Our views on regulation

These proposals would require a standardized appearance for all tobacco packaging, with only the brand name in a specified standard typeface, color, and size.

There is no reliable evidence that this measure will achieve its objectives . Plain packaging will not lead to a change in the actual behavior of smokers, either by reducing smoking initiation by minors or by increased quitting.

Further, proposals for plain packaging are not based on, or consistent with, a credible and scientifically rigorous understanding of the behavior of smokers.

Packaging is essential to brand competition. Packaging is used by consumers to identify and choose tobacco products, easily and without confusion. Manufacturers use distinctive packaging to develop brand equity, innovate and compete. Plain packaging therefore represents an extraordinary and unprecedented attempt to deprive JTI of its most valuable assets – its brands and trademarks – which are worth billions of dollars.

See JTI’s full response to the UK consultation. Expert Reports (here); see more particularly, Professor L. Steinberg’s 2016 and 2010 reports; and Professors R. Dhar and S. Nowlis’s report.

Product displays – whether for tobacco or any other product category – are a platform for genuine competition between companies. Product displays enable consumers to identify,and choose products, easily and without confusion.

Proposals for product display bans are not based on, or consistent with, a credible and scientifically rigorous understanding of the behavior of smokers. Product display bans will not lead to a change in actual smoking behavior, either by reducing smoking initiation by minors or by increased quitting among minors or adults. See Access to Tobacco Products, in JTI’s Full Response to the EU Consultation and JTI Response to the Health Promotion Board’s Public Consultation on Tobacco Control; Expert Reports (here).

While JTI supports regulation of smoking in many public places, we do not believe that laws prohibiting smoking in all places open to the public are the solution. Instead, we advocate tailored, practical, and effective solutions that accommodate the legitimate interests of those who do not want to be exposed to environmental tobacco smoke, those who want to smoke in socially appropriate or traditionally adult venues, and business owners who want to have a role in deciding how to implement solutions that work for their customers and employees.

Solutions that do not rely on blanket prohibitions have been successfully adopted in many cities and countries around the world. Such solutions may include, either alone or in combination, in the form of legislation or voluntary self-regulation:

• Designation of separate smoking and non-smoking areas;
• Designation of an entire business as either a smoking or non-smoking location;
• Effective ventilation to control air flow and quality;
• Visible signage that clearly indicates, before entering the premises, which solutions are in place.

We advocate such solutions by working directly with governments, business organizations, consumer groups and others who have an interest in evidence-based regulation that can be enforced fairly and efficiently.

Ingredients play a significant role in JTI's development of unique cigarette brands which meet consumer preferences, particularly regarding taste and aroma.

Ingredients are also:

• Added to tobacco during the manufacture of JTI's products to help keep tobacco moist, and to help maintain product quality and facilitate the manufacturing process;
• Used in the manufacture of non-tobacco materials such as filters, cigarette papers and packaging materials.

JTI supports the regulation of tobacco product ingredients, if it is coherent, scientifically sound, and necessary to meet valid regulatory objectives.

JTI is concerned that unless a science-based approach to ingredients regulation is adopted, governments may implement unnecessary, inappropriate, and potentially arbitrary restrictions on the ability of JTI to innovate and manufacture a wide range of competitive products that meet consumer preferences. This could also inadvertently limit the development of new technology products that may have the potential to reduce the risks associated with smoking.

See Regulation of Ingredients, JTI Full Response to the EU Consultation.

Regarding ingredients disclosure:

Smokers want to know what it is they are smoking. JTI provides ingredients information on this web site, and provides ingredient information to governments who request it.

As is the case for many well-known consumer products however, JTI's brand recipes and other commercially confidential information are highly valuable trade secrets, and must be protected.

For more information about the ingredients we use in our products, see what's in our products.

JTI believes that minors should not smoke, and should not be able to obtain tobacco products or vaping products. It is central to our Code of Conduct, our marketing practices, our operational policies and the way JTI does business.

JTI is committed to youth smoking prevention, and participates with other tobacco companies and retail associations in on-going programs to prevent minors from obtaining tobacco products.

As part of this effort, JTI has committed significant resources to the consideration and development of regulatory solutions to reduce or eliminate the ability of minors to obtain tobacco products.

JTI believes that tobacco manufacturers, retailers, regulators, and educators have a common interest in preventing minors from smoking. However, this problem can only be addressed effectively if regulators have an up to date and accurate understanding of minors' behavior, and in particular, the factors that cause minors to take up smoking.

Understanding smoking behavior is the key to changing behavior. But sharing a common goal of preventing minors smoking is simply not enough.

Contemporary research on adolescent decision-making consistently shows that minors are well aware of the health risks of smoking, but that many smoke anyway. Minors have a greater propensity than adults for risk taking behaviors of all kinds, so there is likely to be a proportion of minors who try smoking, irrespective of efforts to remind them about the risks. Measures that limit minors' ability to obtain cigarettes are therefore likely to have a greater impact than those that attempt to diminish their interest in smoking.

See Professor L. Steinberg’s Report;. Consumer Information, JTI Full to the EU Consultation; Expert Reports (here).

Governments are under undue pressure from tobacco control advocates to exclude the tobacco industry from participating in regulatory processes.

JTI strongly believes that the tobacco industry should not be excluded from any national or international regulatory process. JTI has a right – and an obligation – to express its point of view regarding regulation that affects its products and its industry.

JTI believes that transparency and stakeholder participation are critical to ensuring that the resulting regulation is effective, proportionate and meaningful.

Protection of the regulatory process – from the vested interests of any stakeholder – should be founded on internationally accepted principles of Better Regulation and should include effective and proportionate measures that can be adopted by each nation in accordance with their national laws.

Institutional reform, codes of conduct and anti-corruption regulation are examples of measures which should be considered.

However, excluding the tobacco industry – or any legitimate stakeholder – from regulatory processes, consultations and public hearings cannot be an appropriate solution.“