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DRAPT COMMENTS ON THE GULF ST11NpARD__- CIGARF.'1-TES General SASO should he asked 1.E they would cnonsid_r su!-,mitting this rc ISO/TC 126 Tobacco arnd Tobacoo Prociur.:ts for inclugican in thAi.r programme of work. Some of the confusi.on in thi s document tstPms frotu inar.iQquatc translation. Unlike the 'decree' situation in the matter of taxation, health warnings and smoke data, this don,zment may be like others somr.- times circulated by Natzonal Standard OrgRnisation5 in which the content can be changed by sensible and constructive commeni-.ing. Specif ic-Calttments i- 3 No problem hut ecsuld he improved by using ISO layout and r3afinitionA. 4 Char.acteris4 i.cs It may be possible to persuac3e them to have a gAneral $tatement on Quality si nae thcre arP .eversi statemnrits which avery respectablc manufacturer would wish to comply with anyway. Taking each poirit in turn, however: 4.1 Add the word ' ac1:i ve' in f ront of moulds. Ar2d ' ot non- plant materials' not covcrHCi under 4.23. 4.2 A more gcnera 1, statcment, P.q. 'should be frr.e trom inFestation'. 4.3 Far more definition anrd detail would bc required. Thi•i is a desirad quality tdctor by manufantUrcrs. Commnrc.ial considerai-i on9 alona would c.liminatc brands of PooY qua l i t.y . 2501077217

2. 4.4, 1 Better split into two statements: 'The burning of paper and tobacco ahall ba homngpnµvus' - a dcsi n 1imiL t' a ~on - - - g which may no t. he bcnci i c:ial to Lhe consumer. ( Retttove ~ statement?). ' Ember shall not be Pasily snparatcd from the rigarnr.•Ze duririq burning' - tatj,8 is a tlurmn i qudlity requi rpment; LOr i t to bc Rper,•ificcl would require a detdiled method. 4-S Thts is adesign limitar.i.on to the detriment of nanL- facturer nnd costsumer. 4.6 Manufacturing impossibility to guarantee width of all tobacco pieces within the cigarette. Even if it wr,:z possible, it•h would limit manufacturers ability to ituurnvn thc physic:~1 and smok,ing properties of the produc+t. 4.7 Any limitations wout_d be to the dutriment nf the consnmer anQ manufacLurer. Unrea 1 irstic dautr.tnd - f.i rlNg leve1 its dcpendent an Lobacco type. Limi.tation heyond qua.tity considerations would inhibit blend design. For quality Gonsidarations a suitable tcst method would have to be clrZrly defined. (Not aware of any suitablv+ pror.edurc:s ) . 4.9 Possible translation problem. Limitations in the use of expanded tobacco and all tobacco sheet, however, would bc detrimental to the connumer by not allowing the manu- facr•urer to improvc t.hr qualiLy and tasLe of the products. 4.10 May be a translation problem here since all manufacLurers wish to ensure product quality. However, if there is to he a limitation On gluc •free ar•cas, this could be det_rimentsl to product dPnign, i_n. Prevcntinq ventilation and coolintl. 4.11 Would suggest using the ISO standard methoa. Like many of these statements manufacturers limit end Zoss for qua 1 ity reasona. The 1 imit mcn t: i.Uned in the draf L, however, is totslly uiu•aalistic nsin=•7 tha TSO procwclitre. (58 mn be a(.-ceptablm as a limit). 2501077218

3. 4.12 Unrealistic - induxt ry uAaS papers up Lo 10t -any limiLaLion would be dr.i:rimental to the consumer and considararion of 4.4. 4-1:1 Deeign limitation against, consumers interetst ~ Marketing? 4.14 PraciaP test method would bc nccdcd since t:ab.zccA i.ndustry methods vary. If definition was 15% as 'water', this may be dc:c_eptable. Lower 1.imit of 10!~ may also be o.k. but may limiL product quality. 4.15 Providing ISO mcthod.; are used these limitations may be acc:Hfst<tble. However, we fccl it is unncccssary and it may limit product c3evelopznent. 4.16 Ditto 4.15. 4.17 Totally unrealial.ic 1«,vHl. - ncfrmttl range 1-5t. Would also rPquiro dctziZcd meLhod Lo be spccilied. 4.18 Undesirable design limitation to dat.rimenl. ol- t:hH consumer. 4.19 Limi.t set too low rot Contor1ndtic:u - batch mean of 20, say, may be accapr.ahla. 4.20 Zndividuai ciyarette weights could vmry; 15% mnrr raal.istic. Batch means oL 20 may bc ac:ccptablc. 4.21 Thifi would limit design OplionS or ciqarcttcu to the detriment of the consumAr. 4.22 Unusual statemPnt whi ch may hc a translation error. Cigarette draw rnGiAtance is an important quality charactPrintic for mannfac-t"r.er.s and the subject of an ISO stlndard. nn uppcr limiL could be set but the figures in t.he standard are Loo low Cor high quality prnducts.

9. 4.23 May be o.k. (Product Dcvclopmcnt/Markcting commcnt!). 4.24 The industry vic'N will be intcresting here. It udoes not posc a major thrcat to REL zincc we currcntly have to be care£ul in the Us and German markeLs. Gonsignment testinq could, however, be very expensive. 4.25 Impossible to meet. Naturally occurring Cadmium 0.5 - 3.5 pg/cig, 3vc~r.3gn . ahci3t' 1. Q }ig/ci g. t.PSC7 A- 23 pg/cig, average about 10 ug/cig. 4.26 Reword. The rollowing charac:Lerislics of cigareLte smrkc analysed to ISO procedures shall be; 4.26/3 O.k. (nacrwa) J f)afinttions should be ~ 4.26/2 O.k. (Decree) J clarified. 4.26/3 By moisture they must mean water (translation?). However, 0.5 mg/cig is impossible. Uh Goveriunent wuuld c:uucut' that levels up to 5.0 mg are quite normal. 4.26/4 No available ISO standard here - level too low. Could point out that HCN is found in some food stuffs as well. BurZey tobs.ccos will be hiqher than Flue Cured. , 4.26/5 There is an ISO sLandard here and suggest fiqures ara quoted in mg/cig. Limit of 15 mg/cig would be rcalistic here! 5. Would suggest that SASO consult ISO for guidance here. Consignment sampling is certainly a matter for SASO but we feel the figures in the draft standar2l necd clarifying. Since the draft standard contains a very comprehcnsive test'.tng ragima, T woulci Auggest a Sampl0 size of 1,200 from selec_ted contailiers, i.e. 400 for the 3 groups listed. 6. O.k. 7. Slight editinq perhaps. (Translation!).

8.8 1 8.9 1 Comm9nts from Marke-Fing! 9. Transportation and Storaae Totally ridiculous buL may bc duc to tranzlation. Thc:.c conditions comply to 130 3401, i.e. Standard Atmoaphcre for Tesring. TherPforP T suggest- that. thPy wish to use these c:onditiona Lot Smoke d11ci PhyyiCa1 TasLit]g Whic:h i5 very $ensibZe. $.M. Ct7MMING emc/fap 15.2.$8