Analysis
The primary warning must occupy 15% of the front of the package and be situated at the top. The secondary warning must occupy 25% of the back of the package and be situated at the top. The side panel warning regarding the contents of tar and nicotine must occupy 20% of one of the sides. The text must be surrounded by a border and the text itself must occupy between 60% to 70% of the total warning display area.
Warnings must appear in black, red, or blue print on white background on half the packages, and appear in white print on black, red, or blue background on half the packages. The primary (front) and side panels warnings must appear in capital letters.
Concurrent rotation is required: each of the eight primary warnings, with associated secondary warnings, must appear on an equal number of packages, within a 10% variance, in a 12-month period. There are no requirements for consecutive rotation.
The warning provisions do not align with FCTC Art. 11 and the FCTC Art. 11 Guidelines. To align with FCTC Art. 11 and the FCTC Art. 11 Guidelines warnings should occupy 50% or more of the principal display areas (PDAs) but shall be no less than 30% of the PDAs.
