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European Initiatives

BMA response to the EU Directive on the manufacture, presentation and sale of tobacco products

16 February 2000

Mr Tim Baxter
Team Leader, Tobacco Policy Unit
Department of Health
Wellington House
133-155 Waterloo Road
London SE1 8UG

16 February 2000
Our Ref: IO102

Dear Mr Baxter,

Thank you for your letter dated 20 January 2000 requesting comments on the above proposal. While welcoming the proposal, the British Medical Association feels that certain changes are necessary to the Directive as drafted, if it is to be effective in correcting current regulatory weaknesses and inconsistencies. We believe that it is essential that the regulations of the Directive must apply to all tobacco products sold and manufactured in the EU, as well as to those manufactured in the EU for export. In particular, I would like to draw your attention to the need to strengthen measures that address the composition and presentation of the product.

Product composition
We believe that smokers should have access to accurate information on the composition of the products that they use. Certain amendments would improve matters in this respect.

  • Accurate independent testing of product yields. Recent evidence demonstrates that the testing systems used by European regulatory authorities for ascertaining the levels of tar and nicotine displayed on cigarette packs do not reflect the actual amount absorbed by the consumer [Kessler DA. The control and manipulation of nicotine in cigarettes. Tob Control 1994;3:362-69]. It is essential that the Directive include a recital whereby accurate independent monitoring procedures for product composition can be developed and set in place. Such a protocol must require the revision of regulations to take account of new evidence. Where public health is concerned, there should be no obligation to respect trade secrecy, and all results should be disclosed at 6-month intervals.
  • Limits on tar, carbon monoxide and nicotine yields. We support an upper limit of 10 mg for carbon monoxide, as well as a maximum nicotine yield of 1 mg, as currently measured. However, in view of the current debate regarding the relative benefits of a tar-reduction strategy and the tar : nicotine ratio approach, we recognise that a further reduction in tar yields may not be appropriate at this time. Implementation of new limits on nicotine and carbon monoxide should be brought forward to 31 December 2002.
  • Disclosure of product composition. More than 600 substances are authorised for use in tobacco products [Bates C, Connolly GN, Jarvis M. Tobacco Additives. London: Action on Smoking and Health and The Imperial Cancer Research Fund, 1999]. We support the full disclosure of all the ingredients of the manufactured tobacco products by brand as required by the Directive. Disclosure of the use of genetically modified tobacco should also be required. We cannot support the provision for trade secrecy as we believe this to be a barrier to public health. In addition, we would like to see the implementation date brought forward to 31 December 2001.

Product presentation
We believe that smokers should have access to accurate information on the health effects of the products that they use, and on resources that can help them stop smoking, should they wish to do so.

  • An end to misleading branding and labelling. The Directive will end branding and labelling that implies certain cigarettes are healthier. Terms such as 'light', 'mild', and 'ultra-light' are misleading to the consumer, and must be prohibited throughout the EU. Brand names and product or pack designs that imply such health benefits should also be forbidden under the Directive.
  • Tar, nicotine and carbon monoxide yields. In view of the evidence that the yields indicated on the package do not reflect the dose absorbed by the smoker, we feel that it is misleading to continue to quantity these on the pack. The Directive should require that packs indicate that cigarette smoke contains tar, nicotine and carbon monoxide, but should prohibit the inclusion of quantitative yields using the discredited FTC/ISO system. This panel should cover 30% of one side surface of the pack.
  • Health warnings. The size of the warning labels should be increased to a minimum of 50% of the package size, and their position, print colour, border size etc. be specified graphically in an addendum to the Directive. The list of health warnings should include the option: 'Smoking causes male sexual impotence'. Rotation of warnings should be required and its frequency defined. There should be the possibility of adding additional health warnings as appropriate.
  • Information on stopping smoking. We believe that in view of the addictive nature of tobacco, information on how to stop smoking should be included on every pack. One possibility would be the addition of a side panel with a Europe-wide Internet address or telephone number giving access to local or national resources that can help smokers to stop. This panel should cover 30% of one side surface of the pack.

Finally, we urge the addition of a new article to the Directive, requiring the inclusion of EU-wide tax-and duty-paid stamps and identifying codes on cigarette packs as a measure to counter tobacco smuggling. Sophisticated international tobacco smuggling is an increasing problem within and beyond the EU, and effective action must be undertaken to prevent this illegal trade that undermines fiscal policies aimed at protecting public health.

We remain at your disposal for any further information that may be required.

Yours sincerely,

M J Lowe
Deputy Secretary
British Medical Association

  
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