The World Health Organisation (WHO) Framework Convention on Tobacco Control (FCTC) is an international treaty that aims to reduce the demand and supply of tobacco. It entered into force in February 2005, and as of 2023, there are 183 Parties to the treaty.¹

Article 3 of the WHO FCTC establishes that “the objective of this Convention and its protocols is to protect present and future generations from the devastating health, social, environmental and economic consequences of tobacco consumption and exposure to tobacco smoke by providing a framework for tobacco control measures to be implemented by the Parties at the national, regional and international levels in order to reduce continually and substantially the prevalence of tobacco use and exposure to tobacco smoke”.²

What is the endgame?

The tobacco ‘endgame’ is the concept of moving beyond a focus on tobacco control, towards implementing policies and strategies that could phase out tobacco products entirely.³ According to Cancer Research UK, among others, this would require systemic changes, including:

“initiatives designed to change/eliminate permanently the structural, political and social dynamics that sustain the tobacco epidemic, in order to achieve within a specific time an endpoint for the tobacco epidemic.” ⁴⁵

This could involve the reduction of prevalence of smoking to – or very close to – zero.

Policy Options

Research conducted into potential endgame strategies has identified plausible new policies for reducing smoking to minimal levels. These include:

• A tobacco-free generation policy, which precludes the sale and supply of tobacco to individuals born after a certain year⁶⁷
• A ‘sinking-lid’ strategy, which involves establishing steadily decreasing quotas on the sales or imports of tobacco products⁶⁷⁸
• Substantially reducing the number of tobacco product retailers, which could include restricting retailer density, location, type, or licensing, or restricting tobacco sales to government run outlets⁶⁷⁹¹⁰
• Mandating low-nicotine levels in tobacco products⁶¹¹
• Banning the sale of one or more tobacco products¹⁰⁶
• Shifting control of the supply and distribution of tobacco products away from tobacco companies³¹²

Implementation of endgame policies

National goals and policies

The first countries to propose tobacco endgame goals, and start developing legislation to achieve these targets, were Finland,¹³¹⁴ New Zealand,¹⁵ Ireland,¹⁶ Scotland,¹⁷ Sweden¹⁸ Canada,¹⁹²⁰ and Malaysia.²¹ Other countries that have more recently adopted endgame goals include the Netherlands,²²²³ Australia,²⁴ and the UK.²⁵ Typically, the goal is to have a smoking prevalence of less than 5% of the population.

As of 2023, the Campaign for Tobacco Free Kids (CTFK) policy database shows that 13 countries have banned the sale of waterpipe tobacco products, and 19 countries have banned the sale of smokeless tobacco products.²⁶ A review carried out in 2020 showed that 40 countries had active or pending flavoured tobacco product policies that ranged from banning flavoured tobacco, to banning flavour descriptors and images on packaging.¹⁰²⁷ No countries have yet implemented mandatory denicotinisation, substantial retailer reductions or the sinking lid strategy at a national level.

In 2010, Bhutan was the first country to ban the sale, manufacture and distribution of tobacco products.²⁸ However, the legislation was reversed in 2021 due to concerns that increased tobacco smuggling could result in cross-border transmission of COVID-19.²⁸

Subnational policies

Several US cities have also implemented endgame strategies. Brookline, Massachusetts introduced a generational tobacco ban in 2021 which prohibited the sale of tobacco products and e-cigarettes to anyone born after 1 January 2000.²⁹³⁰ Despite litigation brought by retailers in Brookline, which argued that the policy was pre-empted by state law, the Massachusetts Supreme Judicial Court upheld the generational ban in 2024.³¹ Some cities in California have prohibited the sale of tobacco and nicotine products within their jurisdictions,³² and others have restricted the number or types of retailers permitted to sell tobacco products.³³

In 2016, Balanga City in the Philippines banned the sale and use of all tobacco and nicotine products to those born after 1 January 2000. It also expanded the coverage of an existing smoking ban in the city’s University Town to cover a wider radius. However, both measures were overturned in 2018 after the tobacco industry pursued litigation.³⁴³⁵

Tobacco industry interference

As of 2023, Malaysia, New Zealand and the UK are the only countries that have announced plans to adopt a generational endgame policy. New Zealand also proposed introducing mandated denicotinisation and substantial retailer reduction.

Tobacco industry interference to prevent, delay or undermine the legislation has been observed in each of these countries, and is detailed below.

Malaysia

Proposed legislation

In 2022, Malaysia proposed the ‘Control of Tobacco Products and Smoking Bill 2022’ which aimed to phase out tobacco products and e-cigarettes by introducing a generational endgame policy, prohibiting their use and sale to everyone born on or after 1 January 2007.³⁶

However, when the latest version of the bill was tabled in 2023, the generational ban clause was omitted for all products.³⁷

Interference from industry and associated organisations

Prior to the bill being tabled, several organisations lobbied against the inclusion of e-cigarettes in the generational endgame policy.³⁸³⁹⁴⁰ One of these organisations, the Malaysian Vapers Alliance (MVA), is a member of the World Vapers’ Alliance,⁴¹ which has received funding from the Consumer Choice Center and BAT. The MVA urged the government to exclude e-cigarettes from the generational ban, and stated that it had conducted a survey of 5000 adult vape users, 96.6% of which did not agree with the ban.⁴²

When the generational endgame clause was removed from the bill, Malaysia’s former health minister stated that this was due to strong lobbying from tobacco companies.³⁷ According to local advocates the bill had seen an “unprecedented level of industry interference, some of which have been done in clear violation of the WHO Framework Convention on Tobacco Control”.⁴³

It is not clear what actions were taken by the tobacco industry to oppose the bill, however industry interference in government activities in Malaysia is high, and has continued to rise in recent years.⁴⁴⁴⁵

New Zealand

Proposed legislation

In December 2022, as part of its ‘Smokefree Aotearoa 2025 Action Plan’,⁴⁶ New Zealand passed the ‘Smokefree Environments and Regulated Products’ Amendment Act’ into law, which would have implemented several tobacco endgame policies.⁴⁷ The legislation included three key approaches: a ban on tobacco products being sold to anyone born on or after 1 January 2009, a significant reduction in the amount of nicotine permitted in tobacco products (an 0.8mg/g nicotine limit, compared to 15-16mg/g present in full strength cigarettes), and a huge reduction in the number of retailers allowed to sell tobacco products across the country (from 6000 to 600).⁴⁷⁴⁸

The legislation was due to be implemented progressively starting with the reduction in retailer numbers from July 2024, however in November 2023, as part of an agreement between parties forming a new coalition government, it was announced that all three endgame proposals would be repealed. The new finance minister stated that the additional tobacco tax revenues resulting from repealing the smokefree legislation would be used to finance tax cuts promised during the election campaign.⁴⁹⁵⁰ The repeal was later confirmed in February 2024.⁵¹ It was reported that health officials had urged the coalition government to maintain elements of the bill and suggested compromises such as introducing a purchase age of 25, however the Associate Health Minister, Casey Costello, rejected this.⁵²

In February 2024, public health experts published a briefing pointing to channels of potential tobacco industry influence on the new coalition government.⁵³ The briefing highlighted past connections between coalition politicians and tobacco companies or industry linked organisations, and noted that the arguments used by the coalition government against tobacco endgame policies aligned with those used by tobacco companies.⁵³⁵⁴ It also called for all government members to declare any past and current industry connections.⁵³⁵⁵

Interference from industry and associated organisations

In 2021, following the release of the Smokefree Aotearoa 2025 Action Plan, Imperial Brands, BAT and JTI all submitted responses to the government consultation opposing the major endgame policies.⁵⁶ Industry linked organisations and individuals also submitted responses opposing the legislation. These included submissions from Centre for Research Excellence: Indigenous Sovereignty and Smoking (COREISS),⁵⁷ which is funded by the Foundation for a Smoke Free World, and The New Zealand Initiative,⁵⁸ a think tank whose members include BAT and Imperial Brands.⁵⁹

In June 2021, BAT reportedly facilitated a protest amongst convenience store owners to contest the proposed tobacco product restrictions.⁶⁰ BAT supplied the dairy owners with postcards which opposed the measures, including the comment “If nicotine is slashed, filters banned and price goes up, many people will go to the black market – these will badly hurt my business, increase risk of robbery to personal safety and could force store to close.” Thousands of these postcards were reportedly delivered to the New Zealand Parliament.⁶⁰

In August 2023, the ‘Save our Stores’ campaign, another seemingly grassroots initiative supported by convenience store owners,⁶¹ called for users to sign a petition urging the government to repeal the latest Smokefree 2025 laws. The campaign website stated that it was “supported by” BAT New Zealand and Imperial Brands New Zealand. The campaign website argued that “A ban on normal strength cigarettes will just mean the illicit trade in tobacco products will boom and be controlled by criminal networks”. It also stated that the legislation would destroy small businesses, and that taking away the tax revenue raised by tobacco sales would “hurt families who are already struggling to make ends meet”.⁶² These narratives were repeated in a series of Facebook adverts published as part of the campaign between August and November 2023, with one advert also stating “tobacco taxes pay for 35,000 police officers”.⁶³

This kind of astroturfing is a well-documented industry tactic.

UK

Proposed legislation

In October 2023, the UK Prime Minister announced plans to introduce a generational endgame policy. The new legislation would prohibit the sale of tobacco products to anyone born after 1 January 2009. All tobacco products, cigarette papers, waterpipe tobacco and herbal smoking products were included in the proposal.²⁵⁶⁴ Later that month, the Westminster government opened a four nations consultation on the tobacco endgame policy, as well as on potential measures to curb the rise in youth e-cigarette use.⁶⁵

The consultation closed on 6 December 2023.⁶⁶ In response to the submissions, the Westminster government confirmed its plans to introduce a generational tobacco ban, ban disposable e-cigarettes and bring forward new powers which would allow the government to restrict e-cigarette flavours, packaging and retail display.⁶⁷ The Scottish and Welsh governments stated that they would also be introducing the new legislation.⁶⁸⁶⁹

Interference from industry and associated organisations

After the generational policy was announced, tobacco control researchers outlined arguments that they anticipated the industry would use to in an attempt prevent or undermine the UK legislation, based on previously used tactics. These included invoking libertarianism and arguments around personal freedom; claiming that the policy would be unworkable and impossible to police; and that it would have unintended consequences, such as increasing cigarette smuggling.⁷⁰

In December 2023, there were reports that the tobacco industry was lobbying the government to increase the age of smoking to 21, instead of introducing the new generational endgame legislation.⁷¹ An industry source quoted by The i newspaper stated that the generational ban was “unenforceable, and the inevitability of such a ban leading to a black market run by dangerous criminal gangs, there’s a large number of libertarian Tory MPs that do not like the idea the government is limiting people’s free choice…if the Prime Minister does cancel the plan, then [the industry] won’t object to him raising the smoking age to 21”.⁷¹ The illicit tobacco trade has often been used by tobacco companies to promote key misleading narratives that advance their own business goals.  See also Arguments and Language.

The i also revealed that the tobacco industry had been “inundating MPs with lobbying material in a bid to persuade them to oppose the changes”. It also reported that a letter was sent to MPs, seemingly from constituents, but in fact drafted by employees of tobacco companies, which called the generational ban “ridiculous” and “impractical, illiberal and untested”.⁷¹ Andrea Leadsom MP, Parliamentary Under Secretary of State in the Department of Health and Social Care, warned that the industry was working behind the scenes to block the policy.⁷²

Tobacco company lobbying

Tobacco companies lobbied the UK Department of Health and Social Care (DHSC) directly, using many of the same arguments, although only Philip Morris International (PMI) went as far as to issue a legal threat.

In November 2023, PMI sent a pre-action protocol (PAP) letter to the DHSC.⁷³⁷⁴ The PAP letter argued that the consultation was predetermined and that it failed to give adequate reasons regarding the inclusion of heated tobacco products (HTPs). It also argued that  the consultation period was not long enough did not allow the submission of sufficient additional evidence.⁷³ In a preliminary response (December 2023), the government stated that it was already possible for organisations to upload supporting documents, but to make this clearer, this instruction had been added to the consultation landing page.⁷⁵

The government’s full response a week later stated that the legal challenge was “misguided and wholly without merit” and would be “an unjustified attempt to delay or derail important legislative change”.⁷⁶ With regard to HTPs, it stated that some of PMI’s claims were “highly subjective and lack supporting independent evidence”. The response concluded that:

“The Government does not intend to enter into any negotiations with the tobacco industry…and will not as you propose “discuss, on an urgent basis, the potential removal of HTP from the scope of the proposed legislation”…the proposed claim has no merit and your client is urged to reconsider its intention to pursue the claim”.⁷⁶

The Telegraph newspaper reported that PMI later withdrew the threat, stating “We notified the government of procedural flaws in the consultation process. They subsequently amended the consultation procedure to allow substantive responses and answered other enquiries. As such, we withdrew the claim on 15^th January”.⁷⁴ PMI told the newspaper  that it agreed with the UK’s smoke-free 2030 plans, but did “not believe that reduced-risk smoke-free products—including heated tobacco—should be included alongside combustible cigarettes in any potential legislation”.⁷⁴ In December 2023, PMI reportedly held roundtable events with UK MPs in to lobby for its heated tobacco products (HTPs) to be exempt from future smoking bans.⁷¹

In November 2023, a law firm acting on behalf of British American Tobacco (BAT) contacted the DHSC, arguing that  the proposals would “materially impact the rights of our clients and others”. It also argued that there was not enough information “regarding the impacts and costs and benefits of the proposals to permit intelligent consideration”, and – as had PMI – stated that consultation period was not long enough, and did not allow the submission of sufficient supporting evidence.⁷⁷ BAT were reported to be sponsoring a roundtable due to be hosted by MP Graham Brady on behalf of the Centre for Policy Studies in December 2023 to “discuss the Government’s smokefree ambitions, what policies could support the goal, and what a Conservative approach to public health should look like.”⁷¹⁷⁸ BAT stated that the proposed legislation would be difficult to enforce, and risked creating a new category of “under-age adults”.⁷⁹ It also published briefing in response to the consultation, which outlined its stance on e-cigarette restrictions.⁸⁰

Imperial Brands and the Tobacco Manufacturers’ Association also reportedly engaged with MPs and government officials regarding the proposals, with a spokesperson for Imperial Brands stating “We understand the Government’s desire for new tobacco control measures, because of the health risks associated with smoking. But, like any prohibition, the proposal to ban the legal sale of cigarettes over time threatens significant unintended consequences.”⁷¹

In December 2023, Imperial also wrote to the DHSC, arguing that the consultation was “materially deficient and unfair in several important respects”. As with PMI and BAT, Imperial stated that the consultation period was not long enough, and did not allow the submission of sufficient supporting evidence. It also argued that the evidence base for the proposal should be shared.⁸¹ Imperial published a summary of its response to the government consultation. It said it opposed the generational ban, as it would be “unworkable and unenforceable, and would see an explosion of illicit trade in tobacco”. It also argued that it would not reduce smoking rates.⁸² Imperial’s UK head of corporate and legal affairs stated in the retail press in January 2024 that it was having “direct conversations with government” and talking to MPs “to make them aware of illicit trade that is already a problem in their constituencies” including highlighting “loss of revenue for the average retailer”. Imperial also stated that it did not support e-cigarette restrictions including plain packaging, device standardisation, or flavour bans.⁸³

In November 2023, Japan Tobacco International (JTI) carried out a survey of 1000 convenience retailers in the UK, and reported concerns that a smoking ban would harm business, increase illicit trade, make ID checks more complicated for retailer staff and impact staff training around underage sales.⁸⁴⁸⁵ A JTI feature in Talking Retail, ‘The Generational Ban: Explained’, described the ban as “an experimental policy not supported by evidence”, and encouraged retailers to respond to the government consultation.⁸⁶

Lobbying by industry-linked organisations

The Institute of Economic Affairs, a British think tank with a history of tobacco industry funding, published a briefing paper in November 2023 titled ‘Prohibition 2.0: Critiquing the Generational Tobacco Ban’.⁸⁷ The report echoed the industry narrative that a smoking ban would drive illicit trade and “bolster criminal gangs”. It also stated that a ban would “lead to a grey market in sales between friends” and that it “infantilises one cohort of adults, discriminates on the basis of age and raises issues of intergenerational unfairness.”⁸⁷ The report disregarded figures published in a review commissioned by the UK’s Department of Health in 2022 relating to the cost of smoking to the NHS, and stated “The reality is that smokers pay far more in tobacco duty than they cost the state in healthcare, while nonsmokers cost the state more, on average, in both healthcare and social security payments”.⁸⁷ Action on Smoking and Health (ASH) published an analysis in December 2023 which found that smoking costs England £49.2 billion each year in lost productivity and service costs, plus an additional £25.9 billion lost quality adjusted life years due to premature death from smoking – far outweighing the money brought in from tobacco taxes.⁸⁸

The Consumer Choice Center (CCC), a US lobby group with a history of tobacco industry funding and links to the Atlas Network, launched a campaign titled ‘No2Prohibition’ which urged the public to contact their MP to oppose the new legislation.⁸⁹ The campaign used the argument that the legislation would result in an increase in illicit trade and stated “Discriminating against adult consumers, depending on what year they were born, is unheard of and would set a dangerous precedent for future regulations. What’s next? Alcohol? Sugar? Fat? We can only imagine”.⁸⁹ The campaign included a series of social media adverts centred on messages of freedom of choice and prohibition.⁹⁰ These ads were removed by Meta as they did not include verified “paid for by” disclaimers.⁹⁰

Forest, a British based Smokers’ rights group with a history of tobacco industry funding, stated that it had urged the government not to introduce a generational ban, ahead of the government consultation deadline in December 2023. It also commissioned a consultancy to carry out a survey, which it states found that “58% of respondents think that if a person can vote, drive a car, buy alcohol, or possess a credit card at 18, they should also be allowed to purchase tobacco”.⁹¹

The Association of Convenience Stores (ACS) is an organisation that represents local stores in the UK. Its “Premier Club” members include BAT, JTI, PMI, Imperial Brands and JUUL.⁹² ACS stated in December that it had responded to the government consultation, and in its submission “set out a number of concerns about the practical implications of the [generational endgame] policy”. It also stated that it did not support a ban on disposable e-cigarettes.⁹³

The Scottish Grocers Federation (SGF), a trade association for convenience stores with tobacco company members, published an article opposing several possible new retail regulations, which included the generational tobacco policy and restrictions on the sale and visibility of e-cigarettes, stating that it would harm retail businesses.⁹⁴ Regarding the disposable e-cigarette ban, the SGF Chief Executive warned against “unintended consequences such as an increase in illicit trade” and said that it would “engage with both governments to ensure the best outcome for retailers and their communities”.⁹⁵ SGF also protested its exclusion from the government’s response to the consultation, due to SGF’s connections with the tobacco industry.⁹⁶

The World Vapers Alliance (WVA), which has links to BAT, criticised the generational smoking ban. It argued that the UK should instead be “doubling down on its harm reduction strategy”.⁹⁷ WVA also urged the public to respond to the government consultation to oppose e-cigarette flavour restrictions, the disposable e-cigarette ban and inclusion of heated tobacco products in the generational smoking ban.⁹⁸ After the consultation closed, WVA published a press release which urged the government to reconsider its stance on banning disposable e-cigarettes.⁹⁹

The UK Vaping Industry Association (UKVIA) published a press release opposing the e-cigarette regulations, stating “the tobacco industry and illicit markets will be the only winners from bans on disposables and flavoured vapes”.¹⁰⁰ (UKVIA stated in September 2023 that all of its tobacco company memberships had ended. For details see the UKVIA page).

Relevant Links

• Sunset Plans: Progress on Tobacco Endgame Around the World, ASH (US) website
• Tobacco endgames, ASH Scotland website

TobaccoTactics Resources

• Tobacco Industry Tactics
• Illicit tobacco trade
• Price and Tax
• Menthol and Flavoured Tobacco

Tobacco Control Research Group (TCRG) Research

Sunak’s smoke-free generation: spare a thought for the tobacco industry, G. Hartwell, A.B. Gilmore, M.C.I . van Schalkwyk, M. McKee, BMJ, 2023; 383 :p2922 doi:10.1136/bmj.p2922

References

The post Tobacco Industry Interference with Endgame Policies appeared first on TobaccoTactics.

This is illustrated by BAT’s activities in New Zealand and Australia in 2010-11.

In 2010, British American Tobacco New Zealand proposed fixed minimum tobacco prices. It made the case that this could prevent tobacco companies competing on price, and thus prevent them attracting children via cheap prices.¹⁰⁵ This was framed as a way to protect children from smoking. It was sanctioned by David Crow, then CEO of BAT Australia and a Director of BAT in New Zealand.

Corporate Social Responsibility initiatives are used by the tobacco industry to help avoid effective regulation, by proposing voluntary measures or minor policy changes.

The New Zealand parliamentary select committee rejected fixing a minimum price on the grounds that an aggressive tobacco tax regime was a more appropriate answer. Minimum prices help increase industry profits but do not increase public revenue. An effective tax regime will bring public health benefits while simultaneously benefiting public (rather than just the industry) finances.¹⁰⁶¹⁰⁷

A press conference in May 2011 confirmed that the company  was not serious about the minimum price proposal. BAT threatened to flood Australia with half-price cigarettes and make the government liable for billions of dollars in compensation if forced to remove branding from cigarette packets. The Australian Daily Telegraph quoted Crow saying:

“When you look at the four Ps (product, price, place and promotion), pricing’s the big one and that’s the only one we have left. We will end up fighting on price.”¹⁰⁸

He went on to say that the cheap prices:

“basically means more people will smoke, more kids will smoke (…) It’s going to backfire and go bad and lead to more people smoking, which is just mad if you’re sitting at a government desk”.¹⁰⁸

Australia’s Health Minister Nicola Roxon dismissed BAT’s claims as baseless, saying: “Big tobacco are fighting to protect their profits, but we are fighting to save lives.”¹⁰⁸

TobaccoTactics Resources

• Price and Tax
• Plain Packaging

For a comprehensive list of all TCRG publications, including research that evaluates the impact of public health policy, go to TCRG publications.

References

The post Pricing as a CSR Tactic appeared first on TobaccoTactics.

Since the early 2000s TTCs have developed interests in e-cigarettes (also known as electronic delivery systems, or ENDS), heated tobacco products (HTPs), snus and nicotine pouches. Companies have referred to these types of products as ‘next generation products’ (NGPs) although terminology changes over time.

• See the product terminology page for more details, including terms favoured by the industry.

All of the ‘big four’ TTCs (PMI, BAT, JTI, Imperial Brands) have invested in Swedish-style snus and related products called nicotine pouches, which they have promoted as part of their harm reduction strategies.

Background

Nicotine pouches are similar to snus pouches as they are made to be placed between the lip and gum, and do not require spitting. However, nicotine pouches do not contain fresh tobacco leaf but a form of dehydrated nicotine that does not need to be kept cold.¹¹⁴ The pouches also generally contain plant fibres, flavourings and sweeteners.¹¹⁵ Nicotine is absorbed into the bloodstream via the mucous membranes in the mouth.¹¹⁴¹¹⁵ They are not new products and similar oral pouches with contents other than nicotine have been available in Sweden for many years, regulated as food.¹¹⁵

TTCs have identified opportunities to market these products in countries where there is either an existing market for snus, or conversely in markets where tobacco snus is currently banned.¹¹⁴

Researchers have cautioned that nicotine pouches in particular may appeal to youth and non-smokers, as they are often sold in a variety of fruit flavours, in attractive packaging, and can be used discreetly (more so than e-cigarettes).¹¹⁴¹¹⁶  They can also contain high levels of nicotine where unregulated.¹¹⁶

“Tobacco Free”

It appears that some nicotine pouches, may use synthetic, or “tobacco-free”, nicotine (rather than nicotine derived from tobacco leaf),  creating confusion and uncertainty as to how best to regulate these products.^114117118119

In its 2022 annual report, BAT states that its “current portfolio contains no synthetic nicotine”.¹²⁰ PMI states that its pouches contain “nicotine derived from tobacco”.¹²¹ JTI and Imperial Brands do not refer to synthetic nicotine and describe their pouches as “tobacco-free”.^122123124125

In 2022, the UK independent scientific Committee on Toxicity (COT) noted in a discussion paper:

“the apparent variation in how manufacturers present nicotine content and strength across different products, which may be confusing for the consumer. In addition, use of the description ‘tobacco-free’ may be misleading as the nicotine may be derived from tobacco, which raises concerns regarding carry over of toxicologically relevant contaminants (e.g., metals and nitrosamines).”¹²⁶

COT also raised concerns around the lack of specific regulations for nicotine pouches in the UK, and the absence of data other than that produced by the industry.¹²⁶ COT planned to produce a full report for the UK government in autumn 2023.¹²⁶

See below for more on regulation.

Figure 1: Images of nicotine pouch brands owned by the largest tobacco companies as of 2023. (Source: TCRG. Product images from company websites)

Cigarette Companies Investing in Nicotine Pouches

The interests of the four main TTCs are summarised below, as well as those of Altria which also sells nicotine pouches outside the US. PMI was the last to acquire this product through its purchase of Swedish Match in 2022.

British American Tobacco

In 2019, BAT introduced nicotine pouches to its portfolio, marketing them as Lyft in the UK and Velo in the US.^127128129 A July 2019 news report suggested that BAT’s nicotine pouches were also on sale in Sweden, Italy and Tanzania.¹³⁰ BAT started  promoting Lyft /Velo in “emerging markets” in LMICs (see below).

In November 2020, BAT announced that it had acquired US-based nicotine pouch company Dryft Sciences, via its subsidiary Reynolds American Inc. (RAI), with the pouches to be sold under the Velo brand.¹³¹ According to BAT this would give them a combined share in the US nicotine pouches market of around 10%.¹³¹

BAT distinguished Epok, Lyft and Velo from traditional snus and allocated them to a new product category, which it called “modern oral products”.¹²⁷ In November 2019, it announced that it would consolidate its NGPs under fewer brand names, and all its “modern oral” products would be sold as Velo.¹³² It continues to market the product as Lyft in Sweden and Denmark.¹³³ It also sells nicotine pouches under its Niconovum brand Zonnic in Sweden.¹³⁴

BAT reported that it had sold 4 billion pouches worldwide in 2022, and held 69% of the market in Europe, although sales in the US had declined since 2021.¹²⁰¹³⁵ It also referred to an estimate that the global nicotine pouch market would grow by 500% by 2026, and referred to the launch of new products ranges called Velo Mini and Velo Max.¹²⁰ In 2023, BAT said that Velo was leading the market outside of the US and contributing to revenue growth.

In 2024 BAT reported that it had opened a new “innovation centre” in Southampton, UK, to focus on the development of nicotine pouches.

• For information on BAT’s other nicotine products see Newer Nicotine and Tobacco Products: British American Tobacco

Japan Tobacco International

Japan Tobacco International sells its  Nordic Spirit brand of nicotine pouches, mainly in Europe.¹³⁶¹³⁷ In its 2020 integrated report Japan Tobacco stated that the pouch was sold in nine countries, and that it held 70% of the UK market.¹³⁸¹³⁹ In 2021, it said that it “prioritized Sweden, Switzerland and the UK”.¹⁴⁰ In 2022, JTI announced that it had test-launched Nordic Spirit in the Philippines and was planning to launch a new “formula” in the UK.¹²³ In 2023, new strong and extra strong spearmint flavoured pouches went on sale in the UK, to meet the “demand for stronger variants”.¹⁴¹ According to the Nordic Spirit website its extra strong pouches contain 11mg per pouch (17mg per gram).¹⁴²

JTI also refers to its nicotine pouches as “modern oral” products.

• For information on JTI’s other nicotine products see Newer Nicotine and Tobacco Products: Japan Tobacco International

Imperial Brands

In May 2018, Imperial Brands announced that it had launched a version of its snus brand Skruf without tobacco leaf, called Skruf Super White, intended for sale in Sweden and Norway.¹⁴³ This product appears to have been rebranded as zoneX for the UK market in August 2019, however its direct sale in the UK was later discontinued.^{144145146  147} In 2022 Imperial’s website stated that in 2021, ZoneX  had “first launched in Sweden and Austria”, further launched in “Norway, Denmark and Estonia” in 2022 and finally made available in “Iceland and duty-free Middle East” in 2023.¹²⁴¹²⁵

In 2020, IMB had previously published an article on its Imperial Science website exploring what it described as “The Tobacco-Free Nicotine Pouch Opportunity”.¹⁴⁸They later said they had launched a “cutting edge bamboo fibre based product”.¹⁴⁹

Imperial’s website describes ZoneX users as:

“young adult nicotine users, typically 25+, urban and open-minded. They’re making lifestyle changes and favour a discreet way to enjoy nicotine.”¹²⁵

In 2023, Imperial acquired several nicotine pouch brands from Canadian company TJP Labs, to market in the US.¹⁵⁰

Altria

In 2019 Altria announced that it was acquiring an 80% share in oral nicotine pouch on! from Swiss tobacco company Burger Sohne.¹⁵¹¹⁵² It set up a new subsidiary Helix Innovations, through which it would manufacture and market the product.¹⁵¹¹⁵² Altria stated that, as on! was already on sale across the US before August 2016, it did not require pre-market authorisation from the US Food and Drug Administration (FDA).¹⁵¹ However, by mid-2020 it had submitted 35 Pre-Market Tobacco Product Applications (PMTA) for on!, it was sold in 40,000 US stores, and Helix was increasing manufacturing capacity.¹⁵³ According to Altria, by the end of 2020 the number of stores selling on! had nearly doubled.¹⁵⁴ A 2020 investor transcript reported that the product was “attracting female tobacco consumers due to its spitless, white and compact format” and accounted for 30% of this type of oral nicotine product.¹⁵⁵

In 2021, Altria acquired the remaining 20% of on!.¹⁵⁶ In 2022, it stated that it held over 20% of the UK nicotine pouch market, although the category was “increasingly competitive”.¹⁵⁷ It also stated that Helix operates internationally, although most of its oral products are sold in the US.¹⁵⁷ As of February 2023, the FDA had not issued marketing order decisions for any on! products.¹⁵⁷

Philip Morris International

At the beginning of 2021, PMI did not have a nicotine pouch product on the market. However, in a presentation to investors in February that year, the company noted the “attractive economics” of this small, but growing, product category.¹⁵⁸ CEO Andre Calantzopoulos said PMI was planning to develop a product through a “combination of partnerships and internal development”.¹⁵⁹

In May 2021, PMI acquired Danish snus manufacturer AG Snus, manufacturer of Shiro nicotine pouches.¹⁶⁰¹⁶¹ For more details see Cigarette Companies investing in Snus.

In July 2021, PMI announced that it had acquired Fertin Pharma, a company specialising in nicotine replacement therapy (NRT) type products.¹⁶² At this time, PMI also began referring to gums and nicotine pouches as “modern oral” products, as BAT and JTI do.¹⁶²

• For more information see: Tobacco Company Investments in Pharmaceutical & NRT Products

At this time, PMI began referring to gums and nicotine pouches as “modern oral” products (as does BAT).¹⁶²

In 2022, PMI acquired Swedish Match.¹⁶³ Swedish Match specialises in snus and nicotine pouches, and does not sell cigarettes. By 2023, Shiro nicotine pouches were presented on the PMI website, along with snus, as “oral smokeless products”.¹⁶⁴ Its nicotine pouch Zyn has been sold mainly in Sweden and some other European countries, as well as the US (since 2015).¹⁶⁵ It also sells the Volt Pearls product in Denmark, Iceland and Sweden.¹²¹

• For more information see Newer Nicotine and Tobacco Products: Philip Morris International and Swedish Match

In its 2022 annual report, PMI stated that the Zyn trademark had an “indefinite life due to the fast growth and the leading position of the brand in the market”.¹²¹

The Global Market

According to a Tobacco Reporter article published in 2024, Euromonitor International values the global market at over US$10 billion and projects it to reach US$15 billion by 2027.¹⁶⁶ Nearly 15 billion units were sold in 2023, but they remain a small part of the market.¹⁶⁶

In 2023, Euromonitor analysts noted that in the US, there were over US$8.5 billion of retail sales and nearly 3% of the population uses pouches. However, the most rapid increase in sales in 2023 was in Pakistan where BAT markets Velo (see below), and they expect most growth going forward to be in Asia Pacific and Eastern Europe.¹⁶⁶ They also noted that most pouches were sold in the US in 2023, the other top five markets (Sweden, Denmark, Pakistan and Austria) between them sold less than a third of the units sold in the US market.¹⁶⁶ Other nicotine pouch markets include UK, Germany, Poland, Czech Republic, Uzbekistan, Ukraine and Indonesia.¹⁶⁶¹⁶⁷

PMI’s purchase of Swedish Match immediately gave it a 60% share of the global market in 2022, a jump from almost zero in 2021. BAT held around a sixth of the global market, and Altria and Swisher (a US-based tobacco company which also sells cigars, snus and snuff, and other nicotine products)¹⁶⁸ each held around a twelfth share.¹⁶⁹ The global market shares of other companies, including JTI and Imperial Brands, were negligible.

• For information on TTC interests in tobacco leaf snus see Cigarette Companies Investing in Snus.

Regulation of Nicotine Pouches

Nicotine pouches are subject to a variety of regulations around the world, from outright bans to partial or selective regulation, depending on how they are defined and classified by governments. In many cases no regulation is in place. The Institute for Global Tobacco Control (IGTC) tracks and reports regulatory approaches around the world (see below).¹⁷⁰ Although not all countries contribute to its Policy Scans for nicotine pouches, the most up to date information available on the IGTC database at the time of writing is referenced below.

In the UK, as of 2023, nicotine pouches are regulated under general consumer product safety regulations, not as tobacco products. They are widely available in shops and online.^126170171 Concerns have been raised over their availability to youth, and social media marketing.^126172173 The UK Department of Health and Social Care stated that it was aware of concerns, but as the use of pouches was low (in England) it did not plan to introduce further regulation at this time.¹⁷³

European Union

While there is an EU-wide ban on tobacco snus, nicotine pouches are not covered by current tobacco product regulations. This is subject to review in the next revision of the Tobacco Products Directive.¹⁷⁴¹⁷⁵ It is however important to note that individual member countries are diverging in the way they regulate these products.

Sweden has an exemption from the EU ban on snus.¹⁷⁵ In Sweden, pouches containing products other than tobacco and nicotine have long been regulated as food items.¹¹⁵ Zonnic oral pouches (owned by RAI from 2009,¹⁷⁶ and BAT from 2017) were registered as an over-the-counter (non-prescription) drug in 2013, but only available from pharmacies and other regulated outlets.¹⁷⁷ There are a range of nicotine replacement therapies (NRT) products registered under the same brand name (see below). In 2019, the Swedish National Food Administration advised that nicotine pouches should now not be regulated as food, as they were intended to be spat out and the contents were mostly absorbed through the mouth, not the stomach.¹¹⁵

Elsewhere in Europe regulation varies widely. In France nicotine is classified as a poisonous substance, subject to regulation, but pouches can be regulated as a medicine for cessation purposes.¹⁷⁰ In Finland nicotine pouches are no longer classified as medicines, unless marketed as such.¹⁷⁸ In Norway (not in the EU but a member of the European Economic Area) a total ban on nicotine pouches and other newer products was lifted in July 2021, and replaced by a market approval scheme.¹⁷⁹¹⁸⁰ Both tobacco-derived and synthetic nicotine pouches are regulated, but advertising and sponsorship are banned.¹⁷⁰

In contrast, in March 2023, Belgium announced a total ban on nicotine pouches, by royal decree.¹⁸¹¹⁸² BAT were reported to be petitioning the courts to annul the decree.¹⁸³ The Netherlands announced a ban a month later.¹⁸⁴¹⁸⁵

In 2021, the German Office of Consumer Protection and Food Safety (BVL) stated that nicotine pouches were not regulated under either the tobacco legislation or as foodstuffs and so could not be legally sold.¹⁸⁶ BAT removed its nicotine pouches from the German market that year.¹⁸⁶ Some federal states have withdrawn pouches, and some products have been classified as a health hazard due to high levels of nicotine.¹⁷⁰

North America

In the US, nicotine pouches are regulated by the FDA and subject to age restrictions, a nicotine health warning and pre-market assessment .¹⁷⁵ There are also regulations specific to synthetic nicotine.¹⁸⁷ Nicotine pouches are freely available to consumers.¹⁶⁵ US researchers have noted a “loophole”: as nicotine pouches were not included in the smokeless tobacco regulation, companies are able to advertise nicotine pouches on radio, TV and other media.¹⁸⁸

Initially the Canadian government did not authorise the sale of nicotine pouches, and issued an alert, stating that as they had not been assessed by “safety, efficacy and quality” they might contain high levels of nicotine and be harmful to health.¹⁸⁹ These products are now regulated, either classified as a ‘Natural Health Product’ or as a prescription drug, depending on the level of nicotine.¹⁷⁰ In July 2023, Health Canada authorized the marketing of BAT’s Zonnic nicotine pouch (with 4mg of nicotine) as a natural health product.^190191192193 Physicians for a Smoke-Free Canada reported that this product contains the same ingredients as BAT’s Velo,¹⁹² and noted that:

“BAT will face very few restrictions on how it can market ZONNIC nicotine pouches in Canada, other than with respect to how it represents the therapeutic benefits of the product.”¹⁹²

Australia & New Zealand

As with e-cigarettes and heated tobacco products, nicotine pouches are banned from sale in Australia, and only available on prescription.¹⁷⁰

In New Zealand, oral tobacco products (including snus) and nicotine pouches are banned, unless approved as medicines.¹⁷⁰ (E-cigarettes are regulated, but not banned)

New and emerging markets

In some low and middle-income countries, including Argentina, Bangladesh, Georgia, Indonesia, India, and Nigeria, only tobacco-derived products are regulated as tobacco products, but not those derived from synthetic nicotine.¹⁷⁰ In others, including Brazil, Brunei Darussalam, Iran, and Thailand, both are regulated as tobacco products.¹⁷⁰ In Ukraine there are no specific regulations in place, but synthetic nicotine pouches are regulated as a food product.¹⁷⁰ Mauritius bans both,¹⁷⁰ whereas in Uruguay, nicotine pouches are categorised as a form of nicotine replacement therapy (see below).¹⁷⁰

At the time of writing, July 2023, nicotine pouches remain unregulated in most countries.¹⁷⁰

As researchers from Norway, among others, have pointed out:

“The boundaries between various tobacco and nicotine products are getting less clear, making it possible for the tobacco and nicotine industries to take advantage of the discrepancies in regulation.”¹¹⁶

• The Policy Scan Project, by the Institute for Global Tobacco Control (at Johns Hopkins University), which tracks and reports regulatory approaches to nicotine pouches around the world.
• For information on tobacco regulation more broadly, see the Tobacco Control Laws website, published by the Campaign for Tobacco Free Kids (CTFK).
• For countries that are parties to the WHO Framework Convention on Tobacco Control (FCTC) progress towards implementation of relevant articles, including newer products, is detailed in the FCTC implementation database.¹⁹⁴

BAT Promoting Nicotine Pouches in LMICs

BAT began marketing Lyft in Kenya in 2019, and Pakistan in 2020. In 2021, BAT said that it was also test marketing its product in Bangladesh and Indonesia.¹⁹⁵ and “consumers are familiar with other similar oral products”.¹⁹⁶ The company has identified an opportunity to market these products in countries where electronic devices are less popular, affordable, or available due to regulatory restrictions. It also referred to markets where there is was a “pre-existing ritual of oral product consumption”.¹⁹⁵¹⁹⁶

Kenya

After announcing its intention to sell nicotine pouches in Kenya, BAT launched Lyft in the country in December 2019.^130197198 In February 2020, the company announced that it was planning to build a new factory in Nairobi to produce nicotine pouches, and for Kenya to become a regional export hub for the product.¹⁹⁹ BAT Kenya (BATK) managing director, Beverley Spencer-Obatoyinbo said that “Given the high incidence of oral stimulant use among smokers, we believe that this new product category will provide a viable alternative to smoking”, although she presented no evidence at the time to support this statement.¹⁹⁹

In response to concerns about the potential impact on tobacco farmers, Business Daily Africa reported that BATK’s head of legal and external affairs stated that the company was “using proceeds from the tobacco portfolio to invest in the new categories. When the time comes, we will help them (farmers) transition to sustainable crops,” although this was “not a change that can happen overnight”.²⁰⁰ Spencer-Obatyoinbo confirmed that BAT switching to “non-combustibles” was “not an immediate thing”.²⁰⁰ Nevertheless, in September 2020, BAT was reported to be lobbying the Kenyan Revenue Authority (KRA) for a tax break for the product, citing its large investment and potential exports.²⁰¹ (According to BAT the nicotine for its pouches is currently manufactured in Switzerland.)²⁰¹ The Chief Executive of the International Institute for Legislative Affairs argued that this would be a “huge setback for tobacco control interventions in Kenya”.²⁰² For more information see the Kenya country profile page.

Nicotine pouches were initially registered as a pharmaceutical product by the Kenya poisons board.²⁰³ This designation was challenged by local advocates.²⁰³ Health Cabinet Secretary Mutahi Kagwe wrote to the poisons board, arguing that the product had been wrongly designated, and stated that it was being distributed via vending machines in contravention of the law.²⁰³²⁰⁴ Although Lyft was de-registered and effectively banned, there was a reported lack of enforcement and the product was found to still be on sale in December 2020.²⁰⁴²⁰⁵ In February 2021, the Kenyan government said that it was intending to classify nicotine pouches as a tobacco product under the Tobacco Control Act, making the product subject to similar marketing restrictions as cigarettes and other tobacco products.²⁰⁴ Concerns have been raised in Kenya over potential use by children (see below).

In February 2021, BAT told investors that “In Kenya, we have temporarily suspended sales due to local regulatory challenges and continue to engage with the local authorities.”¹⁹⁵ In March it told the Kenyan media that it was planning to spend Kenya Sh1 billion (US $10 million) on marketing Lyft once the product was approved.²⁰⁶ This included plans to set up distribution networks across 21 countries in the Common Market for Eastern and Southern Africa (COMESA).²⁰⁶

In 2022, BAT’s nicotine pouch was back on the market in Kenya, as Velo.²⁰⁷ In its annual report, BAT stated it had “reintroduced Velo to a limited retail universe with positive early momentum, as we focus on driving guided trial.”¹²⁰

The introduction of Velo has not been without controversy, and politicians in Kenya are again asking for the product to be banned. Letters between BAT and the Kenyan Ministry of Health reveal that BAT had lobbied to reduce the size of warning labels on the product.²⁰⁸

BAT has also lobbied against increased taxes on these products.^209210211

Pakistan

Velo was launched by BAT in Pakistan in December 2019, with a campaign run by Ogilvy Pakistan “positioned towards affluent adult consumers”.^212213214

A Freedom of Information Request submitted by Bath TCRG revealed that UK High Commission staff in Pakistan had attended a “social event” for Velo in February 2020. The FOI stated that “They were invited by the event coordinator and did not meet any Velo representatives at the event.”²¹⁵

• British diplomats have previously been associated with lobbying by BAT in Pakistan, and other LMICs. See the page on UK Diplomats Lobbying on Behalf of BAT

BAT said it was “particularly proud of Velo’s performance in Pakistan”. ¹³⁵ In its 2022 annual report, BAT stated that Pakistan was its third largest market for nicotine pouches. It said that the market was “enabled by powerful, consumer-centric digital activations”, and that it was selling over 40 million units a month.¹²⁰ These sales figures, and rapid growth, are roughly consistent with Euromonitor’s estimates.¹⁶⁹

South Africa

Unlike NRT products, nicotine pouches are not on the South African Health Products Regulatory Authority’s list of approved medicines, for which it would be subject to clinical trials and regular monitoring updates. Nicotine pouches are also not regulated as tobacco products because the nicotine is synthetic and does not fall under the definition of tobacco products in the Tobacco Products Control Act (2018). This means that they can be sold without health warnings and can be sold to those under the age of 18.²¹⁶

South Africa is also one of the target markets for PMI’s ZYN nicotine pouches. ²¹⁷

Indonesia

In February 2021, BAT referred to the test marketing of its nicotine pouches in Indonesia.  BAT reported “encouraging results”.¹⁹⁵ External statistics suggest the market remained small.¹⁶⁹

Concerns Around Use by Youth

Researchers in the US have identified the risk of nicotine pouches appealing to non-smokers and in particular youth, as some products come in a range of fruit flavours and are more discreet than e-cigarettes.¹¹⁴²¹⁸ As of 2024, PMI was facing a lawsuit for ZYN in the US on the basis of the product being addictive and harmful to young people. The lawsuit states that PMI is benefiting from the promotion of the brand on social media. ²¹⁹The FDA has also issued warning letters and penalty charges to a number of retailers for the underage sale of flavoured ZYN nicotine pouches. As of April 2024, the FDA has not authorised the sale of ZYN products in the United States. ²²⁰²²¹

Although they can only legally be sold to adults in the UK, concerns have been raised over potential use by children.¹²⁶²²²

In 2020, there were reports that Lyft was being used by children in Kenya.¹⁹⁹²²³ Children were also reported to be using the products in schools in Scotland.²²⁴

In February 2021, journalists from the Bureau of Investigative Journalism published an article describing how BAT used social media influencers to promote its nicotine pouches in multiple countries, including Australia, Kenya and Pakistan. The authors argued that this was part of a campaign targeted at young people, rather than older adults trying to quit smoking.^225226227

An investigation by The Guardian newspaper in 2023 identified further promotion in the UK via social media and music events, as well as prize draws and the provision of free samples.¹⁷³

BAT also promotes Velo through motorsport sponsorship.²²⁸²²⁹

• See Snus: Marketing to Youth for information on earlier tobacco company marketing of the tobacco leaf product.

Industry Alliance Lobbying in the EU

The ‘Nordic Nicotine Pouches Alliance’ (NNPA) was established in Belgium in 2020.²³⁰ As of March 2024, BAT and JTI are the only partners listed on the NNPA website.²³⁰

The NNPA webpage states “We engage, inform, and increase knowledge about nicotine pouches”.²³¹  However, on the EU transparency register, its stated goal is to “focus on regulation concerning nicotine pouches within the European Union”, specifically the Tobacco Products Directive and the Tobacco Taxation Directive.²³²²³³ Jonas Lundqvist, NNPA CEO, is listed as the accredited lobbyist on the EU register.^234232233 In 2022, the estimated cost of NNPA lobbying activities was listed as €400,000-499, 999, four times the amount listed in 2021.²³²²³³

NNPA also runs the online news platform ‘Pouchforum’.²³⁵ Articles published on the platform have accused the European Commission of misrepresenting the risk of nicotine pouches,²³⁶ and suggested that the Commission does not act in a transparent manner.²³⁷ The site editor is Robert Casinge, also ‘Senior Partner’ in the NNPA, and previously listed as a lobbyist on the EU register.²³³²³⁸

Framing Nicotine Pouches as NRT

TTCs appear to be framing their nicotine pouches as a nicotine replacement therapy (NRT), which is designed to help smokers quit.^239240241 However, they are also marketing them as consumer products, including for use when it is not possible to smoke or use e-cigarettes, for example on a plane. ^242243244

In 2016, researchers in the US pointed to the implications for both product regulation and smoking cessation,¹⁷⁶ and the:

“blurring of the lines between cessation products and novel tobacco products and potentially confusion and misuse by consumers which may result in initiation or situational and dual use of tobacco products.”¹⁷⁶

All four of the main transnational tobacco companies have conducted their own research on nicotine pouches, published on their science websites.

BAT markets Niconovum NRT products, in the US and Sweden under the brand name Zonnic; in Sweden, Zonnic products include nicotine pouches.^134245246 In 2020, BAT also rebranded its Revel nicotine lozenge as Velo – the same brand as its nicotine pouch – in the US (and submitted it for pre-market approval). ²⁴⁷²⁴⁸

In its 2022 annual report, BAT stated that “[t]he weight of evidence suggest Modern Oral nicotine pouches have a profile that is comparable to nicotine replacement therapy products”. It cited BAT’s 2021 research on Velo, which compared snus, nicotine pouches and NRTs.¹²⁰²⁴⁹ However, the 2022 report then went on to acknowledge “low levels of average daily consumption and high poly-usage”, leading BAT to submit a further PMTA for a “superior” product.¹²⁰ As of February 2023, no Velo products had received pre-market approval in the US.¹²⁰ At the time of writing, it was not yet clear how BAT planned to promote its Zonnic nicotine pouch after it was approved for sale over-the-counter in Canada in July 2023.^190191193

BAT’s science website presents its research on nicotine pouches, as well as a summary of the ‘Snus and the Swedish Experience’.²⁵⁰ For more background on this topic see The Swedish Experience.

PMI acquired Fertin Pharma in 2021, stating that Fertin was a “leading producer of Nicotine Replacement Therapy (NRT) solutions”.¹⁶² PMI has also referred to the “medical” or “pharmaceutical” grade nicotine in its products.¹²¹²⁵¹ (Read more about on PMI’s acquisition of pharmaceutical companies.)

PMI’s science website presents its research on nicotine pouches.²⁵¹ It does not refer to its snus products on these pages.^251252253

Imperial Brand’s science website has cited evidence on tobacco-leaf snus and other next generation products (NGP)s to support its statement that “these products are more satisfying – and acceptable – to adult smokers than traditional nicotine replacement products (NRTs) like patches, lozenges, and gums”.¹⁴⁸  However, the evidence it cites pre-dates the widespread sale of nicotine pouches by TTCs: the 2016 report from the Royal College of Physicians (RCP) refers only to Zonnic and does not discuss satisfaction of acceptability of the product.²⁴¹

Imperial refers to its use of “high purity pharmaceutical grade nicotine”.¹⁴⁸²⁵⁴ In May 2021, Imperial published its “comprehensive scientific assessment” of its nicotine pouches, in comparison to cigarettes.²⁵⁵

Japan Tobacco‘s science website does not feature nicotine pouches, although it includes  its research on these products.²⁵⁶

Environmental Impact

The impact of cigarette filters on the environment is well documented. More recently, the impact of single use, or ‘disposable’, e-cigarettes has been highlighted

As the nicotine pouch market grows the disposal of these single use products is an emerging concern.²⁵⁷²⁵⁸

On its website, BAT states that the Velo plastic cans are being upgraded to use single polymer plastics in order to “align with the group’s ESG ambitions”. ²⁵⁹

TobaccoTactics Resources

• Snus
• Cigarette Companies Investing in Snus
• Newer Nicotine and Tobacco Products
• Harm Reduction

TCRG Research

• S. Peeters, A. Gilmore, Understanding the emergence of the tobacco industry’s use of the term tobacco harm reduction in order to inform public health policy, Tobacco Control, 2015,24(2):182-189

For a comprehensive list of all TCRG publications, including TCRG research that evaluates the impact of public health policy, go to the Bath TCRG’s list of publications.

References

The post Nicotine Pouches appeared first on TobaccoTactics.

Factasia.org is a Hong Kong based organization, founded in 2013, which promotes newer nicotine and tobacco products, including e-cigarettes (also known as electronic nicotine delivery systems, or ENDS) and heated tobacco products, and campaigns for their use in tobacco harm reduction. It is registered as a company, Fact Asia Consultants Ltd, in Hong Kong.²⁶⁶²⁶⁷

As of October 2020, Factasia´s website stated:

“factasia.org seeks to represent the rights of adults in Asia who choose to enjoy smoking or other related forms of consumption of nicotine. factasia.org aims to protect their interests and to provide independent and unbiased data on the issues surrounding smoking – and related issues – in Asia.” ²⁶⁸

According to the tobacco industry publication Tobacco Reporter, Factasia.org was formed to represent the rights and interests of smokers who choose to smoke or consume tobacco, and to provide data on the issues surrounding smoking in Asia.²⁶⁹

Factasia.org receives funding from Philip Morris International, as well as the Tobacco Vapor Electronic Cigarette Association (TVECA) and other companies providing services to the tobacco industry, according to its website.²⁷⁰

However, Factasia.org states that it does not work for the tobacco industry. ²⁶⁹

Activities

Factasia.org conducts its activities under three main themes that it describes as: “consumer choice, rational debate and sensible regulation”.²⁶⁸ It states that “Factasia.org aims to communicate with consumers as well as politicians, legislators and appropriate law enforcement officials”.²⁶⁸ According to Tobacco Reporter, Factasia “aims to lobby on behalf of the millions of growers, distributors and retailers throughout the region whose livelihoods are under threat from bad legislation and excessive taxation” ²⁶⁹

Commissioned Surveys to Argue for Reduced Regulation

The organisation conducted several opinion surveys of smokers in Asia-Pacific markets through the polling company IPSOS. One survey conducted in 2015-2016 included responses from nine countries (Mecau, India, Malaysia, Singapore, Australia, Hong Kong, Taiwan, Philippines, and New Zealand) and over 4,200 smokers.²⁷¹ This survey evaluated awareness, use and perception towards e-cigarettes. A similar survey was conducted in Hong Kong in 2018 with 1,000 respondents.²⁷² Results of these surveys were presented in global pro-vaping conferences and used to develop support for reduced regulations and restrictions on e-cigarettes.²⁷³

In 2015, Factasia.org held an E-cigarette Symposium with speakers from the Institute of Economic Affairs (IEA). ²⁷⁴

Lobbied at COP8

Factasia has lobbied against the Conference of the Parties (COP) of WHO FCTC. Heneage Mitchell, cofounder and director of Factasia.org, was among the group who protested outside COP8 in Geneva in 2018, arguing that the WHO should accept harm reduction as a “basic human right” (Image 1).²⁷⁵²⁷⁶

Heneage Mitchell was present with Martin Cullip, a pro-tobacco blogger and Simon Clark, the Director of the tobacco industry front group Forest at a COP8 side event, hosted by the tobacco industry-funded, representing the Institute of Economic Affairs. The International Network of Nicotine Consumer Organisations (INNCO) was also present, after being denied FCTC observer status. For more information see the page on INNCO.

Image 1.”Heneage Mitchell from Factasia (second from left) was part of a group protesting outside FCTC COP8 event in Geneva, 2018 (Source factasia.org)

Lobbied COP8 via Twitter

Researchers from the Tobacco Control Research Group (TCRG) analysed Twitter data to gain insights into activity of the tobacco industry and its allies, including Factasia.org, in the run up to COP8, and their attempts to influence the FCTC.²⁷⁷²⁷⁸

The researchers concluded that:

“The extensive activity by NGP advocates with links to organisations funded directly and indirectly by PMI … as well as a substantial online presence by PMI executives themselves, suggests a strategic approach by PMI to influence COP8 debates”.²⁷⁷.

For more details see International Network of Nicotine Consumer Organisations (INNCO)

Factasia.org is a supporter of the “Smoke Free for Life” (SF4L) campaign, organised by Coalition of Asia Pacific Tobacco Harm Reduction Advocates (CAPHRA).See below for details.²⁷⁹²⁸⁰

Relationship with the tobacco industry

According to Factasia.org’s website, Philip Morris International and Tobacco Vapor Electronic Cigarette Association (TVECA),  an e-cigarette trade association, are among its supporters.²⁷⁰

Other supporters listed on their website, as of October 2020, were are:²⁷⁰

• Axiom Select LLC – Service provider to tobacco industry from machinery to services which include “regulatory issues, product development, harm reduction, cost / project management and sourcing.”.²⁷⁰²⁸¹
• Cerulean – Provider of test and measuring equipment for the tobacco industry. As a provider, it has presented at several tobacco industry events as the Global Tobacco & Nicotine Forum, World Tobacco Middle East, Tobacco Science Research Conference, among others. ²⁸²
• Moisttech – Provider of moister & measurement control products, that provides services to the tobacco industry.
• Primary Engineering (Thailand) Ltd – Provide service & maintenance for tobacco industry equipment

As stated on the Factasia.org website, its cofounder and director Heneage Mitchell has commentated on the tobacco industry across the Asia region for over 15 years.²⁸³ His LinkedIn profile states, he was the former managing editor/co-publisher at October Multimedia from 2009-2013 and managing editor of Lockwood Publications from 2002 –2009. ²⁸⁴  Lockwood publications was the publisher of industry publication Tobacco Asia.²⁸⁵.

John Boley, the other cofounder of Factasia.org was a speaker at the Global Forum on Nicotine (GFN) in 2016 and 2017. GFN is an event organised by Knowledge-Action-Change (K-A-C) which is funded by PMI-funded Foundation for a Smoke-Free World.

The panel of speakers at the Factasia.org E-cigarette Symposium 2015 included;  e-cigarette researcher Dr. Konstantinos Farsalinos, representatives of TVECA and the Asian Vape Association (AVA), and Terry Barnes representing Institute of Economic Affairs(IEA) (see image 2) ²⁶⁸. The IEA is a think tank which has a history of collaboration with the tobacco industry.²⁸⁶

Image 2: Factasia.org E-cigarette symposium held in Hong Kong in 2015. From Left: Ray Story (TVECA), John Boley, Dr. Konstantinos Farsalinos, Heneage Mitchelle , Nav Lalji (AVA) (Source: Factasia)

Staff

Heneage (‘H’) Mitchell and John Boley, are both founders and directors of the organisation.^{284 287}

According to his LinkedIn profile, Mitchell became Managing Director of factasia.org in October 2013, after working in journalism, publishing and other businesses, including writing on tobacco (see above for details). ²⁸⁴ He states that his specialities include public relations and campaign management.²⁸⁴ and in 2017.²⁸⁸ His presentation in 2016 was titled “Developing a united front for consumers to public health authorities in Asia-Pacific – challenges and opportunities” and, in 2017, “The lexicography of harm reduction”.²⁸⁹

Lobbying decision-makers

Collaborating with third party organizations and funding their activities in order to reach out to decision makers is one of the most common tobacco industry tactics.(See Third Party Techniques) Factasia has not been the exception, as evidenced in the promotion of  looser regulations for newer products in Australia:

Lobbied Therapeutic Goods Administration (TGA)

Regarding PMI´s IQOS, Factasia made a submission in June 2020, after the Australian medicines regulator, the TGA, made an interim decision refusing Philip Morris Ltd application to exempt its IQOS product from the Poison’s Schedule. Factasia´s submission argued that “It is unconscionable that Australia continues to ignore the evidence and is now seeking to further restrict access by adult smokers to these life-saving technologies by considering legislation to require a doctor’s prescription to purchase nicotine-containing vape products.” ²⁹⁰ Despite intense lobbying by PMI to allow the sale of IQOS, in August 2020, the Australian government’s Therapeutic Goods Administration rejected the sale of HTPs in Australia.²⁹¹²⁹².

Lobbied Australian parliament:

After lobbying with CAPHRA for fewer restrictions on e-cigarettes in Australia, in summer 2020,²⁹³   Factasia made a formal submission to the Australian Parliament on October 16, 2020, arguing that “The government has a unique opportunity to act for the good of its citizens by recognizing that harm reduced nicotine products save lives and benefit all Australian citizens by reducing the death and disease caused by smoking. Smokers need to be able to access the life-saving technology of harm reduced nicotine products. This should be a key part of Australia’s Tobacco Control policy”.  ²⁹⁴ Furthermore, Factasia lobbied for newer products to be legalized in Australia and regulated differently than tobacco products. ²⁹⁴

Partnerships

Factasia.org is associated with the Coalition of Asia Pacific Tobacco Harm Reduction Advocates (CAPHRA)²⁹³  and supports its SF4L campaign.²⁷⁹ Heneage Mitchel was at the launch of SF4L, along with Peter Paul Dator, president of Vapers PH; Clarisse Virgino, the CAPHRA Philippine representative; and Nancy Loucas, executive director of CAPHRA (see image 3 below).^{295 280}

Image 3: (from left) Peter Paul Dator, president of Vapers PH; Clarisse Virgino, the Philippine representative to the Coalition of Asia Pacific Tobacco Harm Reduction Advocates; Nancy Loucas, executive director of CAPHRA; and Heneage Mitchell  at the Asia-wide education and information campaign #SmokeFree4Life in Poblacion, Makati City.

Relevant Link

Factasia.org

Tobacco Tactics Resources

• Global Tobacco and Nicotine Forum
• Next Generation Products
• Philip Morris International
• Lobbying Decision Makers

TCRG Research

Robertson, A. Joshi, T. Legg T, et al., Exploring the Twitter activity around the eighth meeting of the Conference of the Parties to the WHO Framework Convention on Tobacco Control, Tobacco Control Published Online First: 11 November 2020, doi: 10.1136/tobaccocontrol-2020-055889

Stopping Tobacco Organizations and Products, Tweetable Influence: The Tobacco Industry’s Attempt to Engage in COP8, STOP blog, 12 November 2020, available from: exposetobacco.org

References

The post Factasia appeared first on TobaccoTactics.

Background

In the summer of 1999, nearly a decade after it was first used by environmental activists, the term “greenwash” entered the Concise Oxford Dictionary, defined as: “disinformation disseminated by an organization so as to present an environmentally responsible public image”.³⁰¹

The first report on “greenwashing” gave the following examples as illustration: “A leader in ozone destruction takes credit for being a leader in ozone protection. A giant oil company professes to take a ‘precautionary approach’ to global warming…Another giant multinational cuts timber from virgin rainforest, replaces it with monoculture plantations and calls the project ‘sustainable forest development’”.³⁰²

In the decades since, greenwashing has been employed by most polluting or controversial industries, including oil, chemicals, and nuclear energy.³⁰⁰ The tobacco industry has historically greenwashed its reputation and products through programmes such as beach clean-ups,³⁰³marketing of new products as “eco-friendly”³⁰⁴ and funding environmental and disaster-relief organisations,³⁰⁵ especially in low and middle income countries (LMICs), as the examples below illustrate. As consumers have grown to care more about corporate environmental performance, and choose more sustainable products,³⁰⁶ corporations including the tobacco industry have made environmental sustainability an integral pillar of their corporate social responsibility (CSR)/corporate social investment (CSI) strategies.

• More information on CSR as a tobacco industry tactic can be found on our page CSR Strategy.

From the early 2000s, the industry started pushing its CSR and greenwashing message. For example, in the introduction to British American Tobacco (BAT)’s “Social Report” in 2002/2003, the company Chairman, Sir Martin Broughton, said “Corporate social responsibility is integral to our approach to the management of our businesses globally”.³⁰⁷³⁰⁸ Critics were quick to point out the dichotomy and hypocrisy of this statement. A report by ASH, Christian Aid and Friends of the Earth argued that “British American Tobacco, while trying hard to convince shareholders and government otherwise, flies the flag for corporate social irresponsibility”. If nothing else, the report argued, BAT’s cigarette’s “kill smokers”.³⁰⁹ Since 2009, BAT has published annual “Sustainability Reports” on its website.³¹⁰

In an investor presentation in March 2020, BAT executives highlighted the importance of sustainability and sustainable messaging to consumers. The presentation detailed how BAT plans to put sustainability “front and centre”, including the targets of achieving carbon neutrality and 50 million non-combustible consumers by 2030 (Image 1). Sustainability appears to be a key part of BAT’s 2020 rebranding, which saw the company tagline change to “BAT: A Better Tomorrow”, accompanied by a new logo and rainbow-themed website. “Sustainability” also appears as one of the five featured headers on the top menu bar (Image 2).

• For more information on how BAT’s rebranding fits into its broader product strategy, see our page on Newer Nicotine and Tobacco Products: British American Tobacco.

Since the 1950s, when the connection between smoking and negative health effects was first made, tobacco companies have made significant investments in CSR campaigns. They have also used environmental impact disclosure processes and sustainability awards from external bodies to try to create a sense of legitimacy and present their industry as socially and environmentally friendly. However, tobacco companies have maintained the same harmful framing and production practices. Tobacco companies save considerable amounts of money by not having to pay the full cost of the environmental impact of tobacco cultivation, product manufacturing or cleaning up post-consumer waste. The amount of money companies make while using harmful practices involved in their supply chain, such as child labour and deforestation, dwarfs the amount they spend on sustainability CSR projects.³¹³

A 2013 collaborative study between TEEB (The Economics of Ecosystems and Biodiversity) for Business, hosted by the United Nations Environment Programme, and TruCost (the risk assessor arm of S&P Global) found that if major industries were held financially accountable for their currently unaccounted, environmental impacts, they would not be profitable.³¹⁴³¹⁵

• See our pages on Tobacco and the Environment and Tobacco Farming for more information on the harms to global and community environments of tobacco production

In addition to avoiding full financial responsibility for the environmental impact of their business, tobacco companies are able to enhance their reputations and minimise harms through existing environmental impact disclosure organisations and practices.

Environmental impact disclosure

Transnational tobacco companies (TTCs) are eager to position themselves as responsible corporations who care about the environmental sustainability of their products. Philip Morris International (PMI) and British American Tobacco (BAT), for example, both state that reducing the environmental impact of their operations is a key part of their visions for corporate sustainability.³⁰³³¹⁶ Company sustainability reports feature awards and recognitions from organisations such as the Carbon Disclosure Project and Alliance for Water Stewardship in places of prominence.^303316305317 All of the ‘big four’ TTCs (BAT, PMI, Japan Tobacco International and Imperial Brands) and Altria have been rated “A”, the highest possible rating, across various indices by the Carbon Disclosure Project (CDP), a not-for-profit independent index since 2003, for climate change, water, or forests.³¹³³¹⁸ Tobacco companies have also been included in the Dow Jones Sustainability Index (DJSI), which ranks top-performing companies across industries by sustainability performance.³¹⁹

Problem of legitimation

The Carbon Disclosure Project (CDP), and other environmental rankings, featured prominently in the 2018 sustainability reports of each of the ‘big four’ tobacco companies.^316303305320 Until it was expelled in September 2017, the tobacco industry also participated in the United Nations Global Compact (UNGC), a voluntary sustainability pact to encourage sustainable business practices and reporting.³²¹ In 2016, for the last UNGC at which the tobacco industry was allowed to participate, Philip Morris International (PMI) authored a brief entitled “Communication on Progress”. The brief, as Image 3 illustrates, minimized the amount of water needed to produce tobacco by comparing it with the amounts necessary to produce tea or chocolate, per weight of finished product.³²²

As the World Health Organization (WHO) noted, “PMI’s comparison attempts to put tobacco on par with these other products, ignoring the differentiator that these other products do not kill one in two of their daily users, as tobacco does”.³²³ The CDP draws a similar conclusion in its reports on corporate environmental disclosure: “industries tend to deemphasise severity of own transgressions and disagree over what constitutes a ‘significant environmental health’ issue.”³²⁴

Participation in the CDP, DJSI, and UN Global Compact (UNGP) may lead to companies disclosing more environmental information, but it also supports the legitimisation of the tobacco industry, allowing companies “to be seen more as ‘partners’ in public health and environmental sustainability than their deserved reputation as sullying both”.³¹⁵ The public and investors may see inclusion on sustainability leader boards as endorsements of companies’ environmental credentials.³¹³

Mandated reporting by governments can limit the opportunity for “trading data for legitimacy”.³¹⁵ In Brazil and Canada, for example, tobacco companies are required to disclose manufacturing practices, product ingredients, toxic constituents and toxic emissions to national health services. In Brazil, the National Health Surveillance Agency (ANVISA) has the power to impose fines on companies that are not in compliance with tobacco control regulations.³²⁵

Problem of voluntary standards

Because environmental impact disclosure is generally voluntary, companies can set their own standards for disclosure. Voluntary disclosure results in environmental impact data that is vague, unclear and inconsistent in its coverage and methodologies.³¹⁵ This creates several problems.

Firstly, there is no industry-wide standardised format that disclosed data must follow. This makes it difficult for researchers and external evaluators to track progress over time or make comparisons between companies. Though PMI, BAT and JTI all release yearly sustainability reports,^303316305 Imperial Brands and the Altria Group only release short summaries on their websites and include minimal information on environmental impact in their annual reports.³²⁰³²⁶

Secondly, a lack of standards leads to the creation of new units of measurement that can obscure the true scale of environmental impact. By 2018, for example, tobacco companies reported environmental impact data in units known as “intensity”.³¹⁵ “Intensity” refers to units environmental cost per net revenue (e.g. tonnes of CO2 equivalent emissions per GBP£ million net revenue from smoked and vapour products).³²⁰ By reporting environmental costs in this way, tobacco companies are able to obscure year-on-year rise in resource consumption as product volume rises.³¹⁵ For example, even as the environmental harm per cigarette decreases, the total volume of cigarettes produced rises, and therefore so does the total environmental impact.

Third, companies are free to set environmental goals to whatever level they like and choose to disclose on topics that portray their practices in the best light. In 2017, after BAT-owned leaf suppliers exceeded the company’s global target of 1.5kg chemicals per hectare , BAT announced it “would no longer have a global average target”.³²⁷ It now discloses no data on the usage of agrochemicals in its leaf cultivation operations.³¹⁶ This strategy also applies to external disclosure: BAT, JTI and Imperial Brands have all opted out of CDP Forestry reporting after receiving “F” ratings on disclosure and impact in 2017 (BAT,³²⁸ JTI³²⁹) and 2019 (Imperial³³⁰).

Finally, companies are not required to take responsibility for all environmental impacts associated with the life cycle of their products. Tobacco companies have long placed the responsibility for the disposal of cigarette butts on the shoulders of consumers and local government.³³¹ Through the CDP’s Supply Chain Leadership Collaboration, companies can encourage their suppliers to disclose their environmental impact data to CDP.³³² Tobacco companies have participated in this programme since 2007.³¹³ PMI, BAT, JTI and Imperial Brands all appear on the CDP Supplier Engagement Leaderboard,³²⁴ a fact which they all promote in their sustainability reports. However, these same companies do not always account for “Scope 3” emissions in their sustainability reporting.³³³ Scope 3 emissions include “indirect” emissions from independent suppliers in the company’s supply chain, purchased goods and services and capital goods.³¹⁵ Tobacco companies can thus exclude water used by contracted tobacco suppliers, for example, from their total reported water usages.

Sustainability corporate social responsibility programmes

Tobacco companies implement a variety of environment/sustainability-themed corporate social responsibility (CSR) programmes across the world in order to enhance their corporate image. As with disclosure and sustainability awards, tobacco companies use CSR programmes around sustainability to pre-empt regulation and influence policymakers.³³⁴³³⁵ The cases below detail where tobacco companies have implemented CSR programmes on this topic and the organisations with which they collaborate in greenwashing efforts.

Global tobacco industry-funded programmes

On both a global and regional level, individual tobacco companies often fund the same organisations. The Eliminating Child Labour in Tobacco Growing (ECLT) Foundation was co-founded in 2000 by British American Tobacco (BAT) and its front group, the International Tobacco Growers’ Association (ITGA), in response to criticism over the incorporation of child labour in its leaf supply chain in Malawi and elsewhere.³³⁶ All big four tobacco companies have since joined.³³⁷ Until 2019, ECLT had a long-standing partnership contract with the International Labour Organisation (ILO). After pressure from tobacco control organisations, ILO allowed the contract to expire. Both BAT and Imperial Brands are also members of the Slave-Free Alliance (SFA), which is part of a UK-based charity, Hope for Justice.³¹⁶³³⁸ In its 2018 annual report, Imperial Brands stated it was a “founding member” of SFA and that SFA, alongside the ECLT Foundation, received the majority of its charitable contributions.³³⁸

• For more information, visit our page on the ECLT Foundation.

Another industry-founded initiative is the Sustainable Tobacco Programme (STP). Launched in April 2016, the STP sought to provide a “single sustainability programme for the tobacco industry”.³³⁹ It is managed by independent supply chain consultant AB Sustain, a subsidiary of AB Agri.³⁴⁰

Total LandCare (TLC) is another sustainability NGO popular with tobacco companies. Its mission is “to improve the livelihoods and standards of living of smallholder farm households across the region”.³⁴¹ Its funders include the Altria Group, PMI, BAT, Japan Tobacco and the ECLT Foundation as well as non-tobacco companies like Coca-Cola. TLC began receiving tobacco industry funding in 2001 from PMI and Philip Morris USA (now a member of the Altria Group).³⁴¹

From 2001 to 2014, BAT, PMI, Japan Tobacco and Imperial Tobacco spent a combined US$22 million on CSR projects through Total LandCare and ECLT targeting child labour and deforestation. Researchers calculated that this amount was roughly equivalent to 2% of the cost savings these companies derived from deforestation and the use of child labour.³¹³ TLC has since partnered with international non-governmental organisations, including the United Nations Food and Agriculture Organization (FAO) and international development agency USAID, as well as government bodies in southern Africa.³⁴¹ According to Dr Athena Ramos, public health disparities researcher at the University of Nebraska Medical Center, CSR programmes targeted at child labour “represent more of a public relations strategy than any real meaningful change in practice”.³⁴²

These partnerships have at times simultaneously involved the tobacco industry and governments. From 2009 to 2014, for example, Imperial Tobacco (now Imperial Brands) funded a TLC project for the Government of Mozambique.³⁴³ Specific examples of the programmes TLC has implemented with tobacco industry funding are detailed below.

Country-level programmes

Transnational tobacco companies (TTCs) also fund specific country- or community-level programmes. Below are examples of CSR programmes implemented by TTCs from countries across the globe, alongside information on in-country tobacco industry activity.

Bangladesh

In 1980, British American Tobacco Bangladesh’s (BATB) launched the afforestation project Bonayan, in collaboration with the Ministry of Forest and Environment, Government of Bangladesh. BATB reported that it had distributed 5 million saplings in 2019.³⁴⁴³⁴⁵ BATB also runs a project, launched in 2009, entitled Probaho, to provide safe drinking water.³⁴⁵ In 2021, BATB expanded the project to the remote areas of Bandarban, launching in the Langi Para area. The Minister for Hill Tracts Bir Bahadur Ushaising MP inaugurated the local 5,000-liter capacity clean water plant, alongside a representative from BATB.³⁴⁶

The company has received awards for this work, including from the Prime Minister of Bangladesh.³⁴⁷³⁴⁸ In 2021, for example,  it received award in the Asia Corporate Excellence and Sustainability Awards,³⁴⁹ and in 2022 another from the Social Enterprise Research Academy.³⁵⁰ BATB has stated that they plan to continue working with the government.³⁵¹

Bangladesh is the 12^th largest tobacco producer in the world,³⁵² due, in part, to BAT’s investments in the 1970s.³⁵³ Over 45,000 hectares of land are used for tobacco cultivation in the country.³⁵⁴ Tobacco farmers are being encouraged to continue to expand cultivation, thanks to incentives like loans and buy back guarantees from tobacco companies.³⁵²

Tobacco curing uses firewood sourced from local community forests. This leads to widespread deforestation throughout the world. In Bangladesh, an estimated 170,000 individual trees are logged for this purpose each season, in the districts of Bandarban and Cox’s Bazar alone.³⁵⁴ In the district of Kushtia, deforestation has meant that local forests can no longer supply the firewood needed for curing plants. Farmers have to rely on imported straw and jute instead.³⁵⁵ Tobacco cultivation also leads to water contamination due to the use of chemical pesticides and fertilisers, as well as soil contamination and depletion of nutrients. A 2020 study by Hussain et al found that, in Bangladesh, levels of water and soil contamination were higher for bodies of water next to tobacco cultivating land.³⁵²

Brazil

Souza Cruz, British American Tobacco (BAT)’s Brazilian subsidiary, has partnered with the National Service of Rural Learning (SENAR) since 1999 to implement the “Growing Up Right” programme intended to minimise the risk of child labour.³¹⁶ Since 2011, BAT has also been involved with the Brazilian Tobacco Growers Association, the Brazilian Institute of Environment and the Ministry of the Environment for the preservation of forest on the south coast of the country.³¹⁷

In Brazil, where criticism of the soybean industry for its contribution to deforestation has led to global outcry, tobacco farming ranks alongside soybeans and wheat as one of the leading causes of vegetation loss.³⁵⁶ In the south of the country, British American Tobacco’s biggest operational area in the world, tobacco shares responsibility for the reduction of native forest cover to less than 2% of its original extent.³⁵⁷ During the same period of escalation of industry forestation CSR programmes, the scale of destruction of forests actually increased in LMICs during the same period as escalating CSR promotion, providing an “entrée for the tobacco industry into civil society and CSR, thus avoiding direct responsibility for the environmental consequences of the industry” according to Professor Kelley Lee, widely cited Canadian global health scholar.³⁵⁶

Canada

Unsmoke Canada Cleanups is an initiative which raises awareness of cigarette butt waste and organises litter clean-ups. Launched in September 2020, this grant-giving programme operates through a partnership between the national nonprofit The Great Outdoors Fund³⁵⁸ and Unsmoke Canada, an initiative of Rothmans, Benson & Hedges Inc., a Philip Morris International subsidiary.³⁵⁹³⁶⁰ KAB has attracted criticism for being a corporate greenwashing front group.³⁶¹

China

In 2020, the China National Tobacco Corporation (CNTC), donated CNY 40 million (US$ 6.3 million) to support the development of a water supply system in the Yonghe County Shanxi Province of China, with a capacity of 5,000 cubic meters of clean water per day.³⁶².

China produces 40% of the world’s tobacco as well as holding nearly one-third of the world’s smokers. As the single largest tobacco producer in the world, the China National Tobacco Corporation produces as many as 2.5 trillion cigarettes per year.³⁶³ Tobacco growing and the manufacturing of cigarettes are extremely water-intensive activities.A 2018 study estimated that the water footprint of a single cigarette is around 3.7 litres.³⁶⁴ CNTC could be using as much as 9.25 trillion litres of water for cigarette production.

India

Imperial Brands funds education, sanitation and health through its leaf partnership with Alliance One in the Kurnool district of Andhra Pradesh, including environmental education through PROTECT, a local NGO, and an after-school programme, which Imperial said was intended to “minimize the risk of child labour”.³⁶⁵

Individual interventions on a community level do not address the structural, ecological and financial harms that tobacco cultivation causes to local communities. In India, where tobacco cultivation causes the loss of 45 kg of topsoil per acre cultivated per year, a government report called mono-cropped tobacco “the most erosive crop”, beating out cotton (7.5 kg), grapes (11 kg) and groundnut (12.5) (Reddy & Gupta, 2001).³⁶⁶ Child labour in the tobacco industry has also been documented in Andhra Pradesh as well as across the country.³⁶⁷ According to Dr Ramos, tobacco industry CSR programmes that propose to address child labour “represent more of a public relations strategy than any real meaningful change in practice” and disincentivise external monitoring efforts, especially in LMICs.³⁴²

Indonesia

Sampoerna, PMI’s Indonesian subsidiary, operates a wide number of environmentally-focussed CSR programmes under its “Sampoerna untuk Indonesia” scheme. These include a two-year (2018-2020) production sludge waste to fertiliser research project with Insitut Peranian Bogor (IPB) and Indonesian Agricultural Department in East Java (BPTP). A second major programme is the “Hope Project”, which re-purposes factory materials like pallets for its “adult consumer events” and forms a key part of Sampoerna’s marketing strategy. The company stated that: “In 2018, this project successfully recycled 52 tons worth of materials while simultaneously reducing 20% in marketing costs”.³⁶⁸ Sampoerna has won national and international awards for these programmes, such as the Green Company Performance Rating Program from the Ministry of Environment and Forestry in 2022,³⁶⁹, a Global CSR Award and a Global Good Governance Award in 2021.³⁷⁰

Human Rights Watch (HRW) reported that in the course of a 2014-2015 study on child labour in Indonesian tobacco fields, nearly half of all children interviewed reported symptoms consistent with acute nicotine poisoning. HRW concluded that “companies’ human rights due diligence practices were not sufficient to eliminate hazardous child labor in the supply chain” and therefore tobacco companies “risk contributing to the use of, and benefitting from, hazardous child labor”.³⁷¹ Both BAT and PMI have major operations in this area: PT Bentoel Internasional Investama (Bentoel) and PT Hanjaya Mandala Sampoerna Tbk (Sampoerna), respectively.³⁷²

Malawi

From 2001 to at least 2013, Total LandCare (TLC) received millions of dollars of funding from the tobacco industry and ECLT Foundation for forestry,³⁷³³⁷⁴ crop diversification³⁷⁵³⁷⁶ and child labour³⁷⁷³⁷⁸ projects in Malawi.

Malawi and Mozambique are “strategic leaf sourcing locations” for Imperial Brands in Africa. In Malawi, Imperial has been piloted many sustainability initiatives across areas including water conservation,^338379380 afforestation,³⁸¹ combatting soil erosion,³⁸² and crop diversification.³⁸³

In 2018, PMI signed a Memorandum of Understanding with Palladium, the in-country implementer of USAID’s Feed the Future Malawi Agricultural Diversification project,³⁸⁴ to implement “select initiatives” in Malawi.³⁰³ It is unclear whether this partnership includes funding. Palladium is also funded by the Foundation for a Smoke-Free World, a foundation funded solely by PMI. Read more on our page on the Foundation for a Smoke-Free World Grantees.

Tobacco industry harms to the environment and to smallholder farmer communities are well-documented in Malawi. Estimates have placed responsibility for 70% of national deforestation in Malawi on the shoulders of the tobacco industry, making it the main cause of deforestation in the country.³⁸⁵ In 2015, Malawi devoted 5% of its agricultural land to farming tobacco, the highest proportion in the world, but also had the fourth fastest deforestation rate in the world.³⁸⁶ BAT is also being sued by the British legal firm, Leigh Day, for deriving “unjust enrichment” from underpayment and forced/child labour in tobacco farming operations in Malawi. Although BAT and Imperial Brands are named on the lawsuit filed on behalf of tenant farmers in Malawi, this case could protect children and serve as legal precedent to force tobacco supply chain reform, according to Margaret Wurth, a senior researcher at Human Rights Watch.³⁸⁷³⁸⁸

Mexico

Philip Morris International (PMI) runs an initiative in Mexico which involves collecting lighters and other litter to prevent fires. It also helps to promote “smoke-free” messaging and its heated tobacco product, IQOS. Participants collect used lighters and take them to PMI stores and other “strategic points.”³⁸⁹

Mozambique

From 2009 to 2014, TLC was one of a several organisations implementing the government initiative “Promoting Rural Investment in Smallholder Enterprises” (PRISE) in Mozambique. This project was majority funded by Imperial Tobacco (now Imperial Brands).³⁴³

Food insecurity has been tied to tobacco cultivation in Mozambique. In 2019, the Global Hunger Index rated the situation in Mozambique as “serious”: 27.9% of the population was undernourished. Tobacco farming takes arable land away from food crops, depletes soil nutrients and contaminates local water supplies, further harming staple crop production. This in turn further diminishes food security and contributes to malnutrition in communities.³⁹⁰³⁹¹

New Zealand

British American Tobacco New Zealand (BATNZ) provides funding to Keep New Zealand Beautiful for its anti-littering education programmes.³¹⁶

More than six million cigarette butts are discarded in the environment in New Zealand each year. Researchers have called initiatives that encourage individual-level interventions to address tobacco product waste largely ineffective: “Fundamentally, these ’corporate social responsibility’ initiatives position butt disposal as a smokers’ problem, reinforce negative stereotypes of smokers, and relocating responsibility away from tobacco companies”.³⁹²

Portugal

PMI has funded ABAE’s “#Breakthehabit” anti-littering education campaign since 2018 in Portugal.³⁰³ PMI is not, however, listed as a partner on the organisation’s website.³⁹³ Beach clean-up initiatives sponsored by tobacco industry in the United States, for example, have attracted criticism for contributing to greenwashing.³⁶¹

Cigarette filters are commonly the most collected item on beach clean-ups. Worldwide, an estimated 4.5 trillion cigarette butts are deposited each year.³⁹⁴ The industry has consistently and disingenuously marketed cigarette filters as “biodegradable”, with the explicit aim of pre-empting environmental legislation.³⁹⁵

Pakistan

In 2021, BAT subsidiary Pakistan Tobacco Company (PTC) donated 500,000 seed balls to the Khyber Pakhtunkhwa Forest Department for the governmental afforestation project “Ten Billion Trees”.³⁹⁶ In 2022, PTC ran a project comprising free distribution of saplings of indigenous species.³⁹⁷ The company received awards for these initiatives, including for Clean Energy Transition, Responsible Investment, Community Impact and Environment –Carbon footprint reduction.³⁹⁸

To produce cigarettes, raw tobacco is cured using wood for fuel. Farmers either obtain this wood from the market, or by cutting down local and indigenous trees. One study observed 4,500 tobacco-curing kilns in just one tobacco-growing village, servicing around 11,000 acres of land under tobacco cultivation. Combined, these kilns burn about 6,300 tons of fuel wood each curing cycle.³⁹⁹ In 2020, around 125,500 acres (50,800 hectares) of land in Pakistan was devoted to tobacco growing.⁴⁰⁰

For World Cleanup Day 2022, Philip Morris (Pakistan) Limited (PMPKL) launched a litter clean-up project titled #MissionCleanerPakistan, including a litter pick on Clifton Beach, Sea View, Karachi, volunteers collected over 3300 kilograms (3.3 tonnes) of trash for this project.⁴⁰¹ PMPKL has won awards for its CSR activities in Pakistan, including in “Employee Volunteerism” and “Waste Management/Recycling”⁴⁰² and “Green Energy Initiatives”.⁴⁰¹⁴⁰³

After the Sri Lankan government publicly announced its intention to ban tobacco cultivation by 2020, Ceylon Tobacco Company (CTC) engaged in spreading misleading information about the contribution of tobacco cultivation to sustainable development, attempted to interfere in the policymaking process, organised a Buddhist ritual against the ban and promoted its SADP programme through media tours.⁴⁰⁴

Tanzania

The JT Group (JTI parent company) partnered with TLC from 2007 to 2014 to fund the Community Reforestation and Support Program in Tanzania and Malawi.⁴⁰⁵

Loss of biodiversity due to tobacco cultivation deforestation-driven habitat fragmentation is well-documented in Tanzania. Excessive wood use during tobacco curing and uncontrolled land clearing are important factors leading to deforestation and desertification. The tobacco industry has a history of funding and promoting afforestation programmes in order to distract and refute research that shows the negative effects of tobacco cultivation on forest cover, biodiversity, soil erosion and ground water retention.⁴⁰⁶

United Kingdom

In January 2021, Philip Morris Limited entered a multi-year agreement with the non-for-profit, Clean Up Britain (CLUB) to “tackle cigarette butt litter”. Within this voluntary agreement, CLUB acts as independent administrator for a PMI-funded project. ⁴⁰⁷ PMI reportedly paid a “seven-figure sum” to fund the project, which consists in applying “emotional” pressure on smokers caught littering cigarette ends.⁴⁰⁸ The campaign was launched in January 2022 in Bristol, under the title “Get Your Butt Off Our Streets”, to be later rolled out across Britain.⁴⁰⁹ An estimated 4.5 trillion cigarette butts are discarded every years in the environment, making them the most littered item on Earth.³⁹⁴ Post-consumer waste, largely in the form of discarded cigarette butts, and its disposal, is however only the last step of life-cycle of a cigarette. Each step of the tobacco supply chain, from agriculture to distribution, contributes substantially to climate change and environmental degradation.

United States 

Altria, Reynolds American International (BAT) and Santa Fe Natural Tobacco Company (BAT) all provide funding for the Cigarette Litter Prevention Programme run by Keep America Beautiful (KAB).⁴¹⁰. The Cumberland Plateau Stewardship Fund, of which Altria is a member along with US government departments, has provided a total of US$3.1 million to the National Fish and Wildlife Foundation to fund conservation programmes in the US Cumberland Plateau, which spans parts of eastern Kentucky, Tennessee, Alabama and Georgia, from 2017-2019.^411412413 RAI and Altria are also both members of the Supply Chain Resource Cooperative hosted at North Carolina State University (NC State).³¹⁶³²⁶ The Cumberland Plateau is located in key tobacco growing states. A 2013 investigation by Human Rights Watch revealed that, of 133 children interviewed in North Carolina, Kentucky, Tennessee and Virginia, where over 90% of tobacco grown in the US is cultivated, 66% reported symptoms consistent with acute nicotine poisoning. At least eight major cigarette manufacturers, including BAT, PMI, Altria, Imperial Brands, JTI and China National Tobacco Company all sourced tobacco leaf from the US at the time.⁴¹⁴

Philippines

In 2019, PMFTC, the Philippine affiliate of PMI, donated 30 waste bins to the Armed forces at camp Servillano Aquino, Tarclac City.Tobacco accounts for 2 million tons of solid waste worldwide, every year.³⁹⁴

Tobacco industry charitable donations

Charitable donations are a key part of tobacco industry CSR strategy Though companies are not always obliged to disclose the amounts and destinations of their charitable donations, both Philip Morris International and the Altria Group publish information on their funding of third-party organisations online.⁴¹⁵⁴¹⁶

The tobacco industry also commonly donates to disaster relief efforts where they operate, including: Ecuador, Guatemala, Haiti,⁴¹⁵ Indonesia,^305417415 Italy, Japan, Malaysia,⁴¹⁵ Mexico,³⁰⁵⁴¹⁵ Mozambique,⁴¹⁸ the Philippines,³⁰⁵⁴¹⁵ Romania, Senegal and Serbia.⁴¹⁵

These lists are not comprehensive. Evidence of funding for sustainability programmes in Australia, Colombia, the Dominican Republic, Ethiopia, Japan, South Africa, South Korea and Ukraine is also given in PMI’s charitable donations disclosure for 2014-2018.⁴¹⁵

In the United States, the Altria Group has funded various environmental sustainability organisations. Donations disclosed in 2018 and 2019 appear in the table below.

Co-option of “sustainability”

In sustainability reports, tobacco companies use “sustainability” as a rhetorical strategy to align themselves with both environmental sustainability and sustainable development. All major TTCs are at least rhetorically supportive of the UN Sustainable Development Goals (SDGs); examples from 2018 and 2019 tobacco company sustainability reports can be seen in Image 4.

For example, in the company’s 2016 sustainability report, BAT CEO (at the time) Nicandro Durante said there was a “clear alignment between the SDGs and our own sustainability priorities”.³²⁷ However, since 2017, WHO’s Framework Convention on Tobacco Control, which prevents the tobacco industry from having influence on health policy, has been explicitly included in SDG 3 (Human Health) through Target 3A: “Strengthen the implementation of the World Health Organization Framework Convention on Tobacco Control in all countries, as appropriate”.⁴²¹ Notably, none of these reports mention the incorporation of the WHO FCTC into the SDGs as part of Target 3.

In Highjacking the SDGs? The Private Sector and the Sustainable Development Goals, German tobacco control expert Laura Graen argued that references to the SDGs form “part of a broader, multi-layered strategy with the aim of stopping tobacco control measures such as taxation, advertising bans or plain packaging”.³²¹ An internal Philip Morris International (PMI) document, leaked to Reuters in 2017, revealed that the potential inclusion of additional tobacco control measures in the SDGs were seen by PMI as an “alarming development” because the company feared “that it could lead to the creation of another international body at the UN that would deal specifically with tobacco issues”.⁴²²

Tobacco companies take advantage of conflicting goals (e.g. economy and health) within SDGs. In particular, tobacco companies point to SDG 17 (on Public-Private Engagement) to justify and advocate for tobacco industry involvement in government, which is prohibited by Article 5.3 of the FCTC.^316303320305 The industry has formed relationships with other government departments after being excluded from health through “sustainable development” partnerships and programmes: BAT Bangladesh has partnered with the Bangladeshi Department for Agricultural Extension to implement sustainability CSR projects.⁴²³ The industry uses SDGs to further circumvent regulation and perpetuate its harmful business practices, undermining sustainable development rather than helping it.³²¹

• For more detail on how the tobacco industry aligns itself with sustainable development in smallholder farmer communities, read our page on Tobacco Farming.

Impact on regulation

On one hand, encouraging companies to disclose more information on the environmental impact of their products (through their life cycle and supply chains) can be seen as increasing transparency and supporting improvement of inefficient and harmful practices. On the other hand, increasing disclosure can also be seen as a form of CSR self-promotion. Academic research on governance suggests that these “proactive moves by the industry to stave off regulation that would require them to adhere to externally wrought environmental standards and practices”.⁴²⁴

Voluntary disclosure and other “ethical and green business” practices have been criticised as CSR and public relations campaigns designed to rehabilitate corporate image and increase product sales without addressing the fundamental changes necessary to core business practices.^313425426 An additional challenge is that regulations differ by location. Tobacco companies have also historically taken advantage of differing regulation to avoid bearing the weight of corporate responsibility for their products. This includes avoiding and evading tax as well as environmental regulations.⁴²⁷⁴²⁸

For example, in March 2016, BAT announced it would close a cigarette manufacturing plant in Malaysia due to the government’s implementation of an increased excise tax and consideration of plain packaging.⁴²⁹ However, it had really made plans to open up another manufacturing plant in southern Vietnam, well before the excise taxes or discussions on plain packaging commenced.⁴³⁰

The tactic of moving production facilities has been used by tobacco companies around the world, often when governments have sought to introduce tobacco control regulations. For example, when faced with the prospect of increased taxes and government’ support for tobacco control, Philip Morris International has closed, or threatened to close, manufacturing plants in Argentina.⁴³¹⁴³² and Colombia.⁴³³ BAT used the same tactic in Chile in 2015.⁴³⁴

Industry-funded sustainability programmes pre-empt criticism and make it difficult to advocate for external regulation. When commenting on the efficacy and intent of tobacco industry reforestation schemes, prominent tobacco control researchers Dr Marty Otañez and Dr Stanton Glantz said that industry-funded programmes facilitate an environment where government officials LMICs who lack revenues to fund their own initiatives are hesitant to criticise tobacco industry schemes or refuse funding. Additionally, “association with social and environmental responsibility may weaken opposition from public health and civil society groups to industry interference in tobacco control policy by making it politically more difficult to criticize tobacco companies”.³¹³

The tobacco industry has also moved to distance itself from tobacco cultivation through establishing “leaf partnerships” with third-party companies. Instead of direct contracts with farmers, this has had the effect of transferring responsibility for monitoring and addressing problems from tobacco companies to leaf companies, while continuing to reap the benefits of cheap leaf products and escaping culpability for harmful practices. Especially in LMICs, where there may be less infrastructure to support monitoring and corporate financial contributions may have a greater impact, tobacco companies can use these kinds of initiatives to increase political support and weaken opposition.³⁴²

The WHO’s 2017 report on the environmental harms of tobacco says that this practice of evading tax and regulation “epitomizes how, in many instances, when citizens petition for better environmental practices or more socially responsible business conduct, transnational tobacco companies simply uproot their operations and ignore the long-term environmental damage that they have caused, and take them to a new location where they can repeat the environmental damage”.³⁸⁵ When companies relocate away from taxation and regulation, they impoverish already cash-strapped central governments. The current and historical tax evasion and anti-tax lobbying of tobacco companies makes it all the more difficult for LMICs with developing economies to devise and implement effective environmental regulatory regimes.

It its 2017 report, WHO recommended that steps to limit greenwashing include legislating at international and local levels to require companies meet specific disclosure requirements for material emissions, water usage, waste disposal, chemical use, child labour and other targets. It is particularly important that these regulations apply equally across countries; tobacco companies have a history of moving their operations to avoid scrutiny and environmental regulations.³⁸⁵ The evaluation of disclosed data should be performed by independent evaluators, such as government, who do not require or accept payment from companies for this service.³¹⁵ The WHO also recommends that countries ban tobacco advertising, promotion and sponsorship (TAPS) that include bans on advertising CSR programmes, in accordance with the FCTC.

Researchers and international non-governmental organisations, including the Organisation for Economic Co-operation and Development (OECD) and European Union (EU), have suggested that implementing and strengthening existing Extended Producer Responsibility (EPR) schemes to make producers responsible for the physical and financial costs of disposing of waste of post-consumer products.⁴³⁵⁴³⁶ EPR will be implemented in the EU, with increasing targets for recycling, prevention and use from 2025 to 2035.⁴³⁷ The “Single Use Plastics Directive” will include cellulose acetate products, including cigarette filters, which do not biodegrade.³³¹

Tobacco Tactics Resources

• Tobacco and the Environment
• Tobacco Farming
• ECLT Foundation
• CSR Strategy
• United Nations Global Compact (UNGC)

Relevant Links

• BAT sustainability webpage
• PMI sustainability webpage
• JTI sustainability webpage
• Altria Group sustainability webpage
• Imperial Brands sustainability webpage

TCRG Research

• J. Hoek, P. Gendall, M. Blank, L. Robertson & L. Marsh, Butting out: an analysis of support for measures to address tobacco product waste, Tobacco Control, 2020;29:131-137, doi: 10.1136/tobaccocontrol-2019-054956
• B.K. Matthes & M. Zatoński, Addressing the tobacco epidemic as a sustainable development priority: the need for cross-disciplinary thinking, University of Bath Centre for Development Studies Blog, 31 May 2019
• B.K. Matthes & M. Zatoński, Tobacco control and sustainable development: shared challenges and future opportunities, J Health Inequal, 2019;5(1):71-79, doi:10.5114/jhi.2019.87840
• S. Ulucanlar, G.J. Fooks, A.B. Gilmore, The Policy Dystopia Model: An Interpretive Analysis of Tobacco Industry Political Activity, PLOS Medicine, 20 September 2016, doi:10.1371/journal.pmed.1002125
• A.B. Gilmore, G. Fooks, J. Drope, S.A. Bialous & R.R. Jackson, Exposing and Addressing Tobacco Industry Conduct in Low-Income and Middle-Income Countries, The Lancet, 2015;385(9972):1029 – 1043, doi:10.1016/S0140-6736(15)60312-9
• G. Fooks & A. Gilmore, Corporate Philanthropy, Political Influence, and Health Policy, PLoS ONE, 2013, 8(11):5, doi:10.1371/journal.pone.0080864
• G. Fooks, A. Gilmore, J. Collin, C. Holden & K. Lee, The limits of corporate social responsibility: Techniques of neutralization, stakeholder management and political CSR, J Bus Ethics, 2013;112(2):283-299, doi: 10.1007/s10551-012-1250-5

References