REVENUE MEMORANDUM CIRCULAR NO. 35-2024 issued on March 6, 2024 provides the policies and guidelines for brand registration and the submission of packaging labels and product composition/formulation sheet as an additional requirement for proper tax classification
of Vapor Products pursuant to Section 4 (C) of Revenue Regulations No. 14-2022 to wit:

1. 1. 1. 1. For proper tax classification of vapor products, applications for brand registration shall be accompanied by a product composition/ formulation sheet as an additional documentary requirement indicating therein the specific type of nicotine used, i.e., nicotine salt/ salt nicotine or freebase nicotine and Affidavit duly signed by the chemist/pharmacist.
         2. The product composition/formulation sheet shall be signed by a chemist or a pharmacist with his/her license number (country where applicable) following the prescribed format in Annex “A” of the Circular.
         3. The product composition/formulation sheet shall be considered Final once submitted to Excise Large Taxpayers Regulatory Division.
         4. No revisions on the submitted packaging labels may be allowed except for the following justifiable/acceptable reasons:
            • • • Update of Graphic Health Warning (GHW) templates as required by the Department of Health; and
                • Change of registered address supported by an amended/updated BIR Certificate of Registration (BIR Form No. 2303).
         5. No withdrawal of the previously submitted packaging label and product composition/formulation sheet shall be allowed.