The first question that my cigar clients ask: “How much is all this going to cost me?”
Unfortunately, the answer isn’t clear yet. However, I can say with some certainty that the recent article in Cigar Aficionado represents the WORST CASE scenario. In the article, industry insiders estimate the HPHC testing cost at $20,000 to $60,000 per brand, per size. So, for an entire line of a single brand with 5 sizes, they estimate $100,000 to $300,000 in testing costs.
In my experience with other tobacco products, the testing cost did not approach these astronomical numbers. While the FDA has not yet released guidance for HPHC testing for premium cigars, good news may be on the horizon. The HPHC Testing Guidance Document released in 2012 for cigarette/smokeless/roll- your-own clearly shows that the FDA is somewhat receptive to the idea that different tobacco products should be treated differently as it relates to scientific testing. For example, roll-your-own tobacco, a product that compares well to premium cigars, must be tested for a very abbreviated list of HPHCs, which drastically reduces the price for laboratory testing.
Don’t get me wrong: the testing requirements, whatever they may eventually be, is certainly going to be costly. However, as I keep repeating, it won’t be an industry-killer. Strategies like consolidated testing, HPHC estimation and planning, and industry partnership can all reduce the testing costs to manageable levels.
I’m in the process of compiling a price-list of public and private laboratories capable of HPHC testing for the premium cigar industry. So far, the numbers haven’t been jawdropping.
If you’re just diving into this and need some help, or if you’re already up to your eyeballs in compliance work, contact me as soon as possible. While there’s no need to panic just yet, you certainly need to get a compliance plan in place so you can budget and forecast accordingly.