Location and Size of Warnings / Messages on Unit Packaging
65% of Front, 65% of Back, Side(s)
Rotation
Required
Number of Warnings / Messages Authorized to Be Displayed at Any Given Time
6
Length of Rotation Period
Uncertain
Analysis
All smoked tobacco products (including cigarettes, loose tobacco, and cigars) must carry picture and text warnings occupying 65% of the front and back of the product packaging. There are a total of 6 combined picture and text warnings, which must be “printed in rotation and equal frequency” on each brand and type of tobacco product. However, it is unclear how long each rotation must last. In addition, a qualitative (descriptive) text message on constituents and emissions must appear one side panel of product packages, occupying “a substantial part” of that surface.
The law meets FCTC Art. 11 and aligns with the FCTC Art. 11 Guidelines with respect to size, location, and rotation of health warnings on packages of smoked tobacco products. However, to more fully align with FCTC Art. 11 and the FCTC Art. 11 Guidelines, the law should require updating of the set of picture/text warnings every 12 - 36 months.
Location and Size of Warnings / Messages on Unit Packaging
65% of Front, 65% of Back, Side(s)
Rotation
Required
Number of Warnings / Messages Authorized to Be Displayed at Any Given Time
6
Length of Rotation Period
Unspecified
Analysis
All smokeless tobacco products must carry picture and text warnings occupying 65% of the front and back of the product packaging. There are a total of 6 combined picture and text warnings, which must be “printed in rotation and equal frequency” on each brand and type of tobacco product. However, it is unclear how long each rotation must last. In addition, a qualitative (descriptive) text message on constituents and emissions must appear one side panel of product packages, occupying “a substantial part” of that surface.
The 6 picture/text warnings for smokeless tobacco are the same as those for smoked tobacco products and therefore not appropriate smokeless products (e.g., the warnings state “smoking products cause . . .”).
While the law meets FCTC Art. 11 and aligns with the FCTC Art. 11 Guidelines with respect to size, location, and rotation of health warnings on packages of smokeless tobacco products, the law does not align with the regard to the content of those warnings. To align with FCTC Art. 11 and the FCTC Art. 11 Guidelines, the law should require health warnings that are specific to smokeless tobacco products. In the addition, the law should require updating of the set of picture/text warnings every 12 - 36 months.
