Trade, Market & Financial Sector

Failure to submit notification of placing a new tobacco product on the market (Art. 155¹¹)

Is the fine charged once, or per product?

The article sets 5,000 GEL for one offence and does not itself lay down how episodes are counted. In practice, therefore, it becomes decisive how the protocol separates the episodes and how many products it names. That is the part of the file to read first.

Does the article apply to distributors and retailers?

The duty in Article 155¹¹ is placed on the manufacturer and/or importer. If you neither manufacture nor import the product, the first question is whether the protocol names the right person. That is an independent argument and it is raised within the same proceedings.

We submitted a notification, but it was treated as deficient. Is that already an offence?

The article attaches liability to failure to submit the notification in the established manner, so the file has to identify precisely which requirement was treated as unmet. A general reference to a deficiency does not answer that question. How it is assessed depends on what was submitted and when.

Does a repeat offence carry a higher fine under this article?

Article 155¹¹ provides no separate, increased amount for a repeat. It names one figure, 5,000 GEL. Any other consequence, if one exists, does not follow from this article and has to be checked on its own footing.

5 min·22 Aug 2026

What Article 155¹¹ requires

Article 155¹¹ of the Administrative Offences Code of Georgia protects a single information duty. A manufacturer and/or importer of heated tobacco or of a new tobacco product must submit, in the established manner, a notification to the Ministry of Internally Displaced Persons from the Occupied Territories, Labour, Health and Social Affairs of Georgia about the placing of that product on the Georgian market. If no notification is submitted, or it is not submitted in the established manner, that omission is what completes the offence — not the quality or the composition of the product itself.

The addressee is defined narrowly: the manufacturer and the importer. The two statuses are not mutually exclusive — the text uses "and/or" — so a company that both produces and imports can be caught in both capacities. If you are a distributor, a wholesaler or a retailer and you neither manufacture nor import the product, the first question to check is whether the protocol has been drawn up against the right person at all.

The sanction the article provides

Article 155¹¹ sets one amount: failure to submit the notification in the established manner carries a fine of 5,000 GEL. That figure is fixed. The article contains no band from a lower to an upper limit, offers no warning as an alternative to the fine, and sets no separate, higher amount for a repeated offence. Nor does it provide for confiscation of the product or for suspension of the activity. The practical conclusion is straightforward: arguing about the size of the fine leads nowhere here, and the position has to be built on whether the duty arose and whether it was performed.

What "in the established manner" means here

The article does not itself describe the form of the notification, its content, or the moment by which it must be filed. On that it points outwards to other regulation and confines itself to setting the liability. This is a detail with practical consequences. The charge is that the notification was not submitted in the established manner, so the file must show exactly which requirement was treated as unmet. Where the protocol carries only a general formulation, and does not identify what element the notification lacked or which product was left unnotified, that in itself is a circumstance to examine. What the decision must recite is not stated in Article 155¹¹; that belongs to the general part of the Code and to the facts of the particular case.

The article also names its addressee in full — the Ministry of Internally Displaced Persons from the Occupied Territories, Labour, Health and Social Affairs of Georgia — so a notification lodged with some other body does not answer the duty as Article 155¹¹ frames it. For the same textual reason the file has to show which product was placed on the Georgian market, and when: it is that event the duty attaches to.

Updated: 14 Oct 2026