How to prepare for the renewal of the e-cigarette manufacturer's license when it expires?

Secondly, responsibilities and division of labor should be clearly defined. Renewal of license is a systematic project, involving a large amount of data preparation and on-site verification, involving the company's finance, production, products, environmental protection, sales, personnel and other aspects, and a special team must be set up to promote it. For small companies, it is recommended that it be a "top leader" project, with the boss or general manager personally in charge. Large-scale companies can authorize a vice president with strong coordination ability to be in charge and designate a leading department. The heads of relevant departments should personally participate to ensure that the task is completed on schedule.

Thirdly, a detailed work plan should be formulated. The special task force should sort out the task list as early as possible, clarify the responsible departments and timetable, and start preparation work. Regular meetings should be held to check and supervise the implementation of tasks, coordinate and solve problems encountered, and ensure that they are advanced and completed as planned.

Submitting the renewal application on time is a prerequisite for a smooth renewal. According to the 2023 notice of the State Tobacco Monopoly Administration, the overdue submission will be "deemed as automatic waiver". Although the "Detailed Rules" did not extend this explanation, overdue submission may result in the failure to renew the license on time. The original license expires and the new license is approved. The company is not allowed to engage in e-cigarette business. Article 52 of the "Detailed Rules" stipulates that "if the applicant fails to complete the renewal (renewal) when the license expires, the original license will be invalid and the company shall no longer engage in e-cigarette related production and operation activities."

If there are any changes, a separate "change" application should be submitted, and the changes should not be included in the renewal application. Applications of different categories must be filed separately, but the Tobacco Bureau can handle them together. If you encounter policy or technical problems when filling out the application, you can consult the local Tobacco Bureau or call the unified consultation phone number: 010-68529651.

• Some necessary certificates need to be checked to see whether they are still valid and whether the registered address is consistent, including fire registration documents, pollutant discharge permits, hazardous chemical production safety licenses, highly toxic chemical storage registration certificates, brand trademark registration certificates, etc.
• Pay attention to the preparation of capacity reports. This is a new key quantitative indicator. The capacity calculation formula covers the calculation of labor productivity of key processes, equipment operation rate of key processes, plant security, raw material warehouse security, finished product warehouse security, etc., and prepare complete supporting materials, specifically in accordance with the "Requirements for On-site Verification of Production Capacity of Electronic Cigarette-related Production Enterprises" and "Notices on Application for Licenses for Electronic Cigarette Production and Operation Entities". According to Article 16 of the "Detailed Rules", the capacity utilization rate must reach more than 50% of the average capacity utilization rate of the electronic cigarette industry to meet the requirements of industrial policies.
• Reserve sufficient time for obtaining relevant test reports. According to "Electronic Cigarettes" (GB 41700), you need to provide test reports for designated items, such as "drop strength", "leakage prevention", "atomizer impurities and pollutants" tests, "atomizer impurities and pollutants", "atomizer nicotine concentration" tests, etc. The test cycle is usually 7-15 working days, and complex projects may be extended. It is recommended to start the test process 3 months in advance.

Before on-site inspection, e-cigarette companies shouldOn-site inspection items and preparation materials for the centralized renewal of e-cigarette related production enterprises in 2025Adequate preparation is required, and the materials submitted for online application must also be prepared during the on-site inspection. After receiving the notification of on-site inspection, do a good job of docking and communicate the arrangements for on-site inspection, including the participants, on-site material review and on-site inspection route, etc. On the day of the inspection, ensure that the materials are complete and in order, the personnel responsible for each task are in place, and communicate in time when encountering problems to ensure the smooth progress of the on-site inspection.

阳成勇

中国人民大学法律硕士，专注于电子烟行业合规实践，供职于电子烟行业协会会员单位广东德纳律师事务所，曾在烟草系统长期工作，兼具产研销一体化大型科技制造企业工作经历，擅长企业法务、争议解决、ESG等领域，具备经济师、人力资源管理师、注册安全工程师等资格，为多家电子烟企业提供法律合规服务。

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