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Packaging & Labelling

The aim of health warnings on tobacco products should be to remind consumers of the health risks associated with smoking. These risks are already well known to the general public. Calls for extending tobacco packaging restrictions through measures such as plain packaging are not motivated by science or concerns about public health, but by ideology and politics. The argument that packaging restrictions work to deter minors from smoking is flawed.

In the EU, health warnings must cover 65% of a tobacco package’s surface.

No reasonable argument can be made that such coverage is insufficient to inform consumers about the health risks of smoking, and there is no evidence proving that further enlarging the required warning coverage would improve public health. Health warnings on packs should educate and remind people about the risks posed, but not shame adults who understand smoking’s health risks, are respectful of others, and opt to smoke by personal choice.

Plain packaging is being justified on the false premise of having an impact on smoking initiation. On the contrary, it represents a dangerous regulatory overreach, flying in the face of intellectual property (IP) rights and setting a dangerous precedent for government intervention by expropriating IP on the basis of ideology rather than science.

There is no credible evidence that plain packaging has an effect on tobacco consumption or smoking initiation.

Rather, its aim is to penalise smokers by creating a negative social stigma. Plain packaging regulation is an example of nanny state intervention and is not a reasonable public health measure.

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Health Warnings

The health warnings on tobacco products in the EU ensure that all smokers are reminded of the associated health risks. The EU Tobacco Products Directive mandates the use of a ‘combined health warning’ (CHW) on both cigarettes and fine-cut tobacco. The CHW, which consists of both text and a picture, must take up 65% of surface on the front and back of a unit package. The warning must be fully visible and may not be covered by the tax stamp. In addition, a text-only ‘general health warning’ (GHW) and information message must each take up 50% of the defined surface on the unit package where they are applied.

In order to accommodate the CHW requirement, producers of fine-cut tobacco had to change the shape of their packets, lengthening the flap to meet the specification of the CHW. This involved a costly process of changing and replacing machinery.

Having borne this expense, manufacturers are now faced with having to change their manufacturing process and machinery again to comply with proposed EU rules for implementing a track and trace system. Placing these undue costs on manufacturers only drives small producers out of business, and serves no public health or economic purpose.

Larger health warnings do not have any effect on smoking rates. Further changes in the size of health warnings cannot be justified on public health grounds, but are rather aimed at increasing expenses for the industry. While this will impact all companies, small manufacturers will face disproportionate costs, possibly leading to further market consolidation.

Plain Packaging

Plain packaging involves replacing all branding on a tobacco product pack with a neutral, government-designed label. With no evidence that such draconian restrictions generate any health benefits, the main effect of plain packaging is to stigmatise smokers.

Plain packaging also constitutes an unjustified infringement of intellectual property rights and trademark rights guaranteed by European and national laws. Legal manufacturers have the right to distinguish and differentiate their products from those of their competitors. But plain packaging makes further innovation impossible by effectively preventing manufacturers from introducing new brands. Consumers also have the right to information about the products they are buying. By denying them this information, plain packaging restrictions are an affront to the legal rights of consumers as well as producers.

Plain packaging also facilitates illegal trade in tobacco by making it easier for counterfeiters to reproduce the unbranded packs. Plain packaging achieves none of its stated aims, disregards the rights of EU consumers and producers, and is counterproductive in the fight against criminality and illegal trade. There is no justification for plain packaging, and no rational argument for how it serves the public interest.