useful to the public and not misleading to laypersons. Therefore, ingredient information is to be provided using units that are consistent across all products.
In addition, the reporting of ingredient quantities is intended to provide the Agency with information to assist with implementation of other provisions of the FD&C Act(e.g., developing tobacco product standards and making substantial equivalence determinations). As such, the quantities need to be reported in consistent units across all products using an absolute measurement that is conserved during chemical reactions. FDA, therefore, interprets the term quantity to mean a unit of mass (i.e., grams with a standard International System of Units prefix as appropriate) of an ingredient contained in a tobacco product
In other words, there will be no more secret blends~!