Analysis
The law requires graphic health warnings to cover 50% of the front and back faces of unit and outside packaging and labeling. On unit packaging, the warnings must occupy the top 50% of the principal display area. For outside packaging and labeling (i.e., cartons), the warnings must occupy the left 50% of the principal display area. Health warnings must be in French on the front side and in Arabic on the back side.
The law also requires an additional text-only message to cover the lateral sides of unit packaging of smoked tobacco products (it does not apply to cartons or packages of smokeless tobacco). The French version is to appear on the left side and the Arabic version on the right side. While the law does not specify the surface area these must occupy, the examples provided in the appendix show the messages cover 100% of the lateral side.
In total, the law includes 11 graphic health warnings (front and back) and five text-only statements (lateral sides). Each year, these warnings/statements must be rotated equally among each brand in a family of brands and each type and size of package. (Note: Although the graphic health warnings are divided into three sets/annexes, it is unclear whether the sets are to be used concurrently or consecutively. For now, the law is interpreted as requiring concurrent use.)
The law meets the minimum requirements of FCTC Art. 11 with respect to size (30%), location, and rotation. The law aligns with the FCTC Art. 11 Guidelines in that the current implementing order requires graphic warnings that occupy 50% of each principal display area.
