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APR 01 '92 15:46 INFOTAB 686 P12/21 STATE OF QATAR - LAW NO. 111992 ON CIGARET['E PRODUCT SPECIFICATIONS Indust1y Submission to H.E. Shaikh Ahmed Bin Saif a1-Thani; Actiing Minister of Health regarding the above Law on Specifications & Conditions required! in Cigarettes & Cia aarette Packets Your Excellency, We, agents and distributors for the Cigarette manufacturing companies named below, would respectfwlly, submit to you our comments, and in some cases our concerns, regarding some features of the above law -"Specifieations and conditions required in Cigarettes and Cigarette Pacltets_" For clarity we refer to each of the articles in turn. Arti;clie 3 We would respectfully ask that the aatthorisation from the Ministry of Public Health will' be given in due time so as to permit immediate importation of the cornsignrnent!_ Article 4! The figures quoted of 12 mg for tar and U.$ mg for nicotine are in line with the AGCC directive and as responsible manufacturers we shall of course comply. We fully accept: the governrnenr may at any time reconsider these figures but we mu5t point out that they are already the lowest in the worldl In fact not many other countries or regions of the world have any limit on nicotine. There a!re very good reasons why these values should not be any lower. If in the future you, contetnplate a change, we would r espectfully request that we be permitted to bring,experts to explain these reasons to you.. Article S Item 1 Our Principals will base their measurements on the internationally approved! methods as published' by the International' Standards Organisationi (ISO). We understandl tliat, it is the intentian of the AGCC to continue to adopt these International Standard's and to pLLbiislt equivalent AGCC Standards.

RPF2 01 ' 92 15: 46 IINFQ1fRB! 666' P13/21. Item 2 We ask you to reconsider this requirement. Tobacco is not like perishable foodstuffs. Its fitness for uFe Aoes not depend on its age. I ndeed, tobacco is often deliberately stored and matured' for 2-3 years before being used for cigarette manufacture, so the date of production does not reflect~ t'he age of the tobacco. The condition of the final product sold to the public depends mainly on the conditions of storage. The consumer may therefore be misled by purchasing according to the manufacturing date rather t'hann the condition of the packaging. , We are all concerned to ensure that the consumer o~nlybuys ,good qualiity, products. From our years of experience we know that the best way to, achieve this is by visual inspection before purchase. The date of manufacture: is not a reliable guide to product qpality.. Item 3 We note that this law requires us to display in Arabic the warning phrasee stipulated in paragraph (b) of article (9), of decision 1*io. (1) of 1982 by the Minister for Municipal Affairs, and we shall comply. Article 6 Our understanding from this article is t'hat all shipments arriving in~ Qatar after 20~ August 1'992 - i.e. 6 months after t'he effective date of implementation of the law, and as stated in Article 11 - shouldl comply with the specifications as indicated in this: law. Arti+cle fi We understandl the intention of'this Article. However, we draw your attention to our' comments on Article 9. Article 9 We are familiar with the Ttegional Centre for Food Contamination Monitoring at the Ministry of Public Health and acknowledge its very high standards and techniicat expertise: We assume that samples to be tested by the laboratory will be drawn according to recognised International Standards for tobacco ~ products. Saudi Arabia has adopted ISO-Standard 8243/199'1 and! produced an, equivalJent Saudi Standard with the proposal that this should be an AGCC Standard. This Standard includes t'he confidence limits which apply to cigarette testing using this sampling reginne: We respectfuldy suggest that a new sentence be added in this Article as follows `-t:igarettes for testing shall be drawn according to the method specified ini ISO : 8243/1991".

APR 01 "92 15:4? DNFOTiAB Article 10 686 P1'14i21 May we respectfillly, suggest tha the Minister of Public Health incorporates the following, International Standards into his procedures and decisions for the implelnentation of the law. iS0 8243/1991 - Samplf ng ISO 3402/1991 - Conditioning. ISO 3308/1991 - Smoking Machine equipment ISO 4387/1991 - Smoking Procedure ISO 10315/1991 - Nicotine dcterrtlination ISO1 10362/1991 - Water dertercrninationn Respectfully, cc: H.E. Minister of Economy and Commerce H.E. Nnister for Agriculture & Municipality Affairs Shaikh Abdiillah Bini Saad Bin Fahd Al': Thani~ -Director of Dept: of Standards & Metrology ALI BIN ALI & CO POBox75 Doha AL YOUSUF"I'FtADIN+G P 0 Box 330 Dohai AL,I BIN ALI & PAR7INERS' P O Box 1993 Doha MODERN HOME P' O Box 615 Doha

RPF7 @1 '92 15:47 I'NFOTRH' 686 P15/21 MERCH! TRADING EST A M ALSOWAIDI & SONS P 0 Box 5511 P' O Box 72' Doha Doha SULAIMAN ALHA:TJ HAIDER & SONS P' O Box 10 Doha I