Last updated: May 26, 2022
Other Packaging and Labeling Requirements
Warning requirements on unit packaging and labeling (e.g., packs)
The law requires that a health warning occupy 50% of the front and back of the tobacco product “package.” “Package” is defined in GSO 246/2011 to specifically include the individual unit package. Therefore, warnings are required on unit packaging and labeling.
The GSO 246/2011 meets FCTC Art. 11 in this respect.
Warning/messages required on outside packaging and labeling (e.g., cartons)
The law requires warnings on the front and back of the tobacco product “package.” “Package” is defined as “any materials in which the product is directly packaged for sale as a separate unit when offered to the consumer [or] . . . the individual package.” This is interpreted as requiring warnings on outside packaging and labeling such as cartons. Moreover, the Ministry of Public Health issued a directive in January 2019 specifically clarifying that health warnings are required on cartons of tobacco products.
The law meets FCTC Art. 11 in this respect. To fully align with FCTC Art. 11 and the FCTC Art. 11 Guidelines, however, the law should contain a definition of “outside packaging and labeling” in accordance with the definition provided in FCTC Art. 11.
Warning texts must be in the principal language(s) of the country
The law requires health warnings in Arabic on the front panel and English on the back panel.
The law meets FCTC Art. 11 with respect to requiring warnings in the principal language(s) of the country.
A requirement that warnings or messages may not be placed where they may be permanently damaged or concealed when opening the pack
The law requires that warnings must be printed directly on the package, not on the package’s outer cellophane wrapper or the product name sticker. The health warnings must be attached so that it is difficult to remove the warning, and the text cannot be hidden or overlapping with other text or images. Finally, the law provides that “the warnings shall be written in such a way . . . that it is not affected by opening the package.”
The law aligns with FCTC Art. 11 and the FCTC Art. 11 Guidelines regarding damaged or concealed warning labels.
A requirement that tax stamps or other required markings may not be placed where they may conceal warnings or messages
The law requires that health warnings be written in such a way that the text is not hidden or overlapping with other text or images.
The law aligns with FCTC Art. 11 and the FCTC Art. 11 Guidelines regarding tax stamps or other required markings concealing warning messages.
A requirement to display qualitative (descriptive) constituents and emissions messages
The law does not require qualitative constituents and emissions messages. (Although one of the health warnings contains a descriptive statement about constituents and emissions, this is different than an explicit requirement that packages must display a descriptive constituents and emissions messages in addition to the prescribed health warnings.)
To align with FCTC Art. 11 and the FCTC Art. 11 Guidelines, the law should affirmatively include this requirement.
Prohibition on the display of figures for emission yields (including tar, nicotine, and carbon monoxide)
The law requires that the level of tar, nicotine, and carbon monoxide be displayed on cigarette packages and the level of nicotine on other tobacco products.
To align with FCTC Art. 11 and the FCTC Art. 11 Guidelines, the law should prohibit the display of figures for levels of tar, nicotine, and carbon monoxide as this information can be misleading to consumers.
Plain or standardized packaging
Plain packaging of tobacco products is not required. The FCTC Art. 11 Guidelines provide that Parties should consider adopting plain packaging measures that restrict or prohibit the use of logos, colors, brand images, or other promotional information on packaging other than brand and product names displayed in a standard color and font style. Plain packaging aims to reduce the appeal of tobacco products, to increase the noticeability of health warnings, and to reduce the ability of the packaging of tobacco products to mislead consumers about the harmful effects of smoking.
Prohibition on misleading tobacco packaging & labeling including terms, descriptors, trademarks, figurative or other signs (logos, colors, images that directly create a false impression that a tobacco product is less harmful than other tobacco products)
The law requires that the "product must not be described or shown on a label or in descriptive data in such a way that it could result in a mistaken impression about its attributes or convey the idea that it is less harmful, with the use of such terms as: light, extra light, gentle, low tar, zero nicotine or tar, mild, low, and similar terms." This provision is interpreted as banning all misleading terms and descriptors, including colors, logos, or other signs.
The law meets FCTC Art. 11 with respect to misleading tobacco product packaging and labeling.
