British American Tobacco - BAT’s view on regulation of reduced-risk products*†

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BAT’s view on regulation of reduced-risk products*†

Regulation for reduced-risk products*† a critical pathway to reducing combustible tobacco-related harm

Tobacco harm reduction (THR) is a public health strategy that recognises the harm caused by combustible cigarettes. It aims to reduce the health impacts associated with cigarette smoking.

THR starts from the widely accepted proposition that most of the harm associated with conventional cigarettes is caused by inhaling the smoke produced by the combustion of tobacco – and not by nicotine itself.

For THR to be effective, there needs to be scientifically substantiated reduced-risk products*† (RRPs) that are available and accepted by adult consumers, together with adequate regulation and vigorous enforcement by Government.

Regulators are increasingly accepting the value of THR, implementing progressive laws that acknowledge the benefit of RRPs and the role they can play in reducing smoking incidence and the negative health impacts of combustible cigarettes.

We have a legitimate contribution to make to policy-related matters around THR and we are committed to transparently sharing our regulatory views about RRPs with our stakeholders.

Our views on the regulation of reduced-risk products*†

We believe that each reduced-risk product*† category should have its own regulatory definition/categorisation and that science should guide the development of evidence-based and risk proportionate regulation for each category.

A general regulatory framework, to maximise RRPs’ harm reduction potential, should be in line with following four regulatory principles:

ADULT CONSUMERS

  • The use and sale of nicotine products by and to the underage should be prohibited by law.
  • Age-verification mechanisms should be mandated at point of purchase and, where feasible, regulation should aim to encourage the integration of access prevention features and technologies into the devices.

PRODUCT QUALITY FOR CONSUMERS

  • Quality and safety standards should be at the heart of any regulation. Appropriate quality and safety requirements should be mandated by law and enforced accordingly.
  • Products should be used as intended by consumers and manufacturers should be required to ensure that all products are tamper-evident to secure product integrity.

CONSUMER RELEVANCE

  • Nicotine levels should be established to balance the need to offer adult smokers satisfying alternatives to smoking while minimising potential harm from accidental ingestion by non-users.
  • Adult relevant flavour range should be available. Evidence shows that certain flavours help smokers transition to reduced-risk alternatives*† and prevent them from relapsing into smoking. Flavours or descriptors that are particularly appealing to minors should be prohibited.

CONSUMER AWARENESS

  • Communication with adults should be permitted just in adult-targeted touchpoints. Communication is necessary to provide adult tobacco and nicotine consumers with accurate information about reduced-risk products*†.

Our guiding principles

In all markets, whether these regulatory principles are in place or not, we are guided by our Product Stewardship approach -with regards to quality and safety standards- and our International Marketing Principles to ensure that we market our products responsibly.

* Based on the weight of evidence and assuming a complete switch from cigarette smoking. These products are not risk free and are addictive.

† Our products as sold in the US, including Vuse, Velo, Grizzly, Kodiak, and Camel Snus, are subject to Food and Drug Administration (FDA) regulation and no reduced-risk claims will be made as to these products without FDA clearance.

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