November 21, 2025
Trade Letter and Compliance Opinion Regarding King Palm Cordia Leaf Products

Dear Retail and Wholesale Partners,

This letter serves as an update on behalf of Good Tree International, Inc., doing business as King Palm, regarding its cordia leaf products. Over the past several weeks, King Palm has engaged in extensive discussions with regulatory agencies and subject-matter experts. Through this process, King Palm has proactively sought and obtained confirmation that its cordia leaf products should not be characterized as either a tobacco product or a tobacco product flavor enhancer under applicable California state regulations. We received the below statement from the Deputy Attorney General of the California Department of Justice:

If the product is not “[a] product containing, made, or derived from tobacco or nicotine that is intended for human consumption, whether smoked, heated, chewed, absorbed, dissolved, inhaled, snorted, sniffed, or ingested by any other means” or an “electronic device that delivers nicotine or other vaporized liquids to the person inhaling from the device” (see Health & Saf. Code, § 104559.5, subd. (a)(17)(i)-(ii)), then it is not a “tobacco product” subject to the listing requirements of the Unflavored Tobacco List. (See also Cal. Code Regs. Tit. 11, § 945, subd. (d) [excluding separately sold accessories, components, and parts from UTL coverage].)

While the Unflavored Tobacco List will identify permissibly unflavored tobacco products, it will not identify tobacco product flavor enhancers. Determining whether a product is a prohibited flavor enhancer is a context-specific inquiry that will depend on whether the product is “designed, manufactured, produced, marketed, or sold to produce a characterizing flavor when added to a tobacco product.” (See Health & Saf. Code § 104559.5, subd. (a)(18).) Multiple state and local agencies and departments are authorized to prosecute flavor ban violations, including the California Department of Public Health (CDPH) and the California Department of Tax and Fee Administration (CDTFA). (See, e.g., Health & Saf. Code § 104559.5, subd. (a)(4).) CDTFA has provided flavor-ban enforcement information on their Tax Guide for Cigarettes and Tobacco Products and in Special Notice L965, and CDPH has provided enforcement information on their Retailer Updates page. Please also note that local agencies may adopt and enforce local flavored tobacco restrictions that are more restrictive than the state’s restrictions. (See Health & Saf. Code
§§ 104559.1, subd. (r), 104559.5, subd (i).)

King Palm and counsel had a very productive discussion with the Attorney General. The meeting resulted in our receipt of concurrence from the Attorney General that King Palm’s cordia leaf products are not tobacco products, and are therefore exempt from any reporting requirement that King Palm register such products on the Unflavored Tobacco List (“UTL”).

In addition, we received the below statement from the Department of Cannabis Control in response to our inquiry for clarity on the classification of King Palm products as "cannabis accessories”:

A product that is designed and intended to be used to roll cannabis for the purpose of human consumption would be a cannabis accessory, as defined in Health and Safety Code section 11018.2. As provided in section 15407 of the Department's regulations, licensed retailers are authorized to sell cannabis accessories. Additionally, cannabis accessories that do not contain any tobacco would not be prohibited from being sold by licensed cannabis retailers under Business and Professions Code section 26054(a)."

Combined with our takeaway from the meeting with the Attorney General, this statement affirms our corporate position that King Palm’s products are not tobacco, but rather that these products are in fact “cannabis accessories” as defined by the current California regulatory framework.

In addition, we are awaiting a formal opinion and determination by the California Department of Tax and Fee Administration and have also requested a meeting with the California Department of Public Health to obtain further guidance in connection with King Palm products, which would be beneficial to the industry overall. We plan to provide you with any additional responses or insight received from these regulatory agencies.

King Palm remains committed to supporting all of its partners and will continue seeking guidance to ensure compliance with California’s regulations. Again, in the event that you are approached by regulatory agents, we encourage you to relay that King Palm has proactively engaged with regulatory and legal experts and has obtained confirmation from regulatory agencies that its cordia leaf products should not be characterized as a tobacco product or tobacco product flavor enhancer.

If you have any questions or concerns, please contact us and we will be glad to assist you in addressing any concern.

Respectfully

Kay Shoor
CEO, King Palm
Tel: 1 424 249 2235
Email: goodtreeint@gmail.com