How to properly distinguish between vape brand owners, manufacturers, contract manufacturers, and ni

On December 2, the draft of the "E-Cigarette Management Measures" released by the State Tobacco Monopoly Administration stipulates in Article 9 that the establishment of e-cigarette production enterprises, e-cigarette contract manufacturing enterprises, e-cigarette brand holding enterprises, and nicotine production enterprises must be approved by the State Council's tobacco monopoly administrative department and obtain a tobacco monopoly production enterprise license, and be registered with the market supervision and management department.Those without a tobacco monopoly production enterprise license will not be approved for registration by the market supervision and management department.

So, how do we correctly distinguish between e-cigarette brand holders, manufacturers, contract manufacturers, and nicotine production enterprises? The draft of the "E-Cigarette Management Measures" clearly defines this in Article 44:

E-cigarette brand holding enterprises: refers to enterprises that have obtained registration for e-cigarette products but do not actually engage in production activities. E-cigarette manufacturing enterprises: refers to enterprises that have obtained registration for e-cigarette products and engage in self-production.

E-cigarette contract manufacturing enterprises: refers to enterprises that do not have registration for e-cigarette products and only process e-cigarette products on commission.

E-cigarette nicotine production enterprises: includes enterprises that produce and process nicotine for e-cigarettes and other uses.

Reviewing the major brands and enterprises currently engaged in e-cigarette products and nicotine production, please identify which belong to e-cigarette manufacturing enterprises, e-cigarette contract manufacturing enterprises, e-cigarette brand holding enterprises, and e-cigarette nicotine production enterprises.

Of course, according to the provisions of the draft of the "E-Cigarette Management Measures," the regulated e-cigarette market must establish e-cigarette manufacturing enterprises, e-cigarette contract manufacturing enterprises, e-cigarette brand holding enterprises, and e-cigarette nicotine production enterprises, provided that they obtain a tobacco monopoly production enterprise license.

Additionally, the draft of the "E-Cigarette Management Measures" also includes relevant provisions regarding "e-cigarette manufacturing enterprises, e-cigarette contract manufacturing enterprises, e-cigarette brand holding enterprises, and e-cigarette nicotine production enterprises."

• Article 10: Those engaged in the production of e-cigarette products and nicotine must obtain a tobacco monopoly production enterprise license and meet the following conditions:

1. Have sufficient funds suitable for the production of e-cigarette products or nicotine;
2. Have fixed production and operational premises, technology, and equipment necessary for the production of e-cigarette products or nicotine;
3. Comply with national e-cigarette industry policy requirements;
4. Other conditions stipulated by the State Council's tobacco monopoly administrative department.
5. E-cigarette nicotine production enterprises must also obtain relevant permits from national authorities.
6. The applicant must be responsible for the legality, authenticity, and completeness of all application materials.

• Article 11: E-cigarette manufacturing enterprises, e-cigarette contract manufacturing enterprises, and e-cigarette nicotine production enterprises must obtain approval from the State Council's tobacco monopoly administrative department for basic construction or technological transformation to expand production capacity.

• Article 12: E-cigarette manufacturing enterprises, e-cigarette contract manufacturing enterprises, e-cigarette brand holding enterprises, and e-cigarette nicotine production enterprises must apply for a change of registration with the original issuing authority if they change the scope of their tobacco monopoly production enterprise license; without approval, they cannot engage in related production and operational activities.

• Article 13: The tobacco used by e-cigarette manufacturing enterprises, e-cigarette contract manufacturing enterprises, and e-cigarette nicotine production enterprises (including reconstituted tobacco and stems, etc.) must be purchased from tobacco enterprises with the right to operate tobacco, and illegal purchases of tobacco, reconstituted tobacco, and tobacco waste are prohibited.

• Article 14: E-cigarette products must use registered trademarks.

1. The trademark labels for e-cigarette products must be printed by enterprises designated by provincial market supervision departments; non-designated enterprises are not allowed to print e-cigarette product trademark labels.

• Article 15: E-cigarette products must comply with relevant regulations on packaging labels and warnings.

• Article 16: Those engaged in e-cigarette production activities must establish a product quality assurance system and be responsible for the quality and safety of the e-cigarette products they produce or register.

1. If e-cigarette products are produced on commission, the e-cigarette brand holding enterprise must be responsible for the quality and safety of the commissioned e-cigarette products and strengthen management of the contract manufacturing enterprise's production behavior to ensure compliance with legal requirements.

• Article 17: The State Council's tobacco monopoly administrative department must establish a unified traceability system for e-cigarette products to strengthen the management of the entire process of e-cigarettes.

Note: Based on the draft of the "E-Cigarette Management Measures"