The first important thing: in previous versions, there were regulations that affected liquids for
electronic cigarette, but they were removed. As a result, the draft law is focused specifically on nicotine pouches.

Next is the already familiar scenario that the market has seen with vapes: "let's ban/regulate everything as much as possible,
and then we will be surprised by the shading."

The declared goal is to protect children and young people and establish clear rules of circulation. We support marketing restrictions, but have questions about the effectiveness of individual tools.

What does VARES support? Banning advertising / promo / sponsorship for this category is a logical and justified step.

What causes doubts?
- 1 mg of nicotine per serving. People will not stop using because of a number in the law. Realistic consequences: either 5-10 servings instead of one, or increased demand for the shadow market.
- Warning 65% of the package. The question is simple: when did it really stop consumption? If it works, you need to show the data and the effect, not just the font area.
- "Notified order" of introduction into circulation. It sounds nice on paper, but in practice the key is: which body, how exactly, which by-laws and whether it will become another "admin quest" that pushes the market into the shadows.
- The transition period is 6 months. Ok. But VARES's position is that 3 months is enough, if the by-law is prepared efficiently and on time.

Conclusion of VARES:
So far, we see the risk that the bid to "ban/cut/administer" will not reduce consumption, but will fuel the black market. We are monitoring the consideration of No. 14110-d and will inform about key decisions and corrections.

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