Flavors - General requirements to minimize regulatory concerns - All products
Many toxicological studies have been done to justify the flavors and use levels in manufactured cigarettes
and the results published in peer-reviewed journals. Moreover, some countries such as Germany (
https://www. tobaccocontrollaws.org/legislation/country/germany/laws)
have laws specifying flavors and other materials that that can be used in the manufacture of tobacco products. Some manufacturers
have published composite lists of the ingredients and maximum levels used in their products. The most comprehensive of these is the
one at http://www.bat-ingredients.com/. It does not cover the US,but that website covers most BAT-manufactured brands except for US
and Canada. For some markets (e.g., Germany domestic), it includes listings for cigar and pipe tobacco products. Ingredients listings
for some US cigarettes and snuff can be found at
http://www.altria.com/About-Altria/our-companies/philipmorrisusa/our-products-and-ingredients/Pages/default.aspx?src=leftnav and
https://www.rjrt.com/commercial-integrity /ingredients/ .
There is much misinformation on choice of flavorings for e-vapor products. First, certification (e.g., FEMA) of a flavor for in foods/beverages
does not mean it is okay to use in e-vapor devices. Some of those flavors increase the toxicity (particularly cytotoxicity) of the
aerosol. Second, some flavorings that may be used in conventional tobacco products should not be used in e-vapor products because
they are not completely volatile under conditions of use and the residues may create pyrolysis products that will increase the toxicity
of the aerosol. Third, uncharacterized mixtures (tobacco extracts) and flavors that are too allergenic for use in cigarettes (certain
cinnamon flavors) should not be used. Fourth, some popular flavor compounds such as vanillin and cinnamylaldehyde react with PG and
VG to form acetals that may increase aerosol toxicity. Thus, expert advice should be obtained before using flavors in e-vapor products.
Conventional Tobacco Products
E-cigarettes, E-liquids, and other novel delivery systems
The first consideration when considering a flavoring or flavoring system for a tobacco product (and e-vapor devices and e-liquids
are considerd tobacco products in the US) is toxicity. A properly designed flavoring system will not increase the toxicity of the
output of the product whether they be an aerosol as in the cases of smoking or vaping or the extractibles in the case of oral tobacco
products. The second consideration is compliance with governmental regulations on permitted flavors and/or use levels. The third consideration
is chemical stability.