Gilles Michel discusses Mayr-Melnhof Packaging’s plans for the recently acquired Tann Group.
TR Staff Report
In January, Mayr-Melnhof Packaging (MM Packaging) concluded its purchase of the Tann Group from its former family shareholders. The deal strengthens MM Packaging’s position in cigarette packaging with capabilities in tipping paper, which is technically closely related to the company’s existing business.
The Tann Group prints and finishes externally sourced paper and is a global leader in cigarette tipping products.
The Tann Group now operates as part of Mayr-Melnhof Cigarette Packaging, which is led by Gilles Michel. With nearly three decades of experience in the packaging and printing industry, Michel has managed MM Packaging’s cigarette packaging sales for approximately 15 years and, prior to that, he managed several of the company’s production facilities.‘
Tobacco Reporter asked Michel about MM Packaging’s plans for the Tann Group.
Tobacco Reporter: What was the rationale behind the acquisition?
Gilles Michel: We are connecting two leaders, Mayr-Melnhof Packaging and [the] Tann Group. Both companies produce their products—hinge lids/packaging and tipping paper, respectively—from fiber-based substrates: carton board and paper. There are considerable parallels between our businesses, including the fact that we use the same technologies.
Concentrating both products and activities in a unit is a perfect fit and creates a worldwide unique bundling of graphic supplies for the cigarette industry. This, in turn, helps meet the industry’s ever-rising demand for complex and innovative solutions in ever-shortening cycles.
What will change, and how are you going to concentrate strengths?
While keeping the established brands Tann Group and Mayr-Melnhof Packaging unchanged, we are going to become a single-stop shop for packaging and tipping paper with one voice to the customer and a close, experienced ear to the market. Our first common presentations as well as our joined appearance at the recent World Tobacco exhibition in Dubai were very positively received by our customers.
After a few months of cooperation in this new setup, it has become evident that we are building on a strong company culture and common understanding based on best practice in operations and innovation with a long-term dedication toward market success.
What are the current market trends, and how are you responding to them?
The industry is more and more driven by fast reaction times—in some countries driven by regulation, in others by competition. Demand has become more volatile over the course of the year, with an increase in complexity.
We are determined to stay on top of this ongoing transformation, building on a very strong customer base and a worldwide reach, as well as a highly motivated workforce that is dedicated to utmost flexibility.
While market volume is obviously dropping in line with decreased smoking prevalence, the outlook for value is more positive due to the cigarette producers’ increased focus on differentiation, branding and innovations such as HnB [heat-not-burn products]. Customers are upgrading their products, and we are offering a wide range of innovative solutions. The range goes from complex multicolor effect prints using special varnishes such as “soft touch” and includes innovations enhancing the design, such as laser imaging or delivering a multisensory experience. In addition, the trend toward haptic experience and aromas continues, and we cater to it with outstanding solutions.
Furthermore, interacting and communicating with the consumer via various functionalities is increasingly gaining attention. This comprises, for example, surface features that directly address the human senses.
On the other hand, cigarette machines are getting faster and faster. This means that the quality of packaging and tipping paper in terms of physical, mechanical and dimensional properties is absolutely crucial.
Last but not least, national and international regulations for tobacco products are becoming stricter. It is our challenge to follow these regulations by developing precise compositions and constructions of packaging and tipping paper without big room for variations. At the same time, we are obliged to maintain a qualitatively outstanding optical appearance of our products.
Looking forward, what are your plans for capital expenditure and expansion?
We remain committed to investing in new machinery and upgrades along with market demand and in line with customer requirements. Our biggest investment recently has been into a state-of-the-art factory in China, Tann Longyou, further positioning us as a leading supplier of tipping paper in the People’s Republic of China.
Moreover, we aspire to bring packaging machinery to our sites, which currently cover only tipping paper, with the aim to add value and service.
Certainly, speeding up performance based on quality, service, efficiency and innovation will continuously affect all operations. The reorganization of internal logistics and packaging is to play a major part involving more projects in automation and digitalization. This way, we will be able to even better support our customers in achieving success in their markets.
How would you describe your personal imprint on these undertakings?
Having been on the sales side of the business for the past decade and a half, I intend to keep solution orientation and close customer contact central to our approach along with a focus on the performance of our asset base.
Our mindset will continue to be characterized by trust, passion, highest product quality, a global perspective and the drive to innovate. Together, these values will take us and our customers to the next level.
Boris Wintermans reflects on the success of Royal Agio Cigars.
By Brian Ledtke
Royal Agio Cigars may or may not be a name you’ve heard in the United States, but for those in Europe, you’ve probably heard of them before. After all, this company has been around for 115 years, despite being relative newcomers stateside. But with the release of their Balmoral Anejo XO cigar line five years ago and the 2019 release of a collaboration cigar with Litto Gomez of La Flor Dominicana Cigars, suddenly the U.S. market is abuzz.
Sitting across from me at the Royal Agio Cigars booth at the 2019 International Premium Cigars and Pipe Retailers (IPCPR) convention in Las Vegas, Nevada, USA, is current president, Boris Wintermans, the great-grandson of founder Jacques Wintermans. Boris Wintermans is eloquent and passionate about the cigar industry, which is evident not only in how he speaks but also in the way his piercing blue eyes light up when he talks about cigars. But it’s not only his love for cigars that makes Boris interesting; he also has a zeal and curiosity for discovery, and he certainly loves to live life on the edge.
“I like to be inspired by new experiences, whether it’s smoking a cigar or trying out a new motorcycle,” Wintermans says as he lights up a Balmoral Anejo XO Nicaragua. “I like to try new things, enjoy life and live in the moment.”
The Netherlands-based company was founded by Jacques in 1895 using 200 Dutch guilders—about $100. Four generations later, this small entrepreneurial company has become the fourth-largest maker of natural wrapped cigars in the world, making about 800 million cigars, and employs over 2,300 people.
However, Wintermans’ passions initially didn’t lead him into the cigar industry, despite growing up around tobacco.
“I probably smoked my first cigar when I was 3 years old or something,” Wintermans says, laughing. “Just kidding. But I was born into the cigar environment. I don’t know whether it was nature or nurture, but somehow it got into my system.”
After working in the family factory during his teenage years, Wintermans attended university for advertising, and after finishing school, he went backpacking for three months in South America where he visited tobacco plantations, which he says led him on a trail of discovery.
Shortly after returning to the Netherlands and working in the advertising business for a brief time, Wintermans decided the nine-to-five life wasn’t for him, and it wasn’t long after that Royal Agio Cigars offered him a position that he readily accepted.
“I wasn’t forced into it,” Wintermans says. “If I ever want to pass this on to my kids, it will have to be their choice. I just want them to be happy, and if it happens to be in the family business, that’s awesome. If it doesn’t, I’m never going to push anybody into a mold.”
Wintermans recalls being on a sailboat in the Mediterranean with his father when he was about 20 years old, smoking one of their first long-filler cigars, a Balmoral. He remembers it was that moment that really began his love for the industry: “Just enjoying the moment, having a nice Churchill, sitting there, and just enjoying the hell out of that cigar.”
Royal Agio Cigars has been in the U.S. market for quite some time now with their other brands (Panter, produced since 1935, and Mehari’s, produced since 1976), but it was their Balmoral premium handmade cigar line that started turning heads about 5 years ago.
The first Balmoral cigar Wintermans blended was the Balmoral Anejo 18, which used an 18-year-old Brazilian wrapper, and it was a huge hit. Unfortunately, the tobacco used in that cigar was extremely limited, and the company soon ran out, prompting Wintermans to begin planning a follow-up—the Balmoral Anejo XO.
“The Balmoral Anejo XO was the cigar that really put us on the map,” Wintermans says. “What we always try to do with our Balmoral cigars is just start on it and basically see where it ends. We have our curiosity; we want to discover new flavors, new tastes, and that takes us in a certain direction. What we don’t want to do is create something that’s already out there. You sometimes have to smoke 100 samples to get it right.”
Wintermans followed up the Balmoral Anejo XO with the Anejo XO Oscuro to take the Balmoral line in a different direction taste-wise and to surprise not only consumers but also himself. The same can be said for the next cigar in their lineup: the Anejo XO Connecticut, which isn’t your normal mild Connecticut cigar but one with an extra punch that will appeal even to the seasoned smoker. The Balmoral Anejo XO Nicaragua, released in August 2019, rounds out the Balmoral lineup and features a gorgeous sun-grown Nicaraguan Habano wrapper.
However, it was the cigar released just last year and the subsequent follow-up this year that created a buzz that even Wintermans didn’t expect. Last year, Wintermans teamed up with Ernesto Perez-Carrillo of EP Carrillo Cigars, under the newly released Balmoral Serie Signaturas collaboration platform, to create the Balmoral Dueto, which received a mountain of accolades. But this was just the beginning.
This year, Wintermans announced the second Serie Signaturas release, Paso Doble, a collaboration with Litto Gomez of La Flor Dominicana Cigars, which sent shockwaves through the industry. The buzz around the IPCPR tradeshow this July was one of shock: Gomez never collaborates … how did Wintermans convince him?
“Well, we said, ‘Litto, do you want to work with us? We might have a spot left. We may be able to squeeze you in,’” Wintermans jokes. “No, we’ve had a relationship for a few decades now, and we’re not the average guy making cigars. Litto, being a curious guy as well, likes to explore different routes and paths, and he was also keen to see where it could take us.”
“This is not something we normally do—in fact we never do it,” Gomez says, “but for Boris, I made an exception because we share the same simple philosophy: to be the best and do things the right way.”
The Balmoral Serie Signaturas Paso Doble combines each cigar maker’s tobaccos and intertwines them into a balance of flavors that stays true to each cigar maker’s signature blending style—the dark, full-bodied richness of La Flor Dominicana and the sophisticated, balanced intricacy of Balmoral cigars.
“You start out on a route and you create something special, and all of a sudden, people start noticing it, start tasting it, give you positive feedback, and I think that’s one of the most valuable things you can do,” Wintermans says. “That’s what we’re doing it for. It’s nice that people are engaged in the same journey we are.”
If you’ve noticed Wintermans mentioning “journey” and “curiosity” often, it’s because he does. Those words are very much a part of him and what make up his life’s philosophy: “Every day is a new opportunity to try something different. When is the last time you tried something for the first time?” His philosophy has segued itself into Balmoral’s social media hashtag: #CuriosityDrivesDiscovery.
And discover Wintermans has—racing motorcycles and cars, running triathlons, starting a band and even competing in a boxing match.
“With the racing and the boxing, it’s all about thrill, the speed, about taking some risks, but it’s also about just starting something and enjoying it for what it is,” Wintermans says. “And that is what is at the core of our brand.”
Aside from thrill-seeking and cigars, Wintermans’ family is also in the high-tech business—3D printing metal and supplying it to the aerospace and car industries. For now, his brother mostly runs that side of the family business, and Wintermans focuses on cigars, but when asked if he has ever thought about moving to the high-tech business, he pauses to think for a moment and then replies, “It’s an awful lot of fun, but I’m liking the cigar industry.”
It’s Wintermans’ curiousness and love for discovering new things that has brought him to where he is today, and it’s that same passion that will propel him, Balmoral and Royal Agio Cigars into the future.
“Life is not about the end goal; it’s about the process as much as doing what we love to do,” Wintermans says, looking down at his half-smoked Balmoral cigar. “And this is the one thing that’s remained a constant in my life. I’ve switch from one thing to another, but cigars have always been a constant in my life and in my family after four generations.”
This year’s Global Forum on Nicotine focused on how to take tobacco harm reduction mainstream.
By Stefanie Rossel
The sixth edition of the Global Forum on Nicotine (GFN), which took place in Warsaw, Poland, June 13–15, was once again the meeting point for multiple stakeholders, ranging from consumers and scientists, regulators and manufacturers to distributors, public health professionals, policy analysts and parliamentarians.
The theme of this year’s event, “It’s time to talk about nicotine,” examined how attitudes toward the use of nicotine are changing and considered some of the compound’s potentially beneficial uses. The three-day conference started with several satellite meetings that focused on topics such as the demystification of scientific modeling and the integration of tobacco harm reduction (THR) into everyday healthcare.
Being staged for the third time, the International Symposium on Nicotine Technology informed participants about the latest technological advances in the rapidly changing landscape of nicotine-delivery systems. Again, the GFN was accompanied by a film festival, which focused on the turnaround in New Zealand, where vaping has been acknowledged as a quit-smoking tool, and the role of nicotine around the world. Alongside the symposium, scientists provided poster presentations of the results of their work related to nicotine and smoking cessation.
The plenaries and partly parallel sessions of GFN 2019 investigated how reduced-risk products (RRPs) could best be taken mainstream, not only in geographical and socioeconomic terms but also with regard to vulnerable and hard-to-reach groups of society. The event made it clear that regulation will be key to the success of THR.
In order to shape realistic regulation of tobacco products and RRPs, however, GFN speakers agreed that a broader base of scientific evidence will be required. The harms and risks of nicotine are an essential consideration in assessing the public health impact of nicotine-based harm reduction. One of the science plenaries hence looked into understanding the effects of nicotine on the human body and the psyche.
Public perceptions of nicotine are at best cautious but mostly negative. Government positions on the substance and its delivery systems vary widely around the world. In the U.K., vaping is endorsed as a means of quitting in the “Switch” campaign. The United States is focusing on the prohibition of flavors in e-liquids. China, on the other hand, is the world’s largest producer of e-cigarettes, but vaping prevalence remains low there.
Smokers use nicotine because it offers positive effects. Nicotine can potentially affect every organ system of the body since it mimics the neurotransmitter acetylcholine. As numerous studies have shown, the substance provides a number of benefits, including anxiety relief, increased alertness and improved cognitive function. Without combustion, long-term nicotine use, while not harmless, is much less hazardous than cigarette smoking. The harms of long-term nicotine inhalation without tobacco combustion have not been determined yet and need to be studied. Major safety concerns for nicotine are related to addiction, cardiovascular disease and reproductive toxicity.
Despite these negative effects, experts generally have no concerns if smokers switch to e-cigarettes and stay with them for the rest of their lives. After all, nicotine-replacement therapy (NRT) products have been accepted as safe and an effective means to wean smokers off combustible cigarettes. This gives reason for hope that in a second step, vapor products will become acknowledged as the new, better products for smoking cessation. According to studies, even dual use could translate into significant harm reduction.
Correct research needed
To accelerate the cause of THR, it is essential to reverse the proliferation of junk science, according to GFN participants. Riccardo Polosa, director of the Center of Excellence for the Acceleration of Harm Reduction at the University of Catania, Italy, called for a resurrection of vigor in THR research. He singled out preclinical in vitro research and animal studies, clinical research, and epidemiology surveys as areas where corrective measures were needed.
To improve the quality of science, Polosa suggested taking advantage of big data and the internet of things. This would permit researchers to capture real-time data and create a cloud platform for behavioral research. Additionally, he recommended creating an expert working group to draft international guidelines setting recommendations for better, high-quality studies.
Brad Rodu, a professor of medicine and holder of the Endowed Chair of Tobacco Harm Reduction Research at the University of Louisville, Kentucky, USA, warned against forever preserving historical, flawed studies. He cited a 1981 U.S. study linking smokeless tobacco to oral cancer that triggered an enduring campaign against the entire product category. What is not widely known, according to Rodu, is that the researcher looked at powdered dry tobacco—a rare product used by only a handful of people. Even though subsequent studies found different results for more commonly used smokeless tobacco products, the findings of the 1981 study continue to taint the entire category.
Of good and bad examples
Almost two decades after the invention of the e-cigarette, the international perspectives of THR differ greatly. Japan, where heat-not-burn (HnB) products were introduced in 2014, continues to stand out as an example of risk reduction in action. According to Hiroya Kumamaru, vice director of the AOI Universal Hospital in Kawasaki, Japan, overall tobacco consumption kept decreasing in 2018 as cigarettes were quickly replaced by HnB products.
Cigarette consumption dropped from 197 billion units in 2012 to 133 billion sticks in 2018, whereas retail volume of HnB consumables stood at 34 billion in 2018. Studies in Japan have not shown evidence of a “gateway effect,” where users of HnB products migrate to combustible cigarettes. Nevertheless, physicians see even more potential in e-cigarettes—which are currently banned in Japan if they contain nicotine—as smoking cessation tools.
In the U.K., vapor products have been officially recognized as cessation tools, but many health professionals remain reluctant to support would-be quitters with e-cigarettes. At the other end of the scale is Australia, which takes a dim view of tobacco harm reduction. Despite its strict tobacco control policies, including plain packaging and the world’s highest cigarette prices, Australian smoking rates have not significantly declined since 2013. According to Alex Wodak, president of the Australian Drug Law Reform Foundation, 15.2 percent of Australian adults still smoke compared with 16 percent in 2015.
At the same time, Australia permits the sale and use of nicotine liquid only with a prescription—but doctors are hesitant to prescribe nicotine liquids because vapor products are regulated as tobacco products. Violators face fines of up to aud45,000 ($30,923) and two years in prison. In 2016, only 1.2 percent of adult Australians vaped, with 0.5 percent vaping daily.
An example of how increased consciousness of THR can be implemented in a low-income country comes from Malawi (also see “A Blank Slate,” Tobacco Reporter, June 2019), where social scientist and THR advocate Chimwemwe Ngoma has installed an information dissemination project on THR and science. One of its targets has been to source and disseminate evidence-based information on THR to the general public. The project has succeeded in igniting THR discussion in the African state. The project has created more than 15 partnerships with organizations and individuals.
Reaching the hard to reach
While bringing THR to lower-income countries will be a major challenge in the future, higher-income countries in which RRPs are already present are confronted with the question of how to best get safer nicotine products to vulnerable and hard-to-reach populations, which tend to have higher rates of smoking than other parts of society.
As Kevin McGirr, clinical professor at the University of California San Francisco School of Nursing, explained, it is vital to understand the meaning and the culture of smoking in these communities and to take a psychological and neurobiological approach. In contrast to the middle-class white population where the peer pressure to quit smoking is continuously growing, people from vulnerable populations, especially those with mental health issues, face less such pressure. In these communities, THR takes on another dimension, circling around questions such as how far mentally challenged people can handle vapor products as well as around questions regarding access and cost—and what happens if a program to make these populations switch to e-cigarettes ends?
Sarah Cox, trial manager at the London South Bank University’s Centre for Addictive Behaviours Research, looked at smoking and homelessness in the U.K. and found that smoking is considered a “nonissue” as there are so many other problems, meaning that the more problems a person seems to have, the less cessation help they will get. A positive outcome in THR, Cox’s studies have shown, is increased by person-to-person contact with the cessation helper as well as behavioral support. Barriers include an underestimation of the clients’ desire to change and little faith in their recovery on the helpers’ side; on the smokers’ side, contact with other smokers is the biggest obstacle.
Rebecca Ruwhiu-Collins, THR lead for New Zealand’s only indigenous Maori public health unit owned by tribes, presented her strategy to help the Maoris switch to RRPs. New Zealand is aiming to be smoke-free by 2025, which means that smoking prevalence is to be brought under 5 percent. Because stop-smoking support programs developed for white people turned out not to work for the indigenous population, Ruwhiu-Collins developed a dedicated Maori wellness-based model that empowers the people to lead. Instead of promoting NRTs that have not proven successful, the program recognizes that vaping is a legitimate tool to help established smokers quit. According to Ruwhiu-Collins, the model has helped many Maoris stop smoking. Last year, New Zealand became the first country where all RRP categories are available.
Once more, the GFN 2019 made it clear that the road to success for THR is tied closely to regulatory framework for reduced-risk products. Already, there is plenty of evidence showing that an accommodative legal framework results in higher levels of smoking cessation than a “quit-or-die” approach. As David Sweanor, chair of the advisory board of the Centre for Health Law, Policy and Ethics at the University of Ottawa in Canada, put it, “Where else do we permit a really deadly product but try to restrict access to safer ones? Unfortunately, the people who say, ‘our fight is against big tobacco companies’ are the ones who are protecting cigarettes.”
Does industry funding taint the work of think tanks?
By George Gay
Now here’s a thought: Given that there are apparently thousands of think tanks in the world, is it reasonable to assume that thinking comprises one of the least productive sectors of all? Think about it. How many meaningful, original thoughts are generated worldwide each year by the members of independent think tanks that come within the definition of such organizations in the country or countries in which they operate?
If, like me, you’re having difficulty even guessing at an answer to the question above, it’s probably because such organizations aren’t always easy to identify. As far as I can see, any think tank operating in the countries where the bulk of these organizations are based (throughout North America and Europe) can be involved in one or more of a whole string of activities, including but not limited to advocacy, consultancy, lobbying and research. And although, because of the tax status of these organizations, their activities are generally subjected to limits in some areas, such as politics, it would seem that these limits are, shall we say, tested at times. Think tanks can have wide-ranging interests, or they can be little more than single-issue pressure groups.
Generally, the benign view of think tanks is that they comprise experts in various fields who use their expertise to try to solve problems that arise in those fields. Some view them, however, as more malign—organizations that push, sometimes using dodgy data as well as business and social agendas that are a response to invented problems and that are aimed at advancing the interests of only a minority. The reality is probably that they exist on a continuum that runs from one such extreme to the other.
One contentious issue that sticks to the bottom of think tanks’ shoes has to do with funding. Are they funded by people and organizations that approve of the views they expound? Or are those views guided by the source of the funding the think tanks can muster?
The impact of donations
In November 2018, The Guardian published a story by Jessica Glenza that was introduced with the statement that more than 100 free-market think tanks (FMTs) from North America to Europe and South Asia took positions helpful to the tobacco industry or accepted donations from the tobacco industry. A strap line said, “How tobacco industry donations cloud debates over cigarette controls” while the first paragraph said, “Free-market think tanks around the world provide a powerful voice of support to cigarette manufacturers in battles against tougher regulations, a Guardian investigation shows.”
I don’t have strong views on FMTs because I simply don’t know enough about them, and, since they operate in different jurisdictions, it is not easy to make generalizations. But my interest was raised by the use of the word “or” in the writer’s opening statement, and one thing led to another …
The tobacco manufacturers quoted in the story, on the other hand, responded to the more pointed idea behind the strapline: How tobacco industry donations cloud debates over cigarette controls. The manufacturers basically said that they supported think tanks that already opposed policies that did not achieve what was intended and that were inimical to conducting their businesses efficiently in a competitive environment. And the response of the FMTs was that they did what they did regardless of who was funding them.
The amounts of money that were mentioned seemed to support the idea that the FMTs were not in the pay of tobacco manufacturers. Even assuming that the manufacturers were wrong in apparently claiming that ideas are not for sale, it seemed unlikely that the amounts reportedly on offer would turn heads or buy too many great ideas, although it has to be said that the information on funding was patchy—because of a lack of transparency according to one side of the argument and because of the need to uphold democracy or some such on the other. From my reading of the results of The Guardian’s research, not all FMTs covered were found to have accepted tobacco industry funding, but I wasn’t certain whether, in individual cases, that was due to a lack of information, the fact that they weren’t offered such funding, or that they were offered it and refused it.
Worthy of debate
Interestingly, the issue mentioned most often as the one that FMTs had become involved in had to do with standardized packaging, which the FMTs oppose. I say this is interesting because it can be used as an argument for supporting the idea that the FMTs are in league with the tobacco industry, while, just as legitimately in my view, supporting the view that these organizations are looking at a wider picture. Yes, standardized packaging has been focused on the tobacco industry, but there can be little doubt that those in other industries are feeling the cold winds of such policies.
And it also has to be said that standardized packaging is a subject worthy of debate. It would be ridiculous to assume that governments could introduce such a radical, largely unproven policy that seems to run counter to ideas of commercial freedoms and free speech without somebody at least saying, “Wait a minute. Perhaps we should take another look at this.”
The second most-mentioned issue overall was cigarette taxes—though, if my adding up is anything to go by, this was the main issue in North America, possibly because FMTs there were opposing rises at the federal and state levels. Again, this can be interpreted in two ways. One is that this was about cigarette taxes and therefore supportive of the tobacco industry. But it is also in line with the nature of the FMTs, which are generally against what they would see as burdensome taxes and regulations aimed at the redistribution of wealth downward.
As with the question of standardized packaging, there is surely no surprise that there is a debate about taxes. In fact, it would be wrong if there were not such a debate, and for there to be a debate, there have to be naysayers.
Overall, the FMTs looked at some issues in ways that would be supported, I believe, by a fair number of people who are opposed to tobacco and tobacco manufacturers. For instance, some FMTs opposed the denormalizing of smokers and some supported the liberalizing of vaping regulations. Some would probably have even lent their support to arguments, made by at least by one FMT, against higher health insurance costs for smokers, but only those tending toward more libertarian views would have gone along with arguments against smoking bans and the raising of the minimum age at which people should be allowed to buy tobacco products. Clearly, more eyebrows are going to be raised when the issues being addressed by FMTs are more narrowly focused—opposition to a ban on the use of menthol in tobacco products, for instance, and support for the commercialization of the IQOS brand in the U.S.
Of course, while it might be correct, as some believe, that it is ridiculous to imply that supporting an FMT would result in its taking action it otherwise would oppose, you have to ask the question: What would happen in the case of an FMT that was formed of people who were generally free trade oriented but neutral in respect of a certain issue, say standardized packaging as it applies to tobacco products, and that was offered money by a tobacco manufacturer? Might it be swayed? And you cannot rule out the possibility that an FMT, especially a new one or one having difficulty raising funds, might latch on to pro-tobacco issues with the hope of obtaining tobacco funding.
Effectiveness
One thing that I found most difficult to gauge was the critical question of how successful these FMTs were in changing minds or, given largely sympathetic right-wing governments, at holding the line. I would guess patchy. My observation seems to indicate that the denormalization of smokers has been laid to rest, but then it was morally repugnant and so it was an easy target. With standardized packaging and taxation, FMTs possibly still have their fingers in the dyke, but they seem largely dead in the water when it comes to minimum age requirements and smoking in indoor public places.
Need people unconvinced by free trade thinking fear the work of these FMTs? In some respects, I think not, because I believe the FMTs’ thinking is too rigid. Thinking should be robust but not rigid, otherwise the brains of the thinkers will atrophy. Thinking, to my way of thinking, is about change, and I believe the whole free market agenda has been coasting for years in the wake of ideas put into practice by Ronald Reagan and Margaret Thatcher—ideas that have lost any buoyancy they ever had. Some of these FMTs seem to have become dogma tanks.
But they cannot simply be shrugged off. Their ideas don’t have to be new and shiny to influence the already committed legislator, and they don’t have to hold up the introduction of a tobacco tax rise for too long to make them attractive to manufacturers. And that is why I would come down on the side of the argument that says that whenever FMTs are involved in lobbying, they should be required to declare who their backers are, even if not how much funding those backers are providing—after all, that can be guessed at.
Of course, now you want to know what I mean by “lobbying.” Sorry, I seem to be out of words.
Why live events continue to matter even in an increasingly digital world.
TR Staff Report
Despite the rapid evolution and accepted benefits of virtual trade fairs (VTFs), reports of the traditional “live” events’ death have been greatly exaggerated. As preparations continue for TABEXPO 2019, which will be held in Amsterdam this November, we looked at some of the reasons why “full-bodied” business gatherings continue to survive and thrive.
VTFs have been around since the mid-1990s. For many companies, especially small and medium-sized enterprises, the benefits are clear: Virtual events are almost always cheaper, easier to plan and set up, and more convenient for visitors to attend, regardless of their locations. All you need is a computer or a mobile device with an internet connection. There are obvious savings in staff time, transport and accommodations.
In theory, every business-savvy organization should have junked its banners and booth equipment by now and become fully virtual. So why are there still over 10,000 trade fairs and events annually all over the world?
According to the 2019 Oxford Economics and Events Industry Council report, in 2018 exhibitions alone generated $136.9 billion in direct spending worldwide, with almost half of that expenditure in North America. Everything from building materials and beauty products to food and fashion appears to get its “15 minutes of fame” under the bright lights of a bustling exhibition center somewhere in the world. In an industrywide report commissioned in 2018 by Bizzabo, a New York-based global leader in event software, 84 percent of business leaders responding believed that in-person events were a critical component of their company’s success.
Product-focused businesses, including those in the tobacco and nicotine industry, are particularly likely to prefer a live exhibition. Food and drink, textiles, jewelery and many other industries need live visitors to see, taste, smell and touch these types of products in order to gauge quality and weigh “wantability.”
But there is an even deeper motivation, and Aristotle nailed it centuries ago: “Man is by nature a social animal,” he said. In marketing psychology, it’s called “propinquity.” Potential customers interacting with your brand in real time, face to face with another person, are more likely to build rapport with the brand and go on to establish a real relationship. Research has also shown that people value a product more highly if they are physically in the same space with it.
Perception is also important—miss a trade show and rumors might begin to circulate that your company is not in buoyant health. The “grapevine” also flourishes at live events, with chance meetings and informal conversations often providing gems of information that might not be elicited on a conference call via Skype or set down in an email.
In truly global businesses such as tobacco and nicotine, the personal connection and subtle cues of body language can leap across language and technology barriers. “There’s an energy you feel when you walk into a busy exhibition space,” says Barbara Hicks, director of TABEXPO 2019 and several previous TABEXPO events. “People are moving around, talking, sharing; that buzz isn’t there when communicating through devices.” Friendships forged over decades and across continents are still common in these industries, and many visitors come to keep up these connections.
TABEXPO 2015 in London filled over 5,000 meters of exhibition space, featuring 114 traditional tobacco companies and 42 e-cigarette and next-generation product purveyors.
Its accompanying two-day congress, which featured headline-making speakers, attracted high-quality visitors. TABEXPO 2019 in Amsterdam will have the same high-potential atmosphere. Shaking hands, exchanging greetings, making eye contact, talking about place, people and products, chatting over coffee or a glass of wine. This is the global marketplace in action—a true meeting of minds and motivations.
Despite the approval of IQOS, the FDA’s premarket application process is still flawed.
By Michael McGrady
At the end of April, the U.S. Food and Drug Administration (FDA) approved Philip Morris Products’ premarket tobacco product application (PMTA) for the company’s heat-not-burn device known as the I Quit Original Smoking system, or IQOS. An FDA press release states that the agency recognizes the potential improvement for population-level public health by authorizing such a product due to how heat-not-burn (HnB) systems work.
HnB systems, as we know, heat the tobacco instead of burning it, providing a cleaner nicotine-delivery system. “The agency determined that authorizing these products for the U.S. market is appropriate for the protection of the public health because, among several key considerations, the products produce fewer or lower levels of some toxins than combustible cigarettes,” the FDA admitted.
This is an astounding and surprising move by the FDA. However, there is still the elephant in the room. While the IQOS approval is undoubtedly a step in the right direction for the post-Gottlieb regulatory environment, the premarket approval process is still dangerously flawed and inefficient.
When the Obama-era Tobacco Control Act of 2009 granted the FDA the power to regulate all nicotine-containing products under the deeming provisions, the law additionally encouraged the implementation of a regulatory framework that prohibits new and modified products without agency approval. Premarket approval regulations, as promulgated by FDA guidance, cover every aspect of a tobacco product or deemed product. From the risk the product poses to health to the design of the label, a PMTA covers virtually every aspect of a product’s configuration.
According to a recently published position paper titled, “The Public Health Rationale for Recommended Restrictions on New Tobacco Product Labeling, Advertising, Marketing and Promotion,” the FDA justifies a broad regulatory query as a process that is vital to protecting not only general public health but also the country’s youth.
“Given the level of evidence indicating the direct and powerful impact of tobacco marketing on youth
tobacco use, and FDA’s statutory mandate to protect young people from the dangers of tobacco use, it
is both reasonable and critical for firms to submit planned labeling, advertising, marketing, and
promotional materials and plans for new tobacco products that are seeking or have received premarket authorization, and for FDA to place restrictions on the marketing of such products,” the agency’s position paper concludes.
While this justification is admirable, and many in the industry are employing self-regulatory measures and industry standards for marketing, product labeling, transparency as the FDA wants, the structure of the PMTA law still provides a case for government-supported market inefficiency.
PMTAs are designed to require a standard of substantial evidence that a current or new product was designed with relative risk. By consequence, the PMTA applications process requirements kick in and send product manufacturers and marketers down an expensive process.
Agency estimates put the cost of each PMTA at $300,000 per product application. Other calculations put the cost estimates into the millions. Timeframes for application reviews also average from 500 hours to 1,700 hours. At a minimum, that is about 63 days of review per product application. Applications for products that claim to offer modified-risk scenarios during use have yet to be approved despite overwhelming evidence suggesting a reduced-risk case.
However, in my opinion, the key reason why the PMTA regulation is still so inefficient is how it interacts with safety development in vapor products. For starters, consider the controversy surrounding the FDA’s block of safer e-cigarette products.
In October 2018, Joyetech released its eGo AiO to Canadian markets. This device is one of the very first to receive a safety certification that complies with Underwriters Laboratories’ (UL) 8139 standards for the manufacturing of electronic nicotine-delivery systems. UL 8139 is also a manufacturing standard that was not borne from a government agency; rather, UL coordinated with members of the industry to create a safer device.
PMTA rules prevent Joyetech from selling that product due to the process for approval. In an interview with NBC News around the release of the eGo AiO, Joyetech’s chief regulatory and compliance officer, Joshua Church said, “We’ve been frozen out of the U.S. market by the FDA, whose last concern is product innovation. So, we’re sitting here stuck in the water.” Given this design, the regulation is structured to prevent further inefficiencies when receiving a compliant status for a product.
PMTA rules also present several scenarios for concern when they conflict with the statutory mandate of other federal regulators. The Child Nicotine Poison Prevention Act (CNPPA) is a little-known product safety law that requires child-resistant packaging on liquid nicotine containers. The CNPPA is enforced and interpreted by the federal Consumer Product Safety Commission (CPSC) following the regulatory framework outlined in the Poison Packaging Prevention Act (PPPA). Since the CNPPA has gone into effect and the commission has promulgated rules, the requirements for liquid nicotine packaging have grown more stringent.
In the latest round of enforcement, CPSC leadership has begun interpreting the CNPPA requirements for packaging to include flow restrictors and provided guidance that mandate that all e-cigarette packages feature these new safety implementations. According to an analysis written on this issue by regulatory attorneys at Keller and Heckman LLP, this interpretation of rules could dramatically impact firms that are not compliant. “Companies with products that do not have both child-resistant closures and flow restrictors may be required to cease sales and initiate product recalls until their packaging is brought into full compliance,” the Keller and Heckman analysis indicates, additionally noting that changes to packaging may trigger the FDA’s PMTA requirements.
While the analysis was optimistic that the PMTA requirements would be waived to ensure product compliance with other areas of federal law, the FDA does not have the greatest track record of cooperating with the industry or its fellow regulators. Per a memorandum of understanding, the FDA and CPSC have intentions to work together in overlapping regulatory efforts. This, however, does not mean that the FDA will not attempt to add more requirements related to packaging configurations to put product manufacturers at higher levels of scrutiny during the PMTA process.
A remedy for many of the disputes outlined in this piece would be for the FDA to reinterpret the Tobacco Control Act to permit greater flexibility for the industry to voluntarily reach higher levels of safety. Existing rules are likely to stay the same as a part of the continued crusade to fight to a so-called youth vaping epidemic. If this holds, the only remedy would be a legislative fix that could come at a slower rate than amended agency guidance. Regardless, the PMTA still serves as an example of inefficient regulatory power that places industrial input last.
In debating the relative health risks of various nicotine products, one consideration trumps all others.
By Clive Bates
What is the best alternative to smoking cigarettes? Unless we are allowed the answer “not smoking cigarettes,” then sadly this is the wrong question. We are already seeing commentators and companies declaring they have the best product or being champions of vapor products, heated tobacco or snus—as though preferred product choice was like supporting a football team.
So, let’s be clear. There best alternative product to cigarettes is the one that works for a particular individual, at a particular time, in a certain setting, in a given jurisdiction. That will differ between people, and the same person will have different preferences at different times. There just isn’t a single best product.
The most important distinction from a health and public policy point of view is whether or not the nicotine product is combustible—i.e., whether the product is designed so that dried and cured tobacco is set on fire and the resulting smoke is inhaled. Almost everything else is incidental, a second- or third-order issue.
Choice and risk in the nicotine market
We are now seeing a spectacular expansion of choice in reduced-risk alternatives to smoking. Within the broad category of smoke-free products we can identify four subcategories (see figure). Within each of these four, there is rapidly advancing diversification driven by innovators, consumer demands and regulators.
Pure Nicotine
Tobacco
Heated Aerosol
Vapor products, e-cigarettes, tank systems,
e-hookah
Heated-tobacco products, hybrids
Unheated
Gums, lozenges, films, synthetic snus, NRTs
Smokeless tobacco, snus, snuff
These products represent a disruption in the tobacco and consumer nicotine marketplace. Even long-established products like snus are taking on a new role as awareness of the “Swedish experience” grows and the products are repackaged as “modified-risk.” These products are quite different from each other but, in my view, we should treat these smoke-free products in more or less the same way for policy, fiscal and communications purposes—as a broad noncombustible category of consumer alternatives to smoking.
There is nothing inherently superior in health terms about nontobacco products such as e-cigarettes compared with tobacco products such smokeless tobacco. Some appraisals, for example, Nutt et al, 2014, have suggested that e-cigarette use would be safer than smokeless tobacco use. But why? Smokeless tobacco does not involve lung exposure, but vaping does—couldn’t that create different risks than those posed by smokeless products? I’ll guess it is because the authors instinctively ranked any tobacco product as being inherently more dangerous than any nontobacco product because of some hunch about the “dirtiness” of tobacco itself. But there is no scientific basis for that.
The aerosol generated by heated-tobacco products may be more chemically complex than typical e-cigarettes—and potentially more hazardous. But is this difference a material concern for policymakers? I think it should make little difference. Heating hardly matters as long as there is no burning—that is, as long as the temperature of the tobacco stays safely below 350 degrees Celsius, the temperature at which combustion occurs. What matters is that the products are all much safer than smoking—the differences between the various smoke-free products matter much less than the difference between smoked and smoke-free products. Imagine there was a scale of harm ranging from 1 to 100, with combustible cigarettes being 100. Suppose noncombustible products are in the range of harms from 1 to 5. The relative difference between smoke-free products could be a factor of five—a large range—but in practice this is in a tiny absolute range at the extreme end of a spectrum of risks that includes smoking.
Some may object that, for public health reasons, we should concentrate on whatever noncombustible products is the least harmful and propose that as the preferred alternative to smoking. Why have any additional risk if it is unnecessary? While that logic is superficially attractive, it would not in practice reflect the public health optimum. To put it bluntly, the perfectly safe product that no one wants to use is of little value from a public health point of view. This is the reason why pharmaceutical nicotine products have not been a conspicuous consumer success, even though some are licensed for continued use for nicotine maintenance. For an alternative to smoking to succeed in public health terms, there has to be both substantially lower risk and people have to want to use it instead of smoking. For minor absolute differences in risk, then it will be worth making trade-off to widen the appeal.
Appeal and product diversity
This brings us to the fundamental point about tobacco harm reduction: appeal matters. And consumer appeal is what the consumer decides is appealing. For some, a product that is as close as possible to their smoking experience could be their ideal choice—and so they may choose a heated-tobacco product. Others may be trying to distance themselves from their life as a tobacco consumer and will welcome a fruit-flavored vapor product. For some nicotine users, the discreet use of a nontobacco oral product might be useful when smoking or vaping is inappropriate. In some jurisdictions, high taxes or regulations may shape consumer preferences, for example by making e-cigarettes more affordable than heated-tobacco products. For some, trying new flavors, products and techniques may be part of the experience, and industry innovators, if permitted, will find endless ways to cater to curiosity.
These consumer preferences may also change in response to marketing, to new studies and media stories, or through advice from other users or vape shops. Preferences are shaped by the environment as well as the consumer. What users find appealing may also change with the time of day or with the progress of a journey from smoking to being smoke-free lasting months or years. Nothing is fixed; product and brand loyalty is fluid.
How should all these diverse preferences be met? From a public health perspective, what each company does is less important than how the market as a whole presents diverse product choices to the consumer. We need a market that provides a wide range of attractive products, with a rapid pace of innovation and responsiveness to evolving consumer tastes. The shape of that market will depend in large part on regulation.
Regulation to support a diverse marketplace
The main threat to consumer choice in the smoke-free market is excessive and disproportionate regulation. The system defined under the U.S. Tobacco Control Act and administered by the U.S. Food and Drug Administration is a case in point. The premarket tobacco product application (PMTA) process is extremely burdensome, very slow and highly opaque. There are few firms that have the resources and capabilities to clamber over these extraordinarily high regulatory barriers to entry. The likely result will be extreme market concentration, dominated by large companies with the means to cross-subsidize their reduced-risk products from ongoing cigarette sales. There will be relatively few products, and these will be simple designs that can be more easily evaluated. The market will shift toward products that appeal to regulators rather than to consumers.
The challenge is to create a smoke-free marketplace that is shaped more like the beer market. That means a few super-brewers like Anheuser-Busch InBev with global brands, but with a range of medium-sized national and regional breweries, and a long tail of microbreweries making exotic beers catering for every imaginable taste. To shape the reduced-risk consumer nicotine market this way demands “risk-proportionate” regulation (see “The Principle of Proportionality,” Tobacco Reporter, December 2018) in which the regulatory burdens, controls, and taxation reflect the risk to the consumer. This would create the conditions for a flourishing smoke-free industry: low barriers to entry, a high degree of competition and a rapid pace of innovation.
Quantifying risk in a diverse market
If consumers have more choice but less risk, we have new challenges in understanding and measuring the overall health impact of the tobacco market. For a thought experiment, imagine you have a choice between two patterns of consumption for a community: 20 percent smoking and no one vaping or 10 percent smoking and 30 percent vaping. In the latter case, there is twice the nicotine prevalence but half the smoking prevalence. Which would be the better outcome for public health? In my view, the option with lower smoking prevalence is by far the better public health outcome, even though there are twice as many users.
We need a more nuanced approach to characterizing the overall impact of the tobacco market—something better than smoking or tobacco-use prevalence. In its response to a consultation on “healthy people” indicators in the United States, the National Tobacco Reform Initiative advocates use of “harm weighting” in characterizing tobacco use, creating an index of tobacco use that takes account of the differences in risk between different products. This would help to focus minds on the real public health problem: that problem is combustion and smoke.
“More Choice, Less Risk” is the theme for the 2019 Global Tobacco & Nicotine Forum (GTNF), to be held Sept. 24-26 in Washington, D.C. Visit www.gtnf.org for details.
Clive Bates is the director of Counterfactual Consulting and the former director of Action on Smoking and Health (U.K.).
With no meaningful history of traditional tobacco control, Malawi may be more open than other countries to the concept of harm reduction.
By George Gay
Malawi has a tobacco control commission but makes no interventions to control tobacco product consumption. There is, however, no anomaly here, as professor Gerry Stimson, a director of Knowledge Action Change (KAC), an organization that promotes health through harm reduction strategies, pointed out during an interview in London in April. This state of affairs merely reflects a tension within the tobacco fabric of Malawi. The Tobacco Control Commission is charged only with overseeing the leaf tobacco production industry—an industry so important to the economic welfare of the country that there is a reluctance on the part of the government to engage also in consumption-control activities.
Freshly returned from a visit to Malawi, Stimson related how tobacco packs in the country carried no health warnings, how the country imposed no age restrictions on tobacco product purchases and how taxation was not used as a vehicle for reducing consumption. Malawi was not party to the World Health Organization’s (WHO) Framework Convention on Tobacco Control (FCTC) and employed none of the WHO’s MPOWER measures intended to assist in country-level implementation of interventions to reduce demand for tobacco.
Such reluctance to rigorously confront one of the greatest health issues of our time will be seen by some as concerning, but Stimson clearly senses an opportunity. When he looks at Malawi, he sees a country that, without a history of narrowly focused tobacco-consumption interventions, is perhaps open to ideas about tobacco harm reduction (THR).
KAC’s directors, Stimson and Paddy Costall, have been active in harm reduction for more than 40 years and, more recently, specifically in THR. They have helped stage the annual Global Forum on Nicotine (GNF) in Warsaw, Poland, since 2014. More recently, using funding from the Foundation for a Smoke-Free World (FSFW), KAC has introduced THR scholarships and launched the Global State of Tobacco Harm Reduction 2018 report.
That report, which was written by Harry Shapiro and launched last year in London, is currently the subject of an international roadshow, also funded by the FSFW, that has so far seen it taken to Australia, Kenya and Malawi, not all of which are necessarily the first countries that would come to mind when planning such a trip. In fact, Stimson admitted that, not long ago, he considered Africa to be off the map in respect of THR. But now, he said, there was a lot of interest and a lot of activity, and some “rising stars” among the people there. Malawi, for instance, was included on the roadshow schedule partly because two of KAC’s THR scholars based there, Chimwemwe Ngoma, who runs the campaigning organization, THR Malawi, and social scientist, Wilfred Jekete, had said they wanted to organize a THR meeting for government officials and others.
Open to ideas
That meeting, described by Stimson as “very interesting,” attracted more than 100 people representing health education and AIDS organizations, universities, nongovernmental organizations (NGOs), farming interests and tobacco community development bodies, as well as and the government departments of agriculture, health and trade, a lineup that seems to support Stimson’s contention that the country could be open to fresh ideas concerning the control of tobacco consumption.
But first there would need to be a shift in thinking away from the idea that acting against tobacco consumption locally could hurt the “health of the tobacco economy,” a shift that has been made successfully in other tobacco exporting countries, even in countries where, unlike Malawi, consumption is mainly of locally manufactured products.
Certainly, the argument that Stimson and his team presented was that the government could concern itself with the health of smokers without what it did affecting the health of the tobacco economy, because consumption of domestic tobacco was minimal. And the prospects in Malawi were good, Stimson said, because the government could develop an approach to tobacco consumption from what was almost a blank slate. It could look at consumption control from a THR approach in which it was concerned about health but was not working only with the rather heavy-handed tobacco control components of MPOWER. This just couldn’t be done in other countries, added Stimson, who made the point that the guest of honor at the meeting was the head of the country’s health service.
To a certain extent, getting across the idea of harm reduction means pushing at an open door because Malawi has a history of dealing with the effects of AIDS. In fact, the joint host of the meeting was JournAIDS, an organization that was originally set up by journalists around the fight against AIDS but that now deals with any number of health and social welfare issues. So it is possible that relaying messages about safer alternatives to smoking or quitting smoking could piggyback on health outreach structures that are already well-developed in Malawi in respect of AIDS, tuberculosis and malaria. Interestingly, there is in place a campaign aimed at raising awareness about the toxicants in smoke—but in this case the focus is on smoke from the open fires used during cooking.
However, there is one major problem with trying to introduce the idea of THR. Despite the wealth of the tobacco industry and the fact that Malawi has long been a major “stakeholder” in that industry, the country is economically constrained and many of its people are financially poor, so they could not afford to replace combustible cigarettes with, say, vapor products or Swedish-style snus. This means that THR would have to be based on alternative, acceptable, noncombustible products that could be produced in the country.
Campaigning for alternatives
Meanwhile, the roadshow in Kenya was scheduled to coincide with the launch by Joseph Magero of a pan-African THR network called the Campaign for Safer Alternatives (CASA), which has members also in other African countries, including the Democratic Republic of Congo, Malawi, Nigeria and Uganda. It included people working in slums, on AIDS and on drugs harm reduction, as well as those supportive of THR. It included, too, representatives of religious organizations, which are important operators in Kenya in the field of youth outreach.
Stimson described the situation in Kenya as fundamentally different to that in Malawi because in Kenya there was a strong alignment of anti-tobacco organizations that were part of the Framework Convention Alliance, which were strong supporters of the FCTC and for whom THR was seen as a threat. “It is a different, difficult situation,” he added, “but an interesting one because there are NGOs that have been working on harm reduction issues and that do get tobacco harm reduction as an idea. And this pan-African organization looks like it might have some traction.”
So, all in all, the Africa leg of the roadshow was a success? Well, said Stimson, the main aims of the roadshow had been to raise awareness about THR as a way to help people shift away from tobacco smoking and to strengthen the capacity of local people to promote THR. As an outsider, KAC could not do that, but it could help, nudge, support and enthuse local people, and it could provide them with the international contacts to enable them to put harm reduction and THR higher up the agenda. KAC was involved in a process of creating a conducive environment for harm reduction. It was a long process, and it was necessary to take every opportunity that presented itself. “I’m particularly enthused by the energy among the THR advocates in Malawi, and I’m particularly enthused by this new organization CASA,” he said. “You never expect things to change massively overnight, but everything seems to be pushing along the road towards harm reduction.”
Money well spent
As can be seen, Stimson is serious about the THR course he has set out on, but, having worked in harm reduction for so long, he is nothing if not a realist, and his answers are regularly punctuated with laughter as he recounts some of the obstacles that litter his path. One such is the reaction to KAC using FSFW money, which originally came from Philip Morris International (PMI) but over which PMI has no control and which cannot be returned to PMI. KAC had taken a risk accepting that money and had received a lot of flak for doing so, Stimson admitted, before going on to say, “… but … I would like to see it spent for the reason the money is there—to help shift people from smoking …. We think the money from the foundation can be well-spent.”
KAC had two Foundation-supported projects, Stimson said. One concerned the Global State of Tobacco Harm Reduction report for which KAC had made a grant application that was accepted and in respect of which there had been “absolutely no interference whatsoever from signing the contract to publishing the report. I have never experienced a donor who has been so hands-off,” he added.
And it was a similar story with its scholarships, which are funded by the Foundation but whose role is totally hands-off. “In my view,” said Stimson, “the ethical issue is no longer that PMI funded the foundation, but, given that the foundation has the money, it would be unethical not to spend it on the purposes for which it is intended.”
The Global State of Tobacco Harm Reduction 2018 report, now available in Mandarin as well as English, has been well-received, attracting a significant number of downloads for both it and the executive summary, which has been translated into a dozen languages. And, with what is now the assurance of a five-year FSFW funding agreement, the report is an ongoing project. Already since its launch, it has seen the addition of country profiles and a new tool that allows country comparisons to be made. And the latest project is adding an index that will measure how favorable governments are toward THR.
KAC has obtained a five-year funding agreement also for its scholarship program, which is run by Kevin Malloy and about which Stimson is “very excited.” The scholarships are designed to introduce and support people new to the field—to help build a new generation of people interested in research and communicating THR.
The program is nearing the end of its first year, during which it supported 15 scholars who initially were provided with a training program built around the 2018 GFN conference and who each received $7,500 to work, with the aid of a mentor, on an agreed project.
This year, the program, which attracted 50 applications, is being expanded and will see 20 scholars, 10 of them from Africa, each receive $10,000, and six who graduated with the first cohort receive $25,000 under an enhanced scholarship scheme. One of the enhanced scholars will be Malawi-based Jekete, who will be in charge of a program aimed at introducing stop-smoking and THR messages into other health organizations.
The fact that half of this year’s scholars will be from Africa was described by Stimson as “extraordinary.” Two years ago, he said, outside of South Africa, very little was happening in Africa in respect of THR.
PMI’s venture into the life insurance business presents customers with new options and raises some interesting questions.
By Stefanie Rossel
In late April, Philip Morris International (PMI) announced a move that was remarkable in more than one respect: The company said that it had diversified into the life insurance business. With its newly established, wholly owned subsidiary Reviti, which is based in the United Kingdom, it targets smokers who use any combustible tobacco product, such as cigarettes or cigars, and who are willing to quit. To incentivize them, smokers who switch to any type of e-cigarette and/or a nicotine-replacement therapy (NRT) product will be given a 2.5 percent discount on premiums. People who change over to PMI’s heat-not-burn (HnB) product iQOS for three months will receive a 25 percent discount, whereas ex-smokers who quit smoking and quit nicotine altogether, including NRTs, for at least twelve months will get 50 percent off. All those who never smoked combustible tobacco and never used nicotine-containing products will be charged the lowest premiums.
Premiums for a 20-year-old nonsmoker stand at around £5 ($6.50) per month for a life insurance policy that pays £150,000. The same premium would buy a £60,000 policy for a 40-year-old nonsmoker.
Reviti believes firmly in the risk reduction potential of e-cigarettes and will determine how big a discount to offer people using alternative products based on scientific data. The potential of a product to reduce a person’s health risk will also play a role.
“Traditional insurance companies set premiums based on how ‘risky’ a customer is to insure when they buy a policy—what Reviti brings to the market is different,” says Andrew Cave, PMI’s director of communications. “They recognize that people’s lives change over time and want to help them on this journey of positive change, so if customers make better choices through improving their lifestyle, Reviti will reward them.”
The life insurance initiative underlines PMI’s ongoing commitment to creating a smoke-free future. Reviti, which acts on behalf of Scottish Friendly Assurance Society Limited, also plans to roll out a range of other insurance policies that reward better lifestyle choices, such as weight management, increased exercise or stress management. For smokers who want to quit tobacco and nicotine altogether, Reviti offers support from a leading pharmacy chain with a range of options including coaching, says Cave. “Every Reviti customer will be offered the chance to work through a program via the new Reviti life app, which provides them with 120 activities and programs designed to support lifestyle changes.”
Rewarding self-optimization
Offering health and wellness incentives to encourage their customers to adopt and maintain healthy lifestyles—which helps reduce the risk of developing chronic illnesses and dying prematurely—has become a trend among life and health insurance companies in recent years. Global management consulting and professional services firm Accenture predicts big benefits for life insurers that promote customer wellness. Termed “connected wellness,” the concept involves the use of digital technology, such as fitness trackers and apps, by insurance providers to build intimate, real-time relationships with their customers and thus encourage them to become healthier and safer to be able to enjoy greater rewards and incentives. In turn, insurers can generate additional value from these long-term relationships by increasing their offerings, capitalizing on new markets and improving efficiency. The approach, however, has also evoked debate because of privacy concerns and potential misuse of data.
What makes Reviti’s insurance model novel is its explicit targeting of smokers. Until now, smokers seeking to get life insurance have had to pay significantly more for their premiums than nonsmokers. According to a U.K. survey taken by moneysupermarket.com between January and November 2018, the average nonsmoker will pay £9.96 per month for decreasing life term insurance while a smoker would pay £21.
New in Reviti’s approach is that it also differentiates between smokers of combustible cigarettes and users of other nicotine delivery systems. Usually, insurance companies don’t distinguish between people smoking two packs of cigarettes a day and those smoking two packs a year. Neither does it make a difference to them whether customers use cigarettes, cigars, pipes or NRTs. Because e-cigarettes contain nicotine and their long-term health benefits have yet to be established, they are also categorized as tobacco products. To qualify as a nonsmoker, and hence for lower premiums, customers must refrain from using any nicotine and nicotine-replacement products for at least 12 months.
Determining whether a policyholder has truly switched to reduced-risk products (RRPs) may present a challenge to Reviti. Although there are a variety of testing methods to determine the nicotine content in the body, a reliable method to verify whether that nicotine comes from combustible cigarettes, e-cigarettes or HnB products does not yet exist.
“As with all questions, customers must answer and complete declarations honestly and truthfully,” explains Daniel Pender, CEO of Reviti. “There may be occasions, in line with the industry, where Reviti asks customers to undertake a test to validate their smoking declaration, and the offer of a discount from Reviti to lower their premium would require customers to consent to this test being a possibility. In line with industry standards, Reviti [is] clear to point out the obligation to answer questions honestly and provide warnings that a failure to do so could result in the insurance being canceled.”
Focus on iQOS
Working with Reviti, PMI fills a gap in the market for life insurance policies for people who smoke and wish to quit tobacco and nicotine altogether or who wish to switch to scientifically substantiated reduced-risk alternatives.
“It was time the insurance business caught up with its customers,” said Pender at the launch of his company. “The life insurance product we offer is a win-win for Reviti and our customers. They get competitive premiums and, with a little help from us, a better lifestyle. We get to help millions of people who have never had access to life insurance before and who will benefit from positive lifestyle changes we’re helping them to make.”
While this is a laudable goal, Reviti’s offer also contains a detail that is unusual in the insurance business: One of the highest discounts offered is tied explicitly to a PMI product. Already, U.K. anti-tobacco activists have criticized the move as a new PMI marketing tactic to promote iQOS in a market where advertising and promotion of tobacco products as well as sponsorship by tobacco companies has been completely banned.
They may have a case. The popularity of HnB products in the British market is still comparatively low. While heated-tobacco products were introduced into the U.K. in late 2016, awareness and ever-use remain rare, as noted by Public Health England (PHE) in its 2018 evidence review of e-cigarettes and heated-tobacco products.
While smoking prevalence among adults in the country decreased to 14.9 percent in 2017, vapor products became the preferred reduced-risk products category. Today, the U.K. is the world’s third-largest vapor market, although the PHE review also found that e-cigarette use had recently plateaued at 6 percent of the adult population.
PHE’s 2015 statement that vaping is 95 percent less harmful than traditional tobacco and the agency’s recommendation of e-cigarettes as smoking cessation tools has contributed to the popularity of vaping in the U.K.
In its most recent report, PHE upholds its view on e-cigarettes, declaring, “The available evidence suggests that heated-tobacco products may be considerably less harmful than tobacco cigarettes and more harmful than e-cigarettes. With a diverse and mature e-cigarette market in the U.K., it is currently not clear whether heated-tobacco products provide any advantage as an additional potential harm reduction product.”
The agency recommends that, depending on emerging evidence on their relative risk compared with combustible tobacco and e-cigarettes, regulatory levers such as taxation and accessibility restrictions should be applied to favor the least harmful options alongside continued efforts to encourage and support complete cessation of tobacco use. Its assessment is in line with the theory of the continuum of risk, which puts e-cigarettes at the lower end of the scale.
Lower risk of relapse
Reviti, however, says it has its reasons for emphasizing iQOS in its insurance concept. “There are hundreds of e-cigarette brands on the market in the U.K.,” says Pender. “Assessing all of those as the same would be the equivalent of a home contents insurer treating all post codes, house sizes and building types the same. The scientific data for each product needs to be assessed together with the potential of a product to reduce risk over the medium to long term. We have data to demonstrate that smokers who switch to iQOS are unlikely to relapse—on average, 70 to 80 percent of iQOS users have quit cigarettes—which makes iQOS a compelling smoke-free alternative for people who would otherwise continue smoking.”
According to Pender, Reviti’s next step will be to cover more smoke-free products, but each one would have to be considered on its own merits rather than taking a category approach. “It is important to keep in mind that both the qualitative and the quantitative composition of e-cigarette aerosols is greatly variable,” he says. “E-cigarette emissions can be very different from one manufacturer to another, from one device to another and even from one puff to another. This leads to a situation where, despite the presence of many high-quality e-cigarettes on the market which are safe for intended use and deliver substantially lower levels of harmful and potentially harmful compounds compared to cigarettes, there are many e-cigarettes which are not manufactured to high standards of quality and safety and therefore present undue risks to consumers. This is why the risk profile of e-cigarettes and other noncombustible products must be assessed on a product specific basis.”
Pushing iQOS sales
PMI has pumped billions of dollars into research and development as well as into the marketing of its next-generation products in recent years. While the company offers a wide range of reduced-risk products, among them many leading e-cigarette brands, its main focus remains on iQOS. During its annual shareholder meeting on May 1, 2019, the company said that its heated-tobacco unit (HTU) shipment volume increased by 14.2 percent to 41.4 billion units in 2018, whereas its in-market sales volume for HTUs nearly doubled, reaching 44.3 billion units, a development driven by all iQOS launch markets. Without distinguishing between individual product categories, the company said that in 2018, all RRPs including HnB products accounted for more than 5 percent of PMI’s total shipment volume and nearly 14 percent of its total net revenues, or over $4 billion. However, the growth was less than expected as volumes saw a decline of 22.6 percent in the fourth quarter of 2018, mainly due to negative distributor inventory movements in Japan. Although margins for the product are currently very low due to discounts and offers as the company is trying to promote the product, analysts expect iQOS to drive the company’s future growth and create value for the company as the discounts are gradually withdrawn.
PMI said it targeted shipping 90 billion to 100 billion heated-tobacco units a year by 2021. On April 30, 2019, the U.S. Food and Drug Administration (FDA) authorized iQOS for sale in the United States. The approval follows a two-year science-based review period through the premarket tobacco product application (PMTA). The FDA was quick to add that while this action permits the tobacco products to be sold in the U.S., it does not mean these products were safe or “FDA approved.” The agency still has not acted upon PMI’s modified risk application for iQOS, which the company had submitted alongside its PMTA application in March 2017.
Where next?
With the U.K., PMI has chosen Europe’s biggest life insurance market for its introduction of Reviti. The company says it has plans to become a global brand with a broad suite of products and to expand overseas in the future, but it hasn’t named any concrete markets yet. If countries such as Germany, for instance, were on Reviti’s list, a launch of its current discount concept could become difficult: In Germany, life insurances are regulated by the principle of equal treatment as stipulated by the insurance supervision law. This principle generally prohibits discounts for individual groups of policy holders if no underlying factual reason for the differentiation can be found in the premium calculation.
Discount premiums especially for users of a certain product of a brand, a spokesperson of the German Insurance Association told Tobacco Reporter, would be permissible if only there were such serious differences between the use of this product compared with the use of a competitive manufacturer’s product with regard to premium calculation that they would justify unequal treatment. The advantage of the product promoted by the insurance policy would have to be statistically proven. In the case of iQOS, this would require independent long-term studies, which for the novel product category don’t exist yet.
The new EU Single-Use Plastics Directive requires cigarette manufacturers to assume greater responsibility for the environmental impact of their products.
By Stefanie Rossel
During a recent holiday, I had plenty of opportunity to watch the phenomenon: smokers discarding their cigarette butts on the ski slope or throwing them out of car windows while they were stuck in a traffic jam on the motorway. Butt littering is a bad habit, and it’s a common one as well. Studies quoted by the Truth Initiative, a U.S. not-for-profit tobacco control organization, found that 75 percent of smokers dispose of their cigarettes in the environment. Smokers are estimated to litter as many as 65 percent of their cigarette butts. Awareness continues to be low: In a survey by Keep America Beautiful, 77 percent of respondents said that they didn’t think of cigarette butts as litter.
The effect on the environment, however, is devastating. According to the Truth Initiative, cigarette butts are the most littered item on earth. Since the 1980s, they have consistently made up 30 percent to 40 percent of all items collected in annual international coastal and urban cleanups, amounting to an estimated 4.5 trillion cigarettes annually being discarded worldwide. For those who find this figure too abstract, in the southern part of Great Britain alone, cigarette butts discarded as street litter amount to 1,710 tons of waste per year—enough to fill seven Olympic-size swimming pools, according to calculations by British online vape shop Vapourcore.com.
Around 98 percent of cigarette filters are made of cellulose acetate (CA), a polymer that degrades in the environment very slowly. The time it takes a CA cigarette filter to disintegrate ranges from 18 months to 10 years, depending on the conditions of the environment in which it has been discarded. In addition, used cigarette filters are full of toxins, such as nicotine, formaldehyde, arsenic and ammonia, which can leach into the ground and harm living organisms that come into contact with them.
EU to combat plastics litter
Cigarette butts are also among the 10 single-use plastic products most often found on Europe’s beaches and in their seas. Together, these products constitute 70 percent of all marine litter items. In an effort to fight marine pollution, the European Commission in May 2018 proposed rules, the so-called Single-Use Plastics (SUP) Directive, which will ban single-use plastic items such as plates, cutlery, straws and cotton bud sticks made of plastic, as well as oxo-biodegradable plastics—i.e., plastics made of petroleum-based polymers that contain additives that accelerate their degradation when exposed to heat and/or light—food containers and expanded polystyrene cups beginning in 2021.
With regard to tobacco, the Members of the European Parliament (MEPs) proposed consumption reduction targets of tobacco product filters of 50 percent by 2025 and of 80 percent by 2030 in the original draft directive. Following several so-called Trilogue meetings—negotiations in the EU legislative process carried out within the framework of a conciliation committee—the Council of the EU and the European Parliament in December 2018 reached a provisional agreement that puts aside the MEPs’ proposal for consumption reduction targets.
Somewhat vaguely, the provisional agreement states that “the huge environmental impact caused by post-consumption waste of tobacco products with filters, discarded directly into the environment, needs to be reduced. Innovation and product development are expected to provide viable alternatives to filters containing plastic, and this development needs to be accelerated.” Through the introduction of extended producer responsibility (EPR), a reinforced application of the “polluter pays” principle, the provisional agreement seeks to further encourage innovation leading to the development of sustainable alternatives to tobacco product filters containing plastic. The SUP Directive was expected to be formally adopted in its current form at Tobacco Reporter’s press time in late March 2019.
“The directive will require producers to cover the costs of consumer awareness-raising measures and EPR schemes tackling the cleanup of litter and its subsequent transport and treatment, the costs of data gathering and reporting, and the costs of collection of waste of tobacco filters discarded in public collection systems,” explains Giovanni Carucci, vice president of EU affairs at British American Tobacco (BAT). “The deadline for EU member states to set up EPR systems is [Jan. 5, 2023].”
In particular, the obligation for member states to implement EPR schemes for tobacco filters containing plastic by 2023 is a precedent, he points out. “As yet there is no available guidance for member states as to how such EPR schemes should be implemented. Apart from a few local schemes, this is something that has never been carried out on this scale before for filters as for the other affected products. At the same time, it’s important to make sure the resulting schemes are efficient and effective and avoid unnecessary complexity.” He adds: “We believe the solution to this will be dialogue and cooperation including other affected industries, and we are open to collaborating and sharing information and expertise about our products to find the best way forward.”
Educating smokers
BAT agrees that companies should minimize their environmental impact and is committed to reducing its environmental impact across the supply chain and operations, according to Carucci. Before the SUP Directive, BAT had long been engaged in diverse projects and initiatives to prevent consumers from littering cigarette butts. “We believe consumer awareness is absolutely critical to solving the problem of butt littering, so we focused on creative projects designed to reach adult smokers,” says Carucci. “For example, in Belgium we worked together with the public authorities to contribute to a voluntary fund designed to support prevention awareness. In other countries, such as Austria, Germany, [the] Czech [Republic] and Switzerland, we distributed thousands of portable, sealable ashtrays as part of consumer education campaigns. These sorts of initiatives are also seen outside of the EU, for example in New Zealand where we contributed to a campaign that provides free purpose-designed cigarette butt bins to member councils and businesses and support to help councils and business associations educate smokers, making them more conscious of their littering and highlighting alternatives. These are just a few examples of the kinds of initiatives which we believe help mitigate the impact of our products.”
In the EU, cigarette manufacturers will have to go one step further: The SUP Directive mandates that, by the second quarter of 2021, tobacco companies put labeling on cigarette packs informing about the negative impacts of cigarettes with plastic filters thrown in the street. The labeling aspects of the proposal need to be in line with already existing tobacco labeling requirements stipulated by the revised Tobacco Products Directive (TPD2). Manufacturers are keen that regulators ensure there is no conflict with existing rules in the TPD2. “The Single-Use Plastics Directive states in Article 7(3) that the provisions of that article concerning tobacco products are in addition to those laid down in TPD2. Although the final compromise text of this legislation was published in January, we are still awaiting further details on the exact requirements on labeling. This will come in the form of secondary legislation—an implementing act—which could take some time to materialize. Until then, we can’t anticipate what such a conflict might look like. Therefore, we encourage legislators to consider the current design of products so that manufacturers can best apply them in a manner that does not conflict with existing legislation.”
For cigarette manufacturers, the cost involved from the measures mandated by the new directive remain unpredictable at this point. “Until secondary legislation materializes, it is not possible to know what additional costs this will add,” says Carucci. “However, we hope that any related costs will be efficient and proportionate.”
Searching for alternatives
While raising awareness among consumers certainly is a challenge, finding the innovative, environmentally friendly alternative to CA cigarette filters as stipulated by the directive might be an even tougher nut to crack. And it’s not just the filter material alone. Carucci says that his company’s current research shows that some constituents of its filters, such as CA derived from wood pulp, can degrade over a month to a three-year time period. “However, for other constituents in our filters, for example polymers or glues, research is inconclusive and requires further testing.”
Filters are an important part of the cigarette because they help comply with legally mandated maximum emission levels of tar, nicotine and carbon monoxide set out by the TPD2, Carucci emphasizes. “This is an essential quality to maintain when considering whether there are alternative materials that could serve the same purpose while taking environmental factors more closely into account,” he says. “At present, there are no alternatives that have been developed that will meet prescribed emission standards in various jurisdictions, while not increasing consumer exposure to certain other priority toxicants. Just to give one example, we’ve partnered with manufacturers developing these types of materials, as in 2014 when we partnered with Green Butts to evaluate some of their materials as potential filter materials. However, when we measured the smoke toxicants of the resulting filters compared to a control product, the majority of toxicants were higher than a cigarette with a standard filter. That’s why cellulose acetate remains, for the moment, as the benchmark. However, we will certainly keep up our efforts to research new materials, and we are open to new partnerships that could offer a solution.”
Solutions in the pipeline
Innovation in the filter and filter tow sectors offers some hope. With consumers becoming increasingly environmentally conscious, manufacturers of cigarette filters and filter tow have been developing alternatives with better biodegradability than the commonly used CA filter. Many of them have long been successfully used in cigarette products.
“Ever since I joined the industry in 2003, we have been running projects, both internally and with customers, to identify more biodegradable alternatives to cellulose acetate tow,” says Patrick Meredith, strategy and business development director at Essentra, a U.K. solutions provider for special filters and scientific services. “Some of the products introduced as a result of this work, such as our own Infused and BiTech filters, do bring performance closer to that of cellulose acetate filters. These may not provide identical performance to cellulose acetate over the full range of filter parameters—e.g., filtration, firmness, hot collapse, sensory and visual appearance—but they can certainly provide a base from which to develop solutions to meet any legislation that is enacted.”
Essentra has a range of solutions in its portfolio, including the Ochre filter, which is manufactured from unbleached paper, uses no chemical adhesives to bond the fibers and degrades three times faster than industry standard CA filters. At the same time, it retains higher levels of tar and nicotine compared to mono-acetate filters while it can provide a closer taste to acetate when the company’s Infused technology is applied, according to Essentra.
Next to “white” dual rod products with enhanced decomposition abilities, Essentra’s range also contains the BiTech filter, a single-segment filter that combines acetate tow with paper or other nonwoven materials and provides better filtration efficiency and greater degradability than a standard mono-acetate filter. Dependent on the raw materials selected, it also features better degradability than commonly used filters, according to the company.
“The latter two products incorporate a combination of cellulose acetate and paper, so adjusting the particular materials and their ratios should allow increased degradability to be achieved,” says Meredith. “We also have our Infused product whereby a liquid additive is applied to a paper filter, i.e., the Ochre filter, to bring the taste closer to that of a cellulose acetate filter.”
Essentra’s most recent innovation in terms of biodegradability is a hemp filter. “The hemp crop used to produce the hemp fiber source is grown without pesticides and irrigation for both seed and straw, which ensures economic stability and sustainability,” says Meredith.
Since 2014, the company also has a plugwrap material on offer that disperses in water at least three times faster than standard materials. “We have worked with a number of customers incorporating this plugwrap into our filter rods,” Meredith explains. “The plugwrap gives us an excellent tool to incorporate into the filter as part of a more degradable ‘total’ solution.”
Improving the availability of biodegradable filter solutions is essential, as regulation will not remain limited to the EU, Meredith notes. “Many other markets either have or are already looking to introduce legislation around degradability and littering of cigarette butts or are watching what happens in Europe with a view to adopting similar legislation. To meet these extended requirements [we] will need transformation across the entire industry.”
Best of both worlds
Progress has also been made with regard to the raw material used for filter production. In June 2018, Rhodia Acetow, a leading manufacturer of cellulose acetate tow, introduced DE-Tow, a fast biodegradable CA filter tow. “DE-Tow offers the tremendous advantage to meet the needs of environmental care regarding products that would be littered in nature; while traditional cellulose acetate in cigarette filters takes several years to decompose, DE-Tow biodegrades in less than six months,” says CEO Philippe Rosier. “Therefore, this innovation offers a global solution to the cigarette butt problem. We consider DE-Tow as a viable alternative to regular cigarette filter tow as referred to in the Single-Use Plastics Directive. Our product also contributes to the EU member states’ transition to a circular economy by generating a waste which, after collection, can be used for the production of biogas, composted, recycled or valorized energetically.”
Rhodia has been working on alternatives to current filters for about a decade. “Thanks to those efforts, with DE-Tow, we have been able to commercialize a biodegradable new generation of cellulose acetate filter tow,” says Rosier. “Therefore, the upcoming regulation is rather rewarding for our work and strengthens our determination to put the environment at the core of our R&D efforts.”
Upon its launch, the product’s biodegradability had already been certified in water, wastewater, and home and industrial compost. In December 2018, it received the certification of biodegradation in soil. Tests performed by external homologated laboratories have demonstrated the product’s biodegradability in marine water, according to Rhoda. “We expect official certification this year,” says Rosier.
DE-Tow can be used for the production of biodegradable cigarette filters through the same manufacturing process used for standard filters, Rosier explains. “There is no structural impact for cigarette manufacturers. With DE-Tow, cigarette manufacturers can replicate any type of filter for the simple reason that our product is made from cellulose acetate. Its main difference compared to regular cellulose acetate filter tow used for cigarette filters is its fast and certified biodegradability. It is also important to mention that DE-Tow is TiO2 free and that its classic filter tow performances, such as rod maker processability, smoke filtration, and filter design and quality, are equivalent to standard filter tow. DE-Tow is the filter material of choice not only for cigarettes but also for heat-not-burn sticks.”
Cellulose acetate has been used in the production of cigarette filters since the 1950s.
In Europe, more than 99 percent of the cigarettes currently sold are made with cellulose acetate-based filters, Rosier estimates. Rhodia Acetow is convinced that the development of sustainable alternatives to current cigarette filters has to leverage these key filtration performances of cellulose acetate. According to Rosier, customers are increasingly concerned about the environmental impact of tobacco products. “Consequently, we have been and are working closely with many cigarette manufacturers to develop, test and qualify innovative solutions respectful of the environment, such as DE-Tow. The first cigarettes with DE-Tow are now launched on the market. This synergy between our companies will be successful and meet both market expectations and environmental needs.”