Analysis
For cigarettes, hookah tobacco, and rolling tobacco
The law requires that a "combined health warning" (including an image and text) cover 65% of the front and back of the packaging of cigarettes, hookah tobacco, and rolling tobacco. The combined health warnings are broken into three sets of 14 warnings each. The three sets are to rotate every year, with the 14 warnings of one set appearing on an equal number of packages over the course of the one-year period. Thus, both simultaneous and consecutive rotation is required.
Within the space set aside of a combined health warning, the image shall take up 50%, the text warning 38%, and information on smoking cessation (a quitline phone number and website) 12%.
In addition, a "general warning" that states "Smoking Kills" is required to appear on one side of the package. An "information text" that states "Tobacco smoke contains over 70 carcinogenic substances" must appear on the other side of the package. These warnings must be at least 20 mm in width on box- or rectangular-shaped packages.
The law meets the requirements of FCTC Art. 11 and aligns with the FCTC Art. 11 Guidelines in that rotating pictorial health warnings cover at least 50% of the principal display areas.
For other smoked tobacco products
The law requires a "general warning" that states "Smoking Kills" to cover 30% of the most visible surface of tobacco product packaging. In addition, a "text warning" must cover 40% of the second most visible surface of tobacco product packaging. There are a total of 14 text warnings and they are to be rotated so as to appear on an equal number of packages.
For other smoked tobacco products, the law does not align with the FCTC Art. 11 Guidelines because it does not require warnings to include a pictorial component, nor does it require the pictorial health warnings to cover at least 50% of the principal display areas.
