Hong Kong has banned the sale of e-cigarettes and other heated tobacco products but personal use is still allowed. The ban will come into effect as soon as mid-2022, Secretary for Food and Health Sophia Chan Siu-chee said. The maximum penalty for offenders will be a HK$50,000 fine and six-month imprisonment.
Lawmakers passed the bill banning the import, sale and manufacture of electronic nicotine-delivery systems (ENDS) but some legislators say bill goes too far in targeting the business of vaping, will hurt the import sector and will deny a potential area for innovation.
The long-delayed Smoking (Public Health) (Amendment) Bill 2019 passed Thursday, “delivering a major victory for health activists and educators who have blamed the devices for encouraging smoking among young people,” according to theSouth China Morning Post.
While the new law targets only vape shops and the local business of vaping, consumers will still be free to use the devices, prompting some politicians to call for more aggressive measures to curb tobacco use, including banning smoking in all public places except for designated areas. Others, however, argued Hong Kong should allow reshipment of vaping products and warned the ban would hurt logistics companies.
The bill was approved by a vote of 32 to three in the Legislative Council. Two lawmakers abstained.
The largest political party in Hong Kong has edged its support towards a ban on all vapor and heated-tobacco products. Democratic Alliance for the Betterment and Progress (DAB) of Hong Kong lawmaker Wong Ting-kwong, chairman of the Bills Committee on Smoking, said the government has asked him to host a meeting next Friday to decide whether the government should finalize its stance on electronic nicotine-delivery systems (ENDS).
According to reports, the DAB decided to throw their support behind the motion of a complete ban on the new tobacco products in a recent meeting, according to The Standard. With DAB lawmakers making up more than half of the committee on smoking members, the legislative amendment banning ENDS products is expected to be passed in this term. The proposed bill is aimed at amending the Smoking Ordinance by targeting ENDS products was introduced in February 2019 to outlaw the importation and sales – but not consumption – of ENDS products.
Liberal Party’s Peter Shiu Ka-fai said that while 64 countries, including China, had started regulating ENDS products, authorities should handle e-cigarettes and heated-tobacco products separately, as there is currently insufficient evidence to ban heated-tobacco products. Shiu also added that it would be unfair to ban heated-tobacco products but not traditional cigarettes, given they are all tobacco products.
The proposal was among four bills that the Legislative Council of the Hong Kong Special Administration Region (LegCo), the unicameral legislature of the Hong Kong Special Administrative Region of the People’s Republic of China, stopped working on last June. Legco stated at the time that it would not ban ENDS because “the products provide smokers with safer smoke-free alternatives.”
However, after Beijing endorsed the Hong Kong government’s request to extend the Legco term by a year, a new bills committee was set up last November. It last met in June this year to discuss the bill.
According to the Food and Health Bureau, the government plans to secure passage of the bill within the current Legco term, which will end in October, The Standard reports. Sales of e-cigarettes are currently banned in 30 jurisdictions, including Macau and Singapore.
It has long been anticipated that the tobacco monopoly in China would one day regulate electronic nicotine-delivery systems (ENDS). On March 22, China’s Ministry of Industry and Information Technology (MIIT) and the State Tobacco Monopoly Administration (STMA) released a draft proposal to overhaul rules governing the ENDS market.
Shares in RLX Technology, parent to China’s market-leading RELX e-cigarette brand, plunged in the wake of the announcement. Just two months after the vapor maker’s billion-dollar debut on the New York Stock Exchange, RLX shares fell by nearly 45 percent to $10.69 per share on March 22, having reached a high of $19.46 per share on March 19.
An online copy of the “Decision on Amending the Implementation Regulations of the Tobacco Monopoly Law of the People’s Republic of China” suggests the government intends to regulate ENDS like ordinary cigarettes. That could mean special licensing requirements and much higher taxes of up to 65 percent instead of the 13 percent value-added rate companies currently pay. The ministry is seeking public comments on the draft regulations until April 22. The implications of the draft regulations could be far-reaching. With an estimated 300 million smokers, China is the world’s largest potential market for vapor products.
“In view of the homogeneity of new tobacco products such as e-cigarettes and traditional cigarettes in terms of core ingredients, product functions and consumption patterns, new tobacco products such as e-cigarettes shall be implemented in accordance with the relevant provisions of the Regulations on Cigarettes,” the draft proposal states. “The implementation … will greatly enhance the effectiveness of e-cigarette supervision, effectively regulate e-cigarette production and operation activities, solve the product quality and safety risks of e-cigarettes, false advertising and other issues, and effectively protect the legitimate rights and interests of consumers.”
While the news will have some impact on the global ENDS market, the Chinese manufacturers producing for international markets will likely continue operations. “Depending on how they regulate and to what extremes, it could be devastating to the companies operating in the consumer market in China,” said a representative of a major China-based ENDS manufacturing company, who asked for anonymity. “We expect that there will be players that remain in the market, possibly working alongside the Chinese government in the promotion and sales of vaping products. Right now, we are just waiting for a better understanding of what this means for China’s domestic market. A worst-case scenario would be an outright ban on all products, but this is unlikely.”
The draft proposal states that the regulations will have three purposes:
To promote the rule of law in the supervision of e-cigarettes;
To conform to the characteristics of e-cigarette products and current international regulatory practices;
To enhance the regulatory effectiveness of e-cigarettes.
There are 350 million smokers in China. The country consumes an estimated 1 trillion cigarettes per year. As the largest cigarette market in the world, it would make sense for China to embrace vapor products as a less risky alternative to combustible tobacco. However, with a state-run tobacco monopoly and billions of dollars of taxes at stake, industry experts say the Chinese vapor market is complicated and slow to implement regulations.
Despite impressive growth, China’s vapor market is still insignificant compared to its tobacco market. As of the end of 2019, an estimated 7.4 million people in China were regular e-cigarette users, according to Cloris Li, a spokesperson for Smoore International, parent to FEELM and the Vaporesso brand.
“That means the electronic cigarette industry in China can still potentially convert a large number of smokers,” said Li. “Considering China’s status as the biggest tobacco market, it has enormous potential to continue the current rapid growth rate. In 2018, Chinese e-cigarettes and auxiliary products had a market size of CNY5.52 billion [$848.38 million], and it is predicted to grow more than double to CNY11.28 billion by 2022.”
Vaping products in China are not considered tobacco products like they are in Europe and the United States. Instead, e-cigarettes are considered a consumer goods product. During the E-Vapor and Tobacco Law Virtual Symposium, sponsored by the law firm Keller and Heckman, two industry experts discussed the current vaping and tobacco market in China. One speaker noted that because e-cigarettes do not fall under the definition of tobacco as defined under the country’s monopoly laws, China, at the time, had yet to implement any major restrictions on vapor products.
With little regulatory guidance, China’s vapor market has been booming both in terms of domestic consumption and manufacturing exports. China, where the modern e-cigarette was invented, has become the manufacturing hub of the fast-growing global vapor industry. This has led to the rise of several major corporations, including the world’s most valuable vapor company, Smoore International.
When Smoore went public in mid-2020, its stock grew by nearly 150 percent on its opening day of trading on the Hong Kong Exchange. Smoore stock did not suffer after the MIIT announcement. The value of Chinese e-cigarette maker RLX Technology, parent to the RELX brand, jumped 146 percent during its trading debut in January 2021 after raising $1.4 billion in its U.S. initial public offering, before dropping drastically after the MIIT announcement.
In its prospectus, RLX stated that vaping products only have a 1.2 percent penetration rate in China compared with 32.4 percent in the U.S. The Electronic Cigarette Industry Committee estimated China’s 2020 e-cigarette sales at CNY14.5 billion, an increase of 30 percent from 2019 (CNY11.2 billion). By comparison, the U.S. e-cigarette market in 2019 was worth $5.34 billion and is expected to reach $6.50 billion in 2020, according to Grandview Research.
RLX is doing its part to accelerate e-cigarette sales in China. In early 2020, the company launched its two flagship RELX vape shops in Shanghai and Beijing. Today, RELX has partnered with 110 authorized distributors to supply its products to over 5,000 RELX-branded partner stores and over 100,000 other retail outlets nationwide, covering over 250 cities in China, according to its prospectus. Revenue for the company nearly doubled in the nine months ended Sept. 30, 2020, to $324 million, with a net income of $16 million.
Along with the Smoore and RLX initial public offerings, China’s vaping industry continues to attract lots of attention from the capital market, according to Li, it is unknown if the proposed regulations will hamper that attention. “This year, in 2021, many more second-tier brands are spearheading efforts to acquire financing to expand the market [in China], especially markets in lower tier cities,” Li said. “For example, MOTI intends to invest cny1 billion to open 10,000 stores. Snow Plus even announced its intent to distribute future stock shares to distributors to open more stores.”
To date, the Chinese government has passed two major pieces of legislation for vapor products. In 2018, it made it a crime to sell a vapor product to anyone under 18 years of age. In November 2019, the government prohibited online sales of vapor products to prevent youth initiation. In 2020, the country passed the Law of the People’s Republic of China on the Protection of Minors. That law is aimed at preventing parents or other guardians from “indulging or instigating minors” to smoke or vape.
The Chinese government wants to avoid the rapid rise in youth vaping that occurred in the U.S. If the U.S. figures replicated domestically in China, it could harden Beijing’s stand on the category, according to a 2021 report from ECigIntelligence. For now, e-cig usage among Chinese youth remains relatively low. A 2019 survey by the Chinese Center for Disease Control and Prevention found that 8.6 percent of high school students aged between 15 years and 18 years in China had used “tobacco” products during the previous 12 months.
Between July and August 2020, authorities collected comments on a bill that would restrict the public use of e-cigarettes nationwide and establish specific areas where vaping would be allowed. “The amendments to the Law on the Protection of Minors would prohibit vape stores from operating near schools, ban e-cigarette sales to minors and vaping in schools, kindergartens and anywhere else where young people are gathered,” the report states. “The bill would also require vendors to ask for an identification document if in doubt about a purchaser’s age while shop owners would be required to put up a prominent ‘no sales to minors’ sign. If the proposals are adopted and e-cigarettes are regulated under the same umbrella as traditional tobacco products, it would be China’s first national law specifically restricting e-cigarettes.”
In 2020, the Chinese government also floated the idea of banning vapor products completely. Another proposal suggested that e-cigarettes should be regulated as tobacco products while prohibiting their promotion as smoking cessation products. The authors of the study point out that Chinese rules can impact a market virtually overnight. Prior to the country’s ban of online sales of vapor products, there were hundreds of thousands of products available on the internet. The day after the announcement, an online search for e-cigarettes would have yielded zero results. “When the authorities do put something in writing and announce something that they want to put into effect, it can happen oftentimes almost immediately,” the report states.
While the Chinese government is yet to release any vapor regulations concerning components and manufacturing, several industry players have come together to self-regulate the industry. In 2017, draft regulation or standards were developed on the industry level. While not mandatory national standards, the rules give a good sense of what the industry considers sensible in terms of specifications, requirements and limitations.
“The same holds true with the group standards concerning the raw materials, about the diluents, the flavorings, and some requirements as it relates to physical, chemical, hazardous substances. They go into some test methods,” a presenter at the Keller and Heckman seminar said. “Not always, but typically, the authorities will look at these group standards, voluntary standards, and start to adopt some of that language when they make mandatory national standards. So, having a good sense of what these [recommended standards] look like … that would be important.”
Further complicating China’s vapor market is the China National Tobacco Company (CNTC), the state-run tobacco monopoly. If the monopoly chooses to enter the vapor market, it could devastate the independent vape shops that proliferate the Chinese market. “The state monopoly has yet to signal clearly how it will regulate e-cigarettes or whether it will sell them. If it does, it has the power to regulate its competitors out of the market,” the report states.
The industry is acutely aware of this risk. In a November 2019 interview with Reuters, one investor in a Chinese e-cigarette startup compared the combined regulatory and competitive threat posed by CNTC as “a knife on the neck.” CNTC is a source of major funding for the Chinese government. Its contribution accounted for an estimated 5.45 percent of the country’s tax revenue in 2018. That amounts to cny10.8 trillion, according to media reports.
If CNTC were to enter the vapor market, the monopoly’s existing 5 million domestic retail outlets could present a major challenge for private vape shop owners. Kate Wang, CEO for RELX, told Reuters (before the draft regulations were announced) that she’s “not worried” about the government’s impact on the sector. The products will continue to remain available, she said, “as long as there’s proof that this is a good solution for smokers.”
China’s Ministry of Industry and Information Technology (MIIT) and the State Tobacco Monopoly Administration announced today the Chinese government’s intent to overhaul rules governing the vapor and electronic nicotine-delivery systems (ENDS) market. The news started a swift downfall of shares of RLX Technology, parent to RELX, China’s largest e-cigarette brand, on the New York Stock Exchange. At 2:45pm today, RLX was down nearly 45 percent to $10.69 per share after recent high of $19.46 per share on March 19.
Draft regulations posted online by MIIT suggest it will seek to regulate these products similarly to ordinary cigarettes. The ministry is seeking public comments on the draft regulations until April 22. The implications of the draft regulations could be wide-ranging as, with an estimated 300 million smokers, China is considered the world’s largest market for tobacco product.
“In order to implement the decision-making and deployment of the CPC Central Committee and the State Council, further strengthen the supervision of new tobacco products such as e-cigarettes, and safeguard the legitimate rights and interests of consumers, we have drafted the Decision on Amending the Regulations on the Implementation of the Tobacco Monopoly Law of the People’s Republic of China,” the rule states. “The amendment is mainly to implement the requirements of the CPC Central Committee and the State Council on promoting the rule of law in the supervision of e-cigarettes , to clarify the legal basis for the supervision of new tobacco products such as e-cigarettes , and to do a good job in connecting with laws and regulations such as the Law of the People’s Republic of China on the Protection of Minors, so as to play an important role in strengthening the rule of law , stabilizing expectations and promoting the long-term.”
RLX Technology raised $1.4 billion during its initial public offering (IPO) in January this year. It sold 116.5 million shares with a target price of between US$8 and US$10 a share. Its successful market debut turned its 39-year-old founder, Wang Ying, into a billionaire overnight with an estimated net worth of $24.8 billion.
In its prospectus, RLX stated that vaping products only have a 1.2 percent penetration rate in China, compared with 32.4 percent in the U.S. According to the China-based Electronic Cigarette Industry Committee, China’s 2020 e-cigarette sales were an estimated 14.5 billion RMB yuan ($2.2 billion), an increase of 30 percent from 2019 (11.2 billion RMB yuan). According to Grandview Research, the US e-cigarette market in 2019 and was valued at $5.34 billion and is expected to reach $6.50 billion in 2020.
RELX recently announced its partnership with 110 authorized distributors to supply its products to over 5,000 RELX-branded partner stores, and over 100,000 other retail outlets nationwide, covering over 250 cities in China, according to its prospectus. Revenue for the company nearly doubled in the nine months ended September 30, 2020 to $324 million, with a net income of $16 million, the latest figures available at the time of this writing.
But tobacco companies are increasingly facing scrutiny from regulators in China. Currently, the only regulatory actions taken by Chinese authorities are in 2018, the country made it a crime to sell a vapor product to anyone under 18 years of age and then, in November 2019, an online sales ban was implemented in order to further prevent youth initiation. In 2020, the country passed the Law of the People’s Republic of China on the Protection of Minors. That law is aimed at preventing parents or other guardians from “indulging or instigating minors” to smoke or vape.
CNTC is a source of major funding for the Chinese government. Its contribution accounted for an estimated 5.45 percent of the country’s tax revenue in 2018. That amounts to 10.8 trillion yuan ($1.5 trillion), according to media reports. If CNTC were to enter the vapor market, the monopoly’s existing 5 million domestic retail outlets could present a major challenge for private vape shop owners.
Wang told Reuters in a recent news article that she’s “not worried” about the government’s impact on the sector. The products will continue to remain available, she said, “as long as there’s proof that this is a good solution for smokers.”
Chinese authorities have shut down an illicit enterprise involved in the manufacture and international distribution of counterfeit Juul products in China, Juul Labs announced in a press release. The operation resulted in the seizure of more than 110,000 counterfeit products, closure of the production facility and arrest of criminal actors behind the illicit enterprise.
Through its global enforcement operations, Juul Labs was able to identify individuals who were offering suspected counterfeit Juul products at wholesale from China. After in-depth surveillance and monitoring, the company was able to locate a clandestine factory manufacturing counterfeit Juul products for international distribution. Juul Labs then shared this information with Chinese law enforcement and supported its efforts to investigate and raid the illicit factory.
In addition to seizures of counterfeit Juul products, packaging and labeling, officials were able to retain a significant amount of documentation on businesses and individuals with purchase history, which will be used in follow-up investigations and enforcement actions. As a result of the raid, both the factory owner and manager have been arrested and will be subject to criminal prosecution.
The raided factory had thousands of counterfeit packaging for Juul products at 5.0 percent nicotine by weight in various flavors, with production runs ongoing for counterfeit Juul pods in menthol flavor. Juul Labs suspects the that the products were intended for the U.S. market. In addition, the factory appeared to have been manufacturing disposable vapor products under various brand names.
Vaping devices and e-cigarettes are included and treated the same as combustible cigarettes in accordance with Macau’s local smoking control laws, according to Macau health authorities. Vaporizers or e-cigarette devices have become growingly popular in the city, and although their use outside designated areas is not forbidden, sales of vaping products are not allowed in Macau.
The Health Bureau (SS) noted that some 2,368 smoking law infractions were recorded last year, with 21 cases referring to the use of electronic cigarettes in prohibited areas. The SS has called on the public to stay away from all tobacco products and all types of electronic cigarettes, to comply with and not violate the smoking law.
Some 92.5 percent of infractions were committed by men, with 40 percent of the total comprising of tourists. Most infractions were reported in parks/gardens and leisure areas, restaurants or commercial establishments.
Last year 409 inspections were also carried out in casinos, with 165 people indicted for smoking in prohibited places. Smoking is banned on the main floors of casinos, but is permitted in closed-off ventilated smoking areas, which are located on the casino floors. Macau is a Special Administrative Region of the People’s Republic of China.
Macau health officials have claimed that e-cigarettes are no safer than smoking traditional cigarettes.
China’s vapor market has mushroomed offline after the country banned online sales of e-cigarettes about a year ago, reports Bloomberg. Not even the coronavirus has stopped the expansion.
RELX Technology, the country’s largest player, opened more than 1,000 stores in the first half of 2020, and said in January it planned to add 10,000 outlets within the next three years. Its rival, Yooz, has also boosted the number of stores.
Shares in Smoore International Holdings, the world’s largest maker of vaping devices and components for brands, have more than quadrupled in value since the company’s July debut, making it one of Hong Kong’s best-performing initial public offerings of the year. RELX and Yooz are both clients of Smoore.
Smoore founder Chen Zhiping’s net worth has surged to $14.2 billion, according to the Bloomberg Billionaires Index.
While the coronavirus outbreak affected Smoore’s production and operations in the first quarter of the year, it still managed to post a 19 percent increase in revenue to CNY3.9 billion ($592 million) for the first six months, with more than half of its sales coming from mainland China and Hong Kong.
Smoore held one-sixth of the global market share for vaping products by revenue last year, and that pie is poised to grow further, according to Frost & Sullivan data it cited in its prospectus. The $36.7 billion global e-cigarette market will reach $111.5 billion by 2024, increasing at an annual compound rate of 25 percent, projections show.
Mounting restrictions on vapor products globally, including a ban on certain e-cigarette flavor in the world’s largest vapor market, the United States, haven’t scared off investors. Stocks linked to China’s consumer sector have been particularly popular this year as the nation has been among the first to emerge from the pandemic.
The Chinese government may tighten its grip on e-cigarettes, according to a new report from eCigIntelligence.
Legally, the China National Tobacco Co. (CTNC) has a monopoly over both combustible and vapor products, but the organization has not exercised its authority to date. According to the report, that could change in the future.
There are three possible scenarios, according to the market intelligence provider: “One possible scenario is that the government may allow private companies to continue operations but under close observation to ensure their products do not target non-smokers or minors.
“The government could also decide to crack down on the e-cig market, which as the report explains would have a significant negative impact on the growth in sales of tobacco-alternative products in the country. A third scenario would involve the China National Tobacco Company extending its existing control over traditional cigarettes to vaping products.”
Chinese authorities helped Juul Labs close down a manufacturer that allegedly counterfeited Juul brand vaping devices and sold the fake products overseas.
The operation was one of the largest ever broken up by the e-cigarette maker in its efforts to crack down on potentially dangerous counterfeit products that could make their way to underage buyers, company officials say.
According to a story in the New York Post, Shenzhen Kang Erqiang Electronic Technology Co. — which hawked bogus Juul vape devices and flavor pods under the name Sourvape Technology — sold about $324,000 worth of counterfeit items over a 16-month period starting in 2018, Juul said.
“While these are the numbers Chinese authorities used in court during prosecution, actual sales could be far more significant,” said Adrian Punderson, Juul’s vice president of brand enforcement.
The probe led to the August conviction of the Shenzhen factory’s operator, who confessed to his involvement in the scheme and was sentenced to more than three years in prison, Punderson said. Juul said it was informed of the conviction earlier this month.
The operation courted e-cigarette retailers and distributors with email blasts boasting about how perfectly it could produce Juul’s packaging, according to the startup. Juul officials learned about these emails in February 2019 and started an investigation, posing as a buyer to try and identify who was behind the scheme, the company said.
Juul reps ultimately got inside the counterfeiter’s factory in March of last year, where about 15 employees worked to churn out fake Juul products six days a week, according to the company, according to the story.
Juul said the operation was even producing pods in flavors such as mango and cucumber, which the company stopped selling in the US last year amid concerns about teens getting hooked on its e-cigarettes.
Juul passed on its findings to Chinese authorities, who launched their own probe and eventually seized 14,600 bogus items when they raided the factory in April 2019, according to Juul.
Juul says its efforts to crack down on counterfeiters have led to the seizure of more than 600,000 items worth close to $4 million over the past year. The shady manufacturers — who primarily operate in China — sell their products for as much as 65 percent below Juul’s standard wholesale price, but those products could be dangerous because they’re made in unsanitary conditions without proper testing or quality control, according to the company.
“As a leader in vapor technology, it is our obligation to support enforcement against illicit and illegal products as we strive to reset the vapor category and earn a license to operate in society,” Punderson said in a statement.
The regulatory challenges of the vapor market in the United States has not deterred a Chinese challenger from entering the world’s largest vaping market.
RELX, one of China’s largest e-cigarette companies, is seeking to submit its Premarket Tobacco Product Application to the U.S. Food and Drug Administration (FDA) by the end of 2021. Upon completion of a review process that will take no longer than 180 days, the FDA will take “action”, which could be marketing authorization, a request for more information, or denial, according to an article on techcrunch.com.
The vaping success story has requested a pre-submission meeting with the FDA and is expected to meet with the regulator in October, said Donald Graff, the two-year-old startup’s head of scientific affairs for North America, appearing in a video during a press event this week in Shenzhen.
Graff had a brief stint at Juuls Labs as its principal scientist after a 13-year streak at clinical research company Celerion where he oversaw tobacco studies. He’s now spearheading PMTA for RELX. Another scientist from Juul Labs, Xing Chengyue, who helped invent the nicotine salts critical to e-cigarettes, also joined in China’s vaping industry and founded her own startup Myst.
The PMTA is an extensive, meticulous, costly bureaucratic process for vaping products to establish that they are “appropriate for the protection of public health” before being marketed in the U.S. RELX, headquartered in the world’s e-cigarette manufacturing hub Shenzhen, has set up a team to work on the application process, including hiring third-party consulting services and clinical partners to generate data from tests that are necessary for the submission.
The high costs of PMTA keep many small players from entering the U.S., but RELX has the financial prowess to bear the expense — it estimates the entire process will cost it more than $20 million. A Nielsen survey RELX commissioned showed that the company had a nearly 70 percent share of China’s pod-style market as of April.
As the risks associated with e-cigarettes continue to draw attention from regulators around the world, Relx has ramped up its research investments to examine vaping’s impact on public health. At this week’s event, its chief executive Kate Wang, a rare female founder of a major tech company in China, and previously the general manager of Uber China, repeatedly highlighted “science” as a key focus at her startup.
Recently unveiled is the company’s Shenzhen-based bioscience lab, which is measuring the effects of RELX vapors through in vivo and in vitro tests, as well as conducting pre-clinical safety assessments.
Despite its ongoing efforts to prove the benefit of switching from smoking to vaping, RELX alongside its rivals faces regulatory uncertainties across various markets. The Trump administration banned flavored vape products last year (RELX plans to submit unflavored products for FDA review) and India banned e-cigarettes citing adverse health impacts on youth.
When asked how the startup plans to cope with changing policies, a RELX executive said at the event that “the company keeps a good relationship with regulators from various countries.”
“You can’t make conclusions on something that is still in the process,” said the executive, referring to the early stage of the vaping industry.