How long is the transition period of e-cigarette Supervision: it is predicted to be 7-11 months

How long is the transition period of e-cigarette Supervision: it is predicted to be 7-11 months

Recently, the shopkeeper @ Landong, who was impressed by many e-cigarette wechat groups, said that the "sudden discovery" of the draft for comments on the national standard of e-cigarette actually stipulated the expected implementation time, "as if" it didn't happen before. It was this notice that many people did not see it, resulting in information deviation. After the official website of the state tobacco administration was released on November 30, blue hole reported this, which proved that it was not the late addition time mistakenly thought by some shopkeepers. We can't ask every shopkeeper to be very familiar with every policy and notice. In the last half month, the e-cigarette supervision has continuously issued documents. The store is mainly familiar with the policies and notices. It's a busy job, but there is still a problem in the end

Recently, the shopkeeper @ Landong, who was impressed by many e-cigarette wechat groups, said that the "sudden discovery" of the draft for comments on the national standard of e-cigarette actually stipulated the expected implementation time, "as if" it didn't happen before.

It was this notice that many people did not see it, resulting in information deviation.

After the official website of the state tobacco administration was released on November 30, blue hole reported this, which proved that it was not the late addition time mistakenly thought by some shopkeepers.

We can't ask every shopkeeper to be very familiar with every policy and notice.

In the past half a month, the e-cigarette supervision has continuously issued documents. The store is familiar with the policies and notices. It's a busy job, but in the end, there is still a state of "pulling the sword and looking at the heart at a loss".

The core of the problem is that we do not know the time when the regulatory policy will take effect. Some agents and shopkeepers panic and choose to close the store or dump goods, or no longer buy goods.

On December 2, the person in charge of relevant departments of the state tobacco monopoly administration pointed out that in order to protect the legitimate rights and interests of e-cigarette production and operation entities, better implement relevant regulatory requirements, safeguard people's health and protect the legitimate rights and interests of consumers, a certain transition period was set from the date of promulgation and implementation of the decision to the formal introduction and implementation of e-cigarette management measures and national standards for e-cigarettes.

How long is the transition period expected? This has become an issue that e-cigarette practitioners must pay attention to.

Blue Hole last predicted that the national standard of e-cigarette could take effect as early as may and as late as July. It was calculated according to the above notice, but it was found that there are more links that must be taken into account. Today, we will carefully smooth the possible timeline of supervision to facilitate everyone's planning and arrangement.

We believe that the premise of the implementation of e-cigarette supervision (the end of the transition period) is the entry into force of the national standard of e-cigarette, which can be used to infer the transition period.

This is also well founded.

According to Article 5 of the draft measures for the administration of e-cigarettes, e-cigarette products shall meet the national standards for e-cigarettes.

The following forecasts are based on the relevant requirements of the "time node" and "mandatory standard management regulations" disclosed in the existing regulatory documents

How long is the transition period: it is predicted to be 7-11 months

1. The first time node explicitly disclosed.

The period for Soliciting Opinions on the measures for the administration of electronic cigarettes is from December 2, 2021 to December 17, 2021, totaling 15 days. Because it is included in the comment period of national standard, it can be ignored temporarily.

2. Clearly disclose the second time node.

According to the above management measures, the information submission period of e-cigarette production and operation entities is: December 6, 2021 - December 21, 2021, a total of 15 days. Because it is included in the comment period of national standard, it can be ignored temporarily.

3. Clearly disclose the third time node.

The consultation period for the national standard of e-cigarettes is from November 30, 2021 to January 29, 2022, a total of two months.

According to Article 23 of the measures for the administration of mandatory national standards:

The organization drafting department shall publicly solicit opinions from the public through its own portal and the national standard information public service platform on the draft of mandatory national standards for comments, preparation instructions and the transition period.

The time limit for public consultation shall not be less than 60 days. In case of emergency, the time limit for public consultation may be shortened, but generally not less than 30 days.

Therefore, this is the basis that the consultation period of the national standard of e-cigarette is 2 months.

4. The fourth time node of the submission standard.

When the consultation period for the national standard of e-cigarettes ends, the relevant formal approval documents also have time regulations.

According to Article 29 of the administrative measures for the preparation and revision of tobacco industry standards:

For the national standards, industrial standards, corporate standards of the head office, metrological verification regulations and metrological technical specifications that have passed the technical review, the leading undertaking unit shall modify, supplement and improve the relevant contents of the standard draft for review according to the review conclusion, and generally form the standard draft for approval within one month; If it fails to pass the technical review, the leading undertaking unit shall modify and improve the relevant contents of the standard draft for review according to the review conclusion, and submit it to the Technical Committee for review again.

According to the above management measures, the draft for approval of the national standard shall be submitted within one month. We calculate the time of the solicitation end period on January 29, and form the draft for approval within one month. The latest time node is February 28, 2022. This point in time is elastic.

5. The fifth time node of authorization and approval.

After the electronic cigarette national standard is submitted for approval, if everything is OK, there are also process and time regulations.

Article 33 of the administrative measures for the formulation and revision of tobacco industry standards stipulates:

The national standards shall be reviewed by the National Bureau and submitted to the National Standardization Administration Committee for approval.

Article 38 of the measures for the administration of mandatory national standards stipulates the time for submission for approval.

The time limit for mandatory national standards to reach the submission of the draft of mandatory national standards for approval under the project plan shall generally not exceed two years, and the time limit for the competent administrative department for standardization under the State Council from receiving the draft of mandatory national standards for approval to authorizing approval and publication shall generally not exceed two months.

If it takes up to 2 months to apply for approval, combined with the fourth time node on February 28, the latest time for the release of the national standard of e-cigarette will be April 28, 2022, which is about equal to may 2022. This point in time is elastic.

The above situation is the latest situation for the release of the national standard of e-cigarettes. However, if the rapid process is used for approval, it does not take one month to form the draft for approval, for example, the winning is 15 days, and the approval time of the competent department does not need two months, for example, the winning is 1 month. In this case, the fastest time point for the release of the national standard may be March 2022.

6. Clearly disclose the sixth time node.

According to the notice of the state tobacco monopoly administration, the national standard of e-cigarette will be officially implemented within 3-5 months after its release.

If the earliest time of release is March 2022, the earliest time of formal implementation is June 2022 and the latest time is August.

If it is issued in May 2022 at the latest, the earliest time for formal implementation is August 2022 and the latest time is October 2022.

In other words, if calculated from the release of the draft of the national standard for comments, the transition period set aside by the competent authorities for practitioners is 7-11 months.

Calculation method of 7 months: from December 2021 to June 2022.

Calculation method of 11 months: from December 2021 to October 2022.

Core principle of transition period: digest the stock and do not make increment

The transition period is also a mandatory national standard, which must be reserved.

The measures for the administration of mandatory national standards stipulates that the transition period of mandatory national standards refers to the period from the publication of standards to the implementation of standards.

The reason for setting the transition period is not only to set aside time for enterprises to carry out technological transformation and smoothly transition to producing (or providing) products (or services) that meet the new standards, but also to digest the products already on the market.

Due to the great differences in technical transformation, cost input, production cycle and sales cycle involved in different products (or services), it is impossible to uniformly specify the transition period. The measures Article 21 stipulates the setting principle of the transition period, that is, when drafting the standard, it shall fully study various complex factors involved in the implementation of the standard, such as technical transformation, cost investment, withdrawal time of old products from the market and so on, and carefully put forward suggestions on the transition period. When soliciting opinions, it is required to solicit opinions on the proposed transition period together with the standards.

What is the impact of this transition period on the e-cigarette industry?

According to the notice of the competent department, during the transition period, the existing e-cigarette production and operation entities can normally carry out production and operation activities, but there are also many restrictions.

The overall production and operation principle during the transition period can be understood as: digest the stock and do not increase.

The existing e-cigarette production and operation entities can normally carry out production and operation activities.

At this stage, the competent tobacco monopoly administrative departments at all levels will not accept the application for production and retail license and product registration of e-cigarette production and operation entities for the time being;

The application for new e-cigarette retail business scope of market operators holding tobacco monopoly retail license will not be accepted temporarily (the specific acceptance time will be notified separately);

The market supervision department will not issue the business license of various e-cigarette production and operation entities according to relevant regulations;

At this stage, all kinds of investors are not allowed to invest in new e-cigarette production and operation enterprises;

The existing e-cigarette production and operation entities shall not build or expand production capacity temporarily;

No new e-cigarette retail outlets and new products on the market shall be established temporarily;

Suspend the import of new e-cigarettes.

The core point is that production enterprises do not build new production capacity, brand enterprises do not list new products, shopkeepers do not develop new retail outlets, and they are unable to issue business licenses and apply for tobacco monopoly retail licenses.

To sum up, we will give you a certain transition period to digest the inventory. If the national standard is implemented, this batch of goods will be non-conforming products and can not be circulated in the market.

After the end of the transition period, with the in-depth implementation of the policy and the full implementation of the supporting policies, the e-cigarette production and operation entities that have obtained the access license and whose products meet the national standards can carry out investment, construction, production and operation activities.

During the transition period, it is necessary to straighten out the processes of product declaration, warehousing, wholesale and retail, the R & D and launch of the national e-cigarette transaction management platform, the traceability process of compliant products of manufacturing enterprises, and prepare new products according to national standards. This will be a new world, which will be shown later.

Blue Hole suggestion: enough time to digest inventory, operate at a normal pace, and don't close the store easily

For manufacturers and brands, it is an important matter to remove inventory during the transition period. With the passage of time, the inventory pressure of such enterprises will be relatively small, but the greater pressure comes from how to obtain compliance licenses.

From the shopkeeper's point of view, according to our calculation, the transition period is 7 to 11 months. There is enough time for agents and shopkeepers to work at ease until the second quarter of next year, and there is also enough time to digest inventory, but it is not appropriate to hoard goods excessively and rush to dump goods. Don't be in serious shortage in the market at that time, but you can only stare and worry.

At the same time, don't hoard too much, just afraid to hit your hands. Purchasing according to the previous normal business rhythm is the best strategy. At this stage, the most important thing to do is to maintain the rhythm of daily operation and not open new stores, but it is necessary to keep the old stores and not close them easily.

Why is it important to keep the old store? After closing, it is forbidden to open new stores during the transition period. After the transition period, it is estimated that it will be very difficult to open new electronic cigarette stores. However, if you are an old store, the competent department may adopt human management methods, such as maintaining and respecting the status quo.

Moreover, if the store is closed now, agents and brands will be affected, and you may lose the opportunity that originally belonged to you.

Of course, based on the specific analysis of specific problems, shopkeepers can reasonably arrange their own plans according to their own conditions during the transition period.

After the approximate stage of the transition period is calculated, we can also know well and do things without panic. I hope it will be helpful to you.

The above only represents the analysis of blue hole according to the public policies and regulations, and does not represent the views of other parties. It is for your reference only. In case of any deviation, the competent department shall prevail.

A digression:

In recent days, we have received feedback from shopkeepers around the world. In some areas, shopkeepers are not allowed to sell e-cigarettes directly, or there are other excessive law enforcement behaviors.

The person in charge of relevant departments of the State Administration made it clear on December 2 that during the transition period, the existing e-cigarette production and operation entities can normally carry out production and operation activities.

We urge local competent authorities to earnestly implement and abide by the provisions of the National Bureau of Commerce, and it is not appropriate to prohibit the sale or excessive law enforcement of e-cigarette merchants within their jurisdiction at this stage.