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Product chemistry
The product chemistry should be characterised with special emphasis on the flavourings’ potential for toxic effects. |
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Pharmacokinetics
The pharmacokinetics should be characterised for different doses of nicotine and for different additives to the product that can alter the pH and the taste profile. |
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What is the absolute and relative safety of the actual product itself?
For example, effect on the oral mucosa. If the product is marketed to users of combustible forms of tobacco, it would be important to compare the product’s safety with that of cigarettes. |
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What is the acceptable maximum level of nicotine per pouch that can achieve its stated public health goal?
Since some of these products sold in certain countries had significantly higher doses of nicotine than seen with licensed medicinal NR products, there might be a need to have a limit on the nicotine dose taking into account the nicotine´s release and absorption from the product. |
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Is the communication around the use of the product appropriately understood?
For example, that the pouches should be marketed and sold for use by current or former users of more risky tobacco products for complete substitution and not used to be together for long durations. |
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Who are the intended consumers?
For example, that the pouches should be marketed solely to adult current users of more harmful products. |
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What is the likelihood of unintended use in the population?
For example, if it is used by non-tobacco users and especially taken up by nicotine-naïve adolescents? If such uptake occurs it would be important to know if it is a gateway to other tobacco use. |
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What is the transition time for current users to switch over to the product?
Understandably there may be a transition time among current users of more risky tobacco products from NP trial, to a phase of dual use (e.g. less than a year), to complete switch to pouches. That time needs to be understood, confirmed in large scale studies and communicated. |
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Do these products deter or delay intentions to completely give up tobacco and nicotine use?
It will be important to study whether the marketing, sale and use of these products undermine individual level and population level attempts to quit risky forms of tobacco. |
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Product abuse liability
Abuse liability should be studied preferably in comparison with other categories like cigarette smoking and ST. |