Category: Print Edition

  • Well-served

    Well-served

    Thanks in part to their country’s embrace of vaping, U.K. smokers and vapers now have a wide variety of products to choose from.

    By George Gay

    Having watched the Brexit fiasco unfold, people living outside of the U.K. could be forgiven for thinking that the country has taken leave of its senses, a view that is shared by many of us living in the U.K. But I would argue that there is at least one area in which the U.K. has kept a level head and could be seen to be leading the world—and that is in respect of accepting some lower-risk products as part of a tobacco harm reduction strategy aimed at steering smokers away from combustible cigarettes, which is an ambitious and vital undertaking given that many institutions claim that tobacco smoking is the leading cause of preventable deaths.

    And significantly, I think, this effort is not confined to the usual stakeholders; it has brought closer, if not together, tobacco manufacturers, vapor product suppliers, public health experts, formal and informal groupings of members of Parliament (MPs), the government and consumers. Not everything is fully aligned, of course, but there is a sense in which things are gradually coalescing.

    This push for a transition from smoking to vaping has been going on for some time, but 2018 seemed to see it step up a gear—right from the start of the year. On Jan. 2, 2018, Philip Morris Limited (PML), the U.K. and Ireland affiliate of Philip Morris International, ran announcements in several U.K. newspapers saying that its New Year’s resolution was to try to give up cigarettes. This, to my way of thinking, was a clever campaign. In using the idea that it was trying to give up cigarettes, PML was aligning itself with smokers—it, too, was hooked and was feeling their pain. And it was letting smokers and other stakeholders know that quitting smoking was not something that could be achieved easily. After all, New Year’s resolutions are often based more on hope than expectation.

    And, later in the year, the idea that quitting was not easy was built upon when the company, which had opened its fourth iQOS store in London in February, launched another campaign in which it recognized that quitting smoking was also something that could not necessarily be done alone—presumably either by individual smokers or individual companies.

    But no matter. There was a feeling in the air that smokers and companies wishing to help smokers switch to vaping were not alone; they had official support. In a press note issued in August alongside its report titled, “E-cigarettes,” the House of Commons Science and Technology Committee said regulations should be relaxed in relation to the licensing and prescribing of e-cigarettes and in respect of the advertising of their health benefits. It also added that their level of taxation and use in public places needed to be reconsidered.

    Meanwhile, reflecting part of what the committee had recommended, the U.K.’s Advertising Standards Agency (ASA) said in November it had changed its rules so that health claims were no longer banned from advertisements for electronic cigarettes. Such a change by the ASA did not mean that the suppliers of vapor products were free to make health claims as they saw fit—only that they would be able to do so should they fulfill the requirements of other agencies. Still, it seemed to be a step in the right direction.

    Also in November, and reflecting another aspect of the committee’s findings, a report by a group of cross-party MPs focused on the vexed question of vaping bans. The All-Party Parliamentary Group for Vaping’s report titled, “Vaping in Workplaces and Public Places,” pointed out that though the U.K. did not ban vaping in public places, many employers and those in charge of public places did ban it. So it recommended in part that employers should have specific workplace vaping policies that balanced the needs of current vapers and smokers looking to switch to vaping with those of nonvapers—policies that were different to their workplace smoking policies.

    Then, in December, again reflecting the committee’s report, the government agreed to review e-cigarette regulations once EU legislation ceased to apply. The Department of Health and Social Care said it was committed to a review to reappraise current regulations to ensure they continued to protect the nation’s health. It said it would look to identify where it could sensibly deregulate without harming public health or where current EU regulations limited its ability to deal with tobacco.

    New devices

    Of course, as welcome as all of these recommendations and proposals are, none of them make sense without smokers having access to alternative devices to combustible cigarettes, and they make little sense if those devices, which, after all, are still relatively new, are not the subject of frequent innovation so as to render them attractive to smokers—from the social smoker to the hardened smoker. Luckily, possibly in part because of the U.K.’s embrace of vaping, smokers and vapers were well served in 2018 by the major tobacco manufacturers, which delivered a range of new and updated alternative devices within the limitations of the EU’s Tobacco Products Directive.

    Such commitment to innovation was well summed up in British American Tobacco’s (BAT) December launch of two products in which its new Puretech blade technology had replaced the coil and wick heating mechanism traditionally found in e-cigarettes. In a note posted on its website, BAT said that it was launching two new closed-system electronic cigarettes, Vype iSwitch and the Bluetooth-enabled Vype iSwitch Maxx, as it sought to provide an even more satisfying option for adult smokers looking for a potentially reduced-risk alternative to traditional cigarettes. Importantly, given that the switch from smoking to vaping has slowed, it said that the new products were aimed at smokers who had yet to find a vaping alternative that satisfied them. And it added that the power and design of the technology delivered nicotine more effectively—even with lower strength nicotine e-liquids.

    Earlier in the year, BAT had launched the Vype ePen 3, which it described as being incredibly simple to use, an important feature given that some smokers are put off switching by what they see as complex devices. “With click in and out pods, Vype ePen 3 is designed to be a convenient and simple-to-use device, while a wide range of flavors and nicotine strengths provide a choice for each vaper,” BAT said in a note that accompanied the launch.

    Meanwhile, Imperial Brands’ 2018 financial year saw it increase significantly its investment in next- generation products (NGP). The company’s NGP portfolio is built around the Blu brand, which will be 10 years old next year but which, during 2018, was expanded with three new launches in the U.K.: Myblu (also launched in Austria, Canada, France, Germany, Italy, Japan [0 percent nicotine only], Russia, Spain and the U.S.); Myblu Intense (also launched in the U.S.); and Blu Ace (also launched in France and Italy).

    Imperial Brands said that its Blu brand was one of the best-selling in the world and available in an increasing number of markets. Myblu is described as a pod format device that combines a high-performance vaporizer with a simple liquid pod system. “The device takes just 20 minutes to charge and lasts all day,” said Imperial. “Blu Ace is our latest open system product and the most powerful device in our portfolio. It comes in an all-in-one stainless steel housing with a built-in liquid tank, and [it] delivers more puffs per charge than competitor products.”

    And in September, Japan Tobacco International (JTI) launched Logic Compact in the U.K., which joined Logic Pro, said to be the U.K.’s No. 1 capsule vapor device. “JTI engineered every aspect of Logic Compact with a modern, design-conscious vaper in mind,” the company said in launching the device. “Magnetic pods, metallic colors (slate gray, steel blue and rose gold) and a large 350 mAh battery are all within a sleek, compact, pocket-sized device. Taste, performance and style come together in a device that’s simple, convenient and easy to use.”

    “The U.K. is a growing e-cigarette market, with consumers increasingly looking for the ultimate vaping product,” Daniel Sciamma, managing director of JTI in the U.K., was quoted as saying. “Logic Compact offers a user-friendly and modern design, which is an exciting addition to our Logic portfolio. The new premium capsule vape is also an excellent product for adult smokers who are looking to vape—it delivers the perfect combination of flavor, power, simplicity and style.”

    Finally, PML launched the iQOS Mesh, which, despite the first part of its name, is an electronic cigarette rather than a heated-tobacco product. The new product has a Mesh heater—rather than a wick and coil system—that is in constant contact with the e-liquid to provide a consistent vaping experience. According to a note posted on its website, digital controls detect when e-liquid levels are low, thus avoiding overheating and the possibility of a burnt taste, while the device’s battery is certified according to ISO standards featuring three protection levels to prevent overheating, short circuiting and pressure buildup.

    The Mesh’s Veev flavor capsules, which are available in seven flavors, each in three nicotine strengths, are said to enable flavor swapping on the go with no flavor aftertaste from one capsule to another.

    I have heard people knowledgeable about the vapor device market say that, in the U.K., there is a device for every smoker. And I have heard people knowledgeable about the cigarette market challenge whether this is true, particularly in respect of price. I don’t know where the truth lies, but to regain the previous momentum that had smokers switching in large numbers to vaping, it seems essential that some of the recommendations and proposals outlined above are put into practice so that at least smokers can be confident that less-risky, satisfying products are available at a reasonable price, that they are useable without needing a degree in engineering, and that they can be bought at a store near them and used widely in public places.

  • The principle of proportionality

    The principle of proportionality

    Photo: Milkos | Dreamstime

    How to regulate reduced-risk products

    By Clive Bates

    How should society regulate reduced-risk products like e-cigarettes, heated tobacco products, novel nicotine products or smokeless tobacco? These products challenge existing systems of tobacco regulation, which generally assume the products are an unqualified threat to be contained. In reality, the products represent a public health opportunity with relatively minor risks to be mitigated.

    If there is too little regulation, people may be harmed by dangerous products or fooled by misleading claims. But if there is too much regulation, the excessive compliance burdens will make perfectly good products ineffective or unviable, and small firms will exit the market. The U.K. Royal College of Physicians provides the best summary of this dilemma in its 2016 report, Nicotine Without Smoke: Tobacco Harm Reduction:

    “A risk-averse, precautionary approach to e-cigarette regulation can be proposed as a means of minimizing the risk of avoidable harm, e.g., exposure to toxins in e-cigarette vapor, renormalization, gateway progression to smoking, or other real or potential risks.
    However, if this approach also makes e-cigarettes less easily accessible, less palatable or [less] acceptable, more expensive, less consumer-friendly or pharmacologically less effective, or inhibits innovation and development of new and improved products, then it causes harm by perpetuating smoking. Getting this balance right is difficult.” (Section 12.10 page 187)

    The question then is: How do we get this balance right? How do we find a “sweet spot” between inadequate and excessive regulation?

    In its August 2018 report on e-cigarettes, the U.K. House of Commons Select Committee on Science and Technology provides some direction. This respected parliamentary committee calls for:

    “… a wider shift to a more risk-proportionate regulatory environment, where regulations, advertising rules and tax/duties reflect the evidence on the relative harms of the various e-cigarette and tobacco products available.”

    This is an elaboration of the “principle of proportionality,” an idea that underpins good policymaking in many jurisdictions. In the European Union, it is coded into the Treaty on European Union at Article 5.4. In the United States, the underlying concept can be found in longstanding Executive Orders (https://bit.ly/2zfCUhu and https://bit.ly/2KeFM2g) that govern regulatory planning and review. This is not really a revolutionary idea; it should be approached as part of normal good practice in policymaking.

    What would it mean for regulation? First, we would start with an overall objective.

    Many possible overarching objectives could be chosen, and many different goals are evident in the statements of public health advocates. These could include reducing the health consequences of nicotine use, reducing smoking or tobacco use, reducing nicotine use, protecting bystanders, preventing youth uptake, or even destroying the tobacco industry. For many years, it was possible for campaigners and governments just to say “all of the above” and duck any hard choices. This is because with cigarettes and other combustibles dominating the market, these goals seemed aligned and unified. But that is not the case now—many of these goals are now in conflict. If a regulator focuses on preventing nicotine use, they risk ending up with more cancer and heart disease because they have closed down reduced-risk nicotine products and made tobacco harm reduction more difficult. We may be concerned about youth uptake, but this is primarily because of later harm to health. In any situation where we give higher priority to a goal other than health outcomes, we implicitly accept that there are situations where we will accept more disease and premature death. It follows that the focus should be reducing disease—and this forms a basis for judging trade-offs between different objectives. A variation on this could be to pursue the greatest possible welfare—taking in enjoyment, stigma and distributional impacts of policies like taxation.

    Second, we should adopt a broad finding: The key issue for public health is not whether nicotine products are tobacco or nontobacco or whether they are novel or long established. The key distinction is combustion versus noncombustion. It is the inhalation of smoke that dominates the harms arising from tobacco use. The difference in risk between combustible and noncombustible products is inherent in the chemical and physical processes involved, and it allows for a much more liberal approach to regulation and risk assessment. For reduced-risk products, there is no case to follow the playbook for regulating products that are, by universal consensus, very dangerous.

    Third, we should consider some approaches to regulation that would be risk-proportionate for noncombustible products.

    Notification not authorization. The route to market for noncombustible products should require notification of a regulator not authorization by a regulator. This would permit access to the market if a product complies with appropriate standards but gives powers to regulators to intervene if there is a material concern about health or safety. In an authorization system, regulators have to approve thousands of products but find it notoriously difficult to say “yes” to anything to do with tobacco. An authorization regime can create a very narrow and costly bottleneck preventing useful reduced-risk products reaching the market.

    Focus on individual risk. The most relevant characteristic of a nicotine product for regulators is its impact on health and safety relative to other products, such as cigarettes, or by comparison with other common risks. However, some jurisdictions, including the United States, require assessments of “population effects” or how the pattern of use of consumers in the market changes as a result of introducing a new product. Some honesty is needed here: It ought to be acknowledged that this is completely unknowable in advance. Population effects are not even a characteristic of the product, but an emergent property of a complex system of thousands of interactions. Many of these have little to do with the product itself, for example, the innovation and pricing strategies of rival products. The effect of demanding answers to impossible to answer questions is predictable and damaging. So, for noncombustible products, the focus should be strictly on individual risk, with any concern about population effects addressed through postmarket surveillance and retrospective corrective action if needed.

    Product and production standards. It is important that manufacturers and importers have a rulebook to work from and that this is comprised of standards that are transparent and proportionate—allowing producers to gear up to meet commonly applied standards. These should cover electrical, thermal, mechanical and chemical safety; standardized testing regimes; labeling requirements; and supply chain quality assurance. It should be possible to set purity standards for ingredients and to blacklist or place limits on any problematic ingredients.

    Consumer risk information. Consumers should be empowered to make good product choices in their own interests and at their own expense. That means they need reliable information about risks. Health Canada has shown real leadership in proposing seven government-approved risk communication statements designed to inform consumers. These include, for example, “If you are a smoker, switching completely to vaping is a much less harmful option,” and, “Completely replacing your cigarette with a vaping product will significantly reduce your exposure to numerous toxic and cancer-causing substances.” The Canadian example shows how a public authority can take responsibility for consumer risk information and support informed consumer choice.

    Allow advertising of an adult product. If regulators prevent producers of reduced-risk products from advertising their products and building brands, then they are protecting the harmful incumbent products from entrants that can benefit health. At the same time, there are concerns about advertising reaching teenagers and recruiting new users. There is no perfect way to segregate audiences, but the pragmatic solution, widely adopted for alcohol advertising, is to place restrictions on content and placement of advertising rather than ban advertising outright.

    Let owners and managers decide policies on indoor use. The case for the state intervening to ban smoking rests on material risk to bystanders, especially workers. No such rationale has been established for vapor and heated-tobacco products, and it is unlikely to be. From a public health point of view, there is a strong rationale for treating vapers differently to smokers to encourage switching and to support switchers to remain smoke-free. This does not mean unconstrained use of these products would be permitted everywhere, but that the decision should rest with property owners to balance the needs of their customers and users. This would allow diverse and nuanced policies that are not possible under the terms of a mandatory ban. Public Health England has approached this issue by publishing guidance on setting vaping policies for property owners.

    Excise tax should be zero or limited and proportionate to risk. One of the greatest drivers of switching from combustible products to reduced-risk products has been the relative pricing. Taking on something new is certainly a lot more appealing if it saves money too. Tax policy is usually underpinned by three objectives: raising revenue, avoiding harmful distortions or achieving positive goals, and keeping tax transaction costs to a small fraction of the revenue raised. These objectives point toward keeping excise at zero on vapor products and ensuring heated-tobacco products and smokeless tobacco products are taxed at zero or a small fraction of the lowest rates for combustible tobacco products.

  • The Future Mapped

    The Future Mapped

    Participants in the 2018 Global Tobacco & Nicotine Forum celebrated innovation and worried about bad policies.

    By Taco Tuinstra

    While the timing was probably a coincidence, the U.S. Food and Drug Administration’s (FDA) Sept. 12 threat against e-liquid flavors underscored the relevance of an already salient program. The Global Tobacco & Nicotine Forum (GTNF), which took place Sept. 11–14 at the Rosewood Hotel in London, focused heavily on ways to reduce the risks to health associated with tobacco consumption. The latest FDA pronouncements provided a perfect example of how not to go about, in the eyes of many participants. Rather than enacting heavy-handed rules and restrictions, GTNF speakers argued, regulators should create a climate that encourages innovation. The market, after all, has a better track record of solving problems than bureaucrats do.

    Jerome Abelman, British American Tobacco’s (BAT) general counsel and director of legal and external affairs, drew an analogy with the GTNF host city’s transportation system. When traveling to the forum, said Abelman, he a had a wide variety of options to choose from. He could travel by car (electric, hybrid, diesel, petrol, Uber or traditional black taxi), public transport (bus or Underground), by bike (his own or one obtained through a bike-sharing scheme) or by foot.

    “Those choices weren’t available 10 years ago,” said Abelman. A combination of good government policy and innovation by private industry has given Londoners not only more options, but also cleaner air. The same principles, he argued, would help reduce the health risks of tobacco.

    Jeff Stier, senior fellow at the U.S. Consumer Choice Center and a keen carnivore, made a similar point using the example of meat consumption.

    He related the story of a biochemistry professor, Patrick Brown, who wanted to tackle industrial animal agriculture. When the typical academic approach—organizing a workshop—failed to make a difference, Brown realized that the only way to impact meat production would be to beat it in the free market. “All you have to do is make a product that the current consumers prefer to what they are getting now,” Stier quoted Brown as saying.

    Brown started a company called Impossible Foods to develop plant-based and laboratory-grown meat alternatives meant to appeal not to vegetarians but to meat lovers. Helpfully, the FDA backed the safety of Impossible Foods’ plant-sourced hemoglobin.

    “While I will not become a vegetarian, the Impossible Burger [one of Impossible Food’s products] increases the likelihood that I will reduce my meat consumption,” said Stier. “That’s good news for those who think the world would be better if I ate less meat. The outcome won’t restrict my freedom; rather, it gives me more choice.”

    This happy result was achieved by private sector-driven innovation and timely government clearance of the product—and without costly finger-wagging public education campaigns, according to Stier. Like Abelman, he believes such factors will also drive progress in the effort to reduce the prevalence of tobacco-related diseases.

    Derek Yach, president of the Foundation for a Smoke-Free World, drew attention to a wider trend of dirty legacy industries changing their activities to cleaner ones. “The past no longer predicts the future,” he said. “What was once unthinkable is becoming possible through disruptive technologies: Coal companies are shifting toward renewable energy, waste companies are shifting from dumping to recycling, and auto companies are reducing their reliance on the combustion engine.”

    Yach went on to describe the characteristics that these companies have in common. “They use technological innovation to transform core businesses,” he said. “They respond to consumer demand for better, healthier and more sustainable products. Change is supported by asset managers and investors, and smarter regulation allows governments to steer sectors to outcomes aligned with sustainable development goals.”

    The tobacco industry, said Yach, has a similar opportunity to reduce the unacceptable health toll of smoking. Citing British psychologist Mike Russell’s famous observation that people smoke for nicotine but die from tar, Yach pointed out that the industry now has a portfolio that cuts risk by decoupling nicotine from lethal smoke.

    Yet considerable obstacles remain, he noted. For example, the parties to the World Health Organization’s Framework Convention on Tobacco Control—which were scheduled to convene in Geneva shortly after the GTNF—systematically exclude from their discussions “the organizations responsible for creating tobacco-related risks and potentially holding the key to mitigation.”

    Consumer misperceptions, nourished by alarmist media stories, are problematic as well. Too many people still view nicotine as a cancer-causing substance, according to Yach, while an increasing number of consumers mistakenly believes e-cigarettes are equally harmful or more harmful than combustible cigarettes.

    “Failure to correct misperceptions will keep smokers smoking and encourage governments to ban harm-reduction products, which we have seen happening at an alarming rate,” he said.

    Clive Bates, director of The Counterfactual, attributed the fierce resistance against working with the tobacco industry to a powerful narrative—“the industry’s interests are fundamentally irreconcilable with public health”—enhanced by aggravating factors, such as the fact that some people don’t like solutions provided by the private sector. The goal of many tobacco control officials, he said, isn’t harm reduction but annihilation. There is a sentiment of “one last push and we’re there,” Bates noted. E-cigarettes, in this account, are seen as a last-ditch survival strategy before the industry is killed off by taxes and regulations.

    Confronted with such a hostile environment, the industry should drive the technology transition, embrace the role of “policy champion” and lead innovation, said Bates (also see “Mapping the Future,” Tobacco Reporter, August 2018).

    Mark Kehaya, chairman of AMV Holdings, offered a striking example of the private sector’s success in converting smokers to vaping. Sixty percent of guests who shopped with his company in May 2017 were still customers 12 months later, he said—which compares with a success rate of the medical device industry of about 6 percent.

    The existing philosophy, noted Kehaya, treats smokers as patients who need medical treatment. A more productive approach, he said, would be to acknowledge that consumers enjoy smoking—and to provide them with a more pleasurable and less risky alternative experience.

    Viewed from that perspective, many of the regulations in place make little sense. For example, rather than increasing enjoyment, EU limits on e-liquid bottle sizes and nicotine strengths merely make alternative products difficult to use.  

    Advertising restrictions, meanwhile, prevent vapor companies from building a connection with their customers—something that would increase both product enjoyment and the likelihood of smokers converting to less-harmful vapor products.

    Regulators should make it quicker and easier to bring continuously better products on the market, according to Kehaya. “The iQOS application should have been a slam dunk,” he noted, referring to the modified-risk tobacco product application that Philip Morris International (PMI) submitted to the FDA in December 2016 and is still awaiting a decision on.

    Kehaya said the U.K. is the closest of any country to having a regulatory framework that will allow a smoke-free future. “Brexit offers a unique opportunity to make changes to laws that will accelerate that process,” he added.  

    Historical Accidents

    Indeed, throughout the conference, speakers repeatedly praised the U.K.’s enlightened policies for vaping. In 2015, Public Health England famously declared vaping to be 95 percent less harmful than smoking. Rather than banning or heavily restricting e-cigarettes, as other countries have done, the U.K. government has tolerated them on the market, allowing the sector to grow and improve its offerings.

    Today, 5 percent of U.K. citizens vape—more than twice the average share in the EU. At the same time, smoking prevalence has plunged. The U.K. now has the lowest rate of smoking in Europe after Sweden, where the tobacco market is dominated by a smokeless product that is outlawed in other EU member states—snus. Earlier this year, a report published by the House of Commons Science and Technology Committee said that the rules around e-cigarettes should be relaxed even further to encourage more people to vape instead of smoke.

    GTNF speaker Matt Ridley, a member of the House of Lords and acclaimed author, attributed Britain’s progressive stance to two historical accidents.

    In 2010, he related, advertising executive Rory Sutherland called on his friend David Halpern, who ran the Prime Minister’s Behavioral Insights Team (BIT), popularly known as “The Nudge Unit.” While they were talking, Sutherland pulled out a “cigalike,” which Halpern had never seen before. After investigating the category, Halpern and his team urged against a ban on the product.  

    “Indeed, we went further,” Halpern later wrote in a book about the BIT. “We argued that we should deliberately seek to make e-cigarettes widely available and use regulation not to ban them but to improve their quality and reliability.”

    The other historical accident, according to Ridley, is the history of harm reduction in the U.K. When the AIDS epidemic took off in the 1980s, Norman Fowler, who was the health secretary in Margaret Thatcher’s government, made the unpopular and unusual decision to provide heroin users with clean needles.

    Despite widespread opposition—critics said the initiative was condoning and encouraging illegal drug use—the policy was wildly successful. By 2010, only 1 percent of British drug injectors had HIV, compared with 18 percent in America and 48 percent in Brazil. The concept of harm reduction, therefore, got embedded in the British civil service system, according to Ridley. “The people who had worked in this key policy of harm reduction and drug use were also at the forefront when e-cigarettes came along,” he said.

    Ridley reminded his audience that the modern e-cigarette was invented as a harm reduction tool when the Chinese chemist Hon Lik designed a vapor device to help him quit smoking. Harm reduction, he said, is about relative risk; a product does not have to be harmless to be beneficial. “You don’t ban seat belts because they very occasionally kill people,” said Ridley.

    Much of the opposition to harm reduction products, he said, was based on an extreme version of the cautionary principle—better safe than sorry. “The problem with the extreme version of the cautionary principle is that it effectively holds the new to higher standard than existing technology,” said Ridley. He quoted a friend who memorably defined this principle as, “never do anything for the first time.”

    John O’Sullivan, senior fellow at the National Review Institute, noted that risk aversion had risen dramatically in Western society—a development that he considered a serious problem.

    O’Sullivan cited the example of a professor giving a lecture on Nazi Germany at an American university who was told his students might not come to the class because it would give them distress. The university set aside quiet rooms with comfortable sofas where students could recover.

    “If we become completely risk averse, we become different people,” cautioned O’Reilly.

    “In a world from which physical danger had been banished […] would physical courage be likely to survive?” he asked, citing from The Road to Wigan Pier by George Orwell. “The truth is that many of the qualities we admire in human beings can only function in opposition to some kind of disaster, pain or difficulty.”

    O’Sullivan stressed that once people have been given all relevant information, they are entitled to enjoy a product that makes life fun or a bit more bearable. A conservative rather than a libertarian, he doesn’t regard this principle as overriding everything else, however. “If something imposes an immediate threat to health, it should be open to control,” he said.

    And if the threat can be clearly reduced by scientific innovation, then suppliers have a moral duty—and in time probably a legal duty—to reduce that harm, O’Sullivan added. “They also have a duty toward their shareholders to reduce that harm or else they are going to face crippling legal expenses down the line,” he said.

    Peter Nixon, managing director of Philip Morris Limited U.K., related his experience at the forefront of tobacco harm reduction from a business perspective. Having worked for PMI for 15 years, Nixon’s career took an unusual twist when in 2017 the company announced its ambition to end the combustible cigarettes business.

    “The first half of my career, I was selling cigarettes, and in the second half of my career, I have been trying to get people off cigarettes,” said Nixon, reflecting on the unusual pivot.

    To help achieve its vision of a smoke-free world, PMI is encouraging smokers who cannot or will not quit to transition from combustible products to less-harmful alternatives such as its iQOS tobacco-heating device. Nixon stressed that in this process, the role of science and sales are equally important. “You can have the best products, but if nobody buys them, it is useless,” he said.

    Prior to directing PMI’s U.K. business, Nixon led the launch of iQOS in Russia and helped pave the way for the product in Japan. One of the lessons he learned from those experiences was that simply putting the product on the market—like the company was used to doing with cigarettes—is not enough. “When smokers make the change from a smoking product to an alternative, it’s a massive change in their lives, and they have to fully understand the benefits of what they are moving to,” he said. “We have to help consumers make that journey, and it has meant we had to change our business model.”

    To educate consumers, PMI has established dedicated iQOS stores in the markets where the product is sold. Unlike with cigarettes, the process doesn’t end with the sale. The company provides coaches to help smokers with their transformation, and many say that such support has been instrumental in helping them switch.

    “Six out of 10 who buy iQOS are able to completely quit cigarettes and switch to iQOS,” said Nixon.

    The Japanese Experience

    The most stunning example of smokers abandoning cigarettes, of course, has been in Japan, where between 2016 and 2018, cigarette sales declined by 24 percent. In 40 years of tobacco control and 10–15 years of tobacco harm reduction, this development is unprecedented, according to Delon Human, president of Health Diplomats, who moderated a discussion about the phenomenon at GTNF.

    Clive Bates once memorably said that the sky should be darkened by airplanes full of public health specialists flying to Japan to find out why this is happening. Yet somehow it is still the best-kept secret in public health—a condition the panelists attributed to the polarization of the debate. Putt off by the industry’s past behavior, many health advocates are finding it difficult to accept that the sector might be part of the solution.

    The panelists explored the factors that contributed to the rapid decline in Japanese cigarette sales and whether it would be possible to replicate the experience elsewhere. E-cigarettes are banned in Japan but tobacco-heating products are legal and have captured a whopping 21–22 percent of the market since they were first introduced to Japan in 2014.

    Remarkably, as became clear during the panel discussion, many consumers who switched to such products did so out of social considerations (about ash, smell, etc.) rather than health concerns—a reflection of the emphasis placed on harmony in Japanese society.

    Rupert Wilson of Strategic Consulting also pointed out that menthol cigarettes account for a comparatively large share of the Japanese combustible tobacco market. Smokers of such cigarettes, he speculated, might be more receptive to flavored tobacco-heating consumables than smokers of nonmenthol cigarettes. What’s more, Rupert added, the price gap between premium and value cigarettes is smaller in Japan than it is in many other countries, which makes it more likely that smokers of value brands will convert to higher priced tobacco-heating products.  

    The affordability of new products was repeatedly raised throughout the GTNF as a potential hurdle to harm reduction. With the majority of cigarettes now being consumed in emerging markets, panelists agreed reduced-risk products should be made available at a wide range of price points. “One size does not fit all,” said one panelist.

    While acknowledging the importance of tobacco harm reduction, Suzanne Wise, senior vice president of corporate development at Japan Tobacco International, cautioned that the industry should take care to retain its access to capital. “We must maintain the confidence of the financial markets,” she said.

    For decades, investors have looked at tobacco stocks as a reliable source of shareholder returns. The business model was relatively straightforward, with pricing increases offsetting volume decreases. The dramatic impact of noncombustible products in Japan has shaken some investors, according to Wise, causing them to ask pertinent questions such as: Is this the end of a trusted business model? Will the huge amounts channeled into product development pay off—and when? Will consumers transition to less profitable product options, and what impact might this have on margins?

    Wise then drew an analogy with the automobile industry, which is also in the middle of groundbreaking transformation. While there’s lots of excitement about driverless cars, she said, commercialization is still a long way off. “Carmakers stress that continuous improvement to conventional products must fund resolution of driverless technology challenges for a long time to come,” she said. “But there is no shortage of capital to fund research and development in the automobile sector, which suggests investors are open to disruption as long as it’s under control.”

    The same principle, Wise ventured, applies to the tobacco industry’s transformation. “JTI’s positive growth outlook in the noncombustible category is additional to the strength and sustainability of the traditional business,” she said. The company expects both to evolve in parallel over the next 15–20 years.

    Animal Spirits

    The FDA’s Sept. 12 announcement loomed heavily over the GTNF panel discussions, which, in addition to the Japanese experience, focused on risk communication, regulation and flavorings. Panelists lamented that the threatened ban on flavored e-liquids would extinguish the promise of vapor products as tobacco harm reduction tools, and many discussions focused on how to respond.

    Neil McKeganey, founder of the Centre for Drug Misuse Research at the University of Glasgow, urged the industry to establish a robust body of evidence so that it could contest proposed legislative changes with “something other than a purely commercial framework.”

    While doing so would not guarantee success, the absence of such evidence would guarantee failure, McKeganey said.

    “Little Vape,” he suggested, should become more like Big Tobacco in that respect—or risk losing domain. For example, when the FDA extended its deadline for premarket tobacco product applications, many vapor companies were at the cusp of initiating research. Yet instead of doubling down on those efforts, many simply grasped the opportunity to sell their products for a longer period, McKeganey lamented.  

    David Levy, professor of oncology at Georgetown University and an economist, asserted that the impact of regulations would depend on how they affect competition, which he believes is essential in developing lower-risk products.

    Controlled by a handful of large players, the traditional cigarette industry, he observed, is anti-competitive with high barriers to entry, no price competition and little innovation. The vapor industry, by contrast, has large numbers of players, low barriers of entry and many outlets in addition to mass market retail, which dominates in cigarette sales.

    The fierce competition in the vapor category has caused product quality to increase and prices to decline considerably in a short time. Regulation, said Levy, should maintain a level playing field so that competition remains.

    The GTNF concluded with an eight-member panel discussion moderated by Mark Littlewood, director general of the Institute of Economic Affairs. Instructed to rate their level of optimism about the regulatory environment on a scale of 1 to 10, the panel returned a gloomy average of 4.5. Yet when an audience member later asked what to tell a potential investor in the vapor sector, the panelists were unanimous in their advice—invest now. One speaker pointed to the $800 billion cigarette market that could be eaten into, another expressed confidence that science would eventually prevail, while yet another said that it would require only three to five countries with U.K-style regulations to make the global vapor market take off.

    Despite its considerable promise, tobacco harm reduction continues to face many challenges, including inaccurate consumer perceptions, hostile politics and misguided regulations. In addition, there is the problem of deviating goals: While the industry is trying to get people off of smoking, many in the medical community want to get them off of tobacco and related products altogether. But one thing became crystal clear during the 2018 GTNF: If harm reduction fails, it will not be due to a lack of industry commitment to the concept.

  • Expanding applications

    Expanding applications

    Originally developed as a tool to reduce waste, reconstituted tobacco is used for an ever-greater variety of tobacco products, including those within the rapidly growing heat-not-burn segment.
    By George Gay
    The U.S. Food and Drug Administration (FDA) seems to be moving inexorably toward requiring that all cigarettes sold in the U.S. deliver what is being described as minimally addictive levels of nicotine. However, it is not clear whether the FDA is likely to require that nicotine levels are reduced gradually to minimally addictive levels or in what would surely be a wildly uncharacteristic one-throw-of-the-dice dislocation of the status quo.
    In any case, there are several ways in which nicotine levels can be reduced, including through the use of reconstituted tobacco (RT) in cigarettes. So the question arises as to whether this material is a contender in the quest to reduce nicotine levels in cigarettes while maintaining a taste that would be acceptable to smokers.
    Iqbal Lambat, president and CEO of Star Agritech International, has no doubt that RT can play a significant role in reducing nicotine. RT is by its nature lower in nicotine than leaf tobacco because of the impact of water dilution during production, which means it provides the ideal ingredient for low-nicotine—and low-tar—cigarettes, he says. However, he added, not all RT would be as effective as nanofiber RT is in this role because not all RT could be used at the higher substitution levels at which nanofiber could be used. This is because nanofiber, which he describes as being the gold standard of RT in terms of its price/quality ratio, has a higher aromatic tobacco flavor and aroma provided by the higher level of tobacco fines in its blend, which amounted to about 70 percent. On top of this, the taste of RT can be modified either by blending the ratio of flue-cured Virginia and burley fines to achieve an American blend profile or by adding oriental fines to achieve a more aromatic result. Casing can also be added to the blend before it was turned into sheet.
    Meanwhile, Alex Boone, senior director of engineered papers business development at SWM, says his company has developed various technologies to selectively reduce the nicotine level from tobacco material while keeping the original tobacco taste. “Compared to leaf and other reconstitution processes, our two-step papermaking technology offers unique capabilities to adjust the tobacco chemical profile, including nicotine level,” he says. “We believe this will be a very helpful tool for cigarette manufacturers. In addition, SWM has also initiated the development of other reconstituted botanical (nontobacco) materials for cigarette applications. While this new product has no nicotine, it shows a positive impact on taste. So, by adding this material to a tobacco blend, cigarette manufacturers can adjust nicotine deliveries.”
    The way in which RT can assist manufacturers to meet lowered nicotine requirements implies that it has wider applications in respect to meeting regulatory demands. Asked if there were any national or regional regulations affecting demand for reconstituted tobacco, volume-wise or in respect of the product characteristics being sought by tobacco manufacturers, Boone said: “Paper RT is an industrial product whose physical and chemical properties can be adjusted and controlled. This flexibility makes paper RT valuable for tobacco product manufacturers because they can partner with SWM and specify properties that will comply with the regulations that apply to them. For SWM, product regulations provide an opportunity to innovate and deliver the end product that customers need to succeed.”
    Noncombustibles
    Commercial sales of cigarettes with minimally addictive levels of nicotine are still in the future of course, while right now one of the most exciting opportunities for RT is being presented by those devices variously known as heat-not-burn or tobacco-heating products but which will be referred to here by the term used by the FDA, noncombusted cigarettes. Sales of these products have been plateauing in some markets, but their potential seems to be largely undiminished.
    Certainly, that seems to be the view of Bruno de Veyrac, the next-generation products director at SWM. He said that noncombusted cigarettes have been a fast-growing product in some countries, such as Japan, and have shown significant potential in other countries and regions. “Although there have been ‘plateauing trends’ in some regions, SWM believes that the demand for noncombusted cigarettes will continue to grow, partly because, over time, noncombusted offerings in different regions will be adjusted to local preferences and demands,” he said.
    In fact, de Veyrac was so confident that he said he believed the industry was just starting to explore RT applications for noncombusted cigarettes. “In the future,” he added, “the flexibility of the two-step papermaking process will allow many specific blends to match manufacturers’ own product developments and unique expectations. SWM has set new manufacturing standards for selection and control of tobacco feedstock, process specification settings and monitoring, traceability, hygiene and other product specifications. This means, in part, that it has the capability to produce strips and bobbin forms for any kind of existing noncombusted cigarette design.”
    So far, de Veyrac said, the impact of non-combusted cigarettes on RT demand had been very significant, because almost all these products used 100 percent RT. “SWM’s papermaking technology,” he added, “is a key component in achieving the vital aerosol formation and generating the taste the consumer expects. With SWM’s technology and capabilities, the nicotine delivery and other key components can be adjusted to the required level and within tight tolerances, while providing the right tobacco taste in the aerosol.”
    Lambat also said that RT was the product best-suited for noncombusted cigarettes. RT provided the best smoke experience because, at the operating temperature used, RT delivered “smoke” that normal tobacco could not provide at such temperatures.
    It was early days in this emerging sector, Lambat said, and currently production methods were driving usage. For instance, Philip Morris International’s Heets used a patented crimping technology, and this meant that other manufacturers had had to find, or would-be manufacturers needed to find, an alternative method of using RT in their sticks. One such product comprised a cut form of RT that could alter the flash point at which the RT generated the required “smoke.” The main types of RT that were suitable for this application were the cast-band and nanofiber RTs.
    Versatile tool
    We tend to hear much about the demand and opportunities that noncombusted cigarettes present for RT, but what was once a poor-man’s tobacco is, in its many developed guises, now sought after for many applications. RT had been developed in the 1970s to use tobacco dust and waste generated during the primary and secondary processes, said Lambat. Before then, this waste would have been discarded or used as fertilizer, so converting it to RT became a cost-saving operation. All multinational and Chinese manufacturers now had their own RT factories but did not provide contract manufacturing services, so most smaller manufacturers purchased RT and still discarded their dust.
    RT, said Lambat, was attractive for combusted cigarettes because it could be used at up to 20 percent of a blend, at a cost lower than that of cheap tobacco filler. Other considerations were that it provided the ideal ingredient for low-delivery cigarettes and, because of its relatively neutral impact, a good tool for the tobacco blender. However, there was a growing demand for flavored types of RT, such as Virginia type, burley type, oriental type, and blended type, etc.
    Indeed, RT seems to be taking on an ever-increasing number of roles. Boone said that the use of reconstituted tobacco helped SWM’s customers improve cigarette blend consistencies and physical attributes such as filling power, pressure drop and smoking deliveries. “At the same time, SWM has applications for roll-your-own and make-your-own blends it is looking at a sustainable market for cigar and cigarillo wrappers and binders and has recently developed RT specifically for shisha/molasses blends and smokeless tobacco,” he said. “SWM offers a full range of tastes, from flue-cured Virginia to oriental, dark air-cured, fire-cured or blended, with or without casings/flavoring.
    “And in line with this innovative approach, SWM is introducing Nexfill, a natural tobacco filler substitute. Using a very specific and select tobacco feedstock and design, it is available in a variety of grades with consistent quality and performance that mix perfectly within existing blends while delivering a neutral taste profile. And it can help our customers more effectively manage their overall supply chain costs.”
    But it is not only in the spheres of blend-modification, delivery controls and cost-savings that RT comes into its own. Tobacco manufacturers are seeking to reduce their environmental impact by reducing waste and what better way can they do that than by recycling tobacco stems and other byproducts from the tobacco supply chain in an operation that also reduces costs?
    “Otherwise,” Boone said, “RT offers high manufacturing yields in cigarette factories because it has no objectionable stems and generates little loss in primaries and secondaries. And this high productivity is present too during noncombusted cigarette manufacture because RT can be used in the primary process with no need for special equipment.
    “In addition, RT offers consistency because, compared to leaf, it is a uniform material, something that is important both in respect of combusted and noncombusted cigarettes.” In the case of the latter, de Veyrac said, a consistent RT “is key in respect of producing a consistent aerosol.” And in the case of the former, Boone said, “SWM pays a lot of attention to raw material blending and processing to ensure very limited product-characteristic fluctuations over the years, so RT is usually considered by blenders to be a major element of the ‘foundation blend’.”
    Drivers of demand
    Given the wide range of applications that RT now has it is surprising perhaps that demand is not higher than it is. Demand for paper RT had been lower globally for the past decade, said de Veyrac, in line with the cigarette market attrition that had occurred outside China. “In China, SWM has seen demand switch from slurry/cast leaf RT to paper RT as factories in that country seek to reduce tar in conventional cigarettes,” he said. “But our company expects to see demand for paper RT increase with the growth of new-generation products because the usage of RT in non-combusted sticks is eight to 12 times higher than it is in conventional cigarettes.”
    Since growth is expected to come from increased sales of non-combusted cigarettes, the rise in demand is expected to follow the geographical expansion of these products. “For the time being,” de Veyrac said, “Japan and Korea seem to be very dynamic markets for noncombusted products, but SWM expects to see significant demand occurring also in the countries of the CIS [Commonwealth of Independent States] and Europe. The U.S. market is predicted to become a big player in the field of noncombusted cigarettes, though the timing will be dependent on the Food and Drug Administration’s approval processes, while in China any market development will depend on when the State Tobacco Monopoly Association authorizes the sale of noncombusted products.”
    SWM is probably not too concerned about where growth occurs first because, it says, it has strong manufacturing footprints in the EU, the U.S. and China. The company estimates that the worldwide operational capacity for paper RT is about 335,000 tons, with SWM and its joint venture in China accounting for about one-third of that capacity. Outside China, the capacity is estimated at about 185,000 tons, with SWM, the largest independent paper RT manufacturer, accounting for about 45 percent of that capacity. Additionally, it says, most, if not all, of the non-SWM capacity is accounted for by cigarette manufacturers and is not available on the market.
    What seems to be clear is that no new paper RT capacity will be needed for some considerable time, if ever, because SWM estimates that only 50 percent of global capacity is used today. This means, the company says, that there is a great opportunity for this type of RT to support the expansion of noncombusted cigarette demand.
    Lambat estimates that, for combustible cigarettes only, the maximum demand worldwide, excluding China, is about 315,000 tons. This was calculated, he said, on the basis of 3 trillion sticks at a usage rate of 15 percent. However, Lambat clearly believes that there is still potential for further demand. A fair percentage of small and medium-sized companies do not yet use RT, and, for instance, there are no known users in sub-Saharan Africa. The Algerian Monopoly does not yet use RT, and it alone could lift demand by 1,800 ton to 2,000 tons per year.
     
     
     
     

  • Into the cloud

    Into the cloud

    Improving tobacco excise tax management with automation
    By John Beaty
    Tobacco excise taxes are almost as old as the United States. In 1790, Alexander Hamilton proposed a tobacco excise tax to the Congress. The tax was passed by Congress in 1794, modified shortly after, then later suspended and repealed. However, in the mid-1860s, tobacco excise taxes were implemented once again, and since then both the number and type of tobacco excise taxes have proliferated, creating a complex web of rules and regulations.
    Today, governments at the federal, state and local levels all use a diverse set of tobacco excise taxes to raise revenue. As a result, tobacco manufacturers, wholesalers, distributors and retailers face a complicated excise tax regulatory environment in which tobacco excise taxes vary greatly depending on product and region, forcing these organizations to invest significant resources into excise tax determination and compliance management efforts. The vast majority of these companies manage excise tax determination and compliance using custom spreadsheets or add-ons built in-house to their legacy enterprise resource planning (ERP) applications.
    These internal legacy excise tax management systems come with a plethora of hidden costs and risks for tobacco companies. They must devote precious resources to monitoring the constantly evolving regulatory environment and then updating their in-house systems to reflect these changes. If they make even small errors during these updates, they can find themselves facing significant noncompliance penalties. In addition, all this work on excise tax management distracts them from their main strategic focus: the production, marketing, distribution and sale of tobacco products.
    Unlike the tobacco industry, many companies in the motor fuel industry and other industries use cloud-based, automated excise tax determination and compliance management solutions. These solutions automate resale or exemption certificate collection preparation and filing of tobacco returns, validation of transactional details, and other aspects of excise tax management, all while also providing detailed tax reporting.
    By following the lead of these other industries in moving to cloud-based, automated excise tax management solutions, tobacco companies can reduce compliance costs and risks and concentrate more on the strategic initiatives that are central to their success.
    Increasing tax management complexity
    In the past, when the tobacco excise tax environment was simpler, companies spent and risked little if they used custom spreadsheets and in-house ERP add-ons to manage their excise tax determination and compliance. However, today the tobacco market, and with it the tobacco excise tax environment, is much more complex. Tobacco companies now sell a wide variety of products such as vapes, snus and heat-not-burn products. There are new distribution channels where manufacturers or wholesalers go direct to consumers and retailers act like wholesalers. While previously only a few states collected excise taxes on electronic cigarettes and vapor products, the number of states collecting taxes on these new tobacco products, and the number and types of taxes they have implemented, is growing. The U.S. Food and Drug Administration (FDA) has also recently enacted a rule to regulate all tobacco products, not just traditional cigarettes, further increasing excise tax complexity.
    In addition, taxes are increasingly calculated using multiple units of measure—sticks, packs, ounces and milliliters. If current internal legacy systems are hard-coded to handle only one unit of measure, it can require major changes to reflect these new units of measurement. Meanwhile, there are new requirements for electronic filing that require e-filing formats that follow FTA standards. While FTA standardization will be beneficial in the long run, in the short-term it will require IT and tax analysis resources to update their internal legacy systems to reflect these new mandated requirements.
    Excise tax systems built in-house come with high costs and risks
    The growing number and types of excise taxes, and constant changes being made to these taxes, mean that tobacco companies are now investing significant resources into updating and maintaining their internal legacy excise tax management systems—whether these be custom spreadsheets or in-house built legacy ERP add-ons. Not only do tax departments need to keep track of changes to all the regulatory rules, rates and forms, but they also need to update their spreadsheets and ERP add-ons to reflect all these changes.
    But that’s not the only expense. Often, human error can be one of the costliest parts of excise tax management. For many tobacco companies, spreadsheets are the go-to tool for managing excise taxes, and these spreadsheets are chalk full of manual processes. Even small errors can affect reporting, and these errors can result in significant penalties for non-compliance. The potential costs are high, and that doesn’t even begin to include the opportunity costs associated with companies investing time and money into this nonstrategic work.
    Automating tax management in the cloud
    To avoid the costs and risks associated with in-house tax systems, industries with similar excise tax complexity, such as motor fuel supply and distribution, use cloud-based, automated excise tax management solutions. These comprehensive solutions support tax determination, calculation, return preparation and filing. This offloads the massive effort required to track tax rules, rates and reporting requirements, as well as the work needed to build and maintain custom spreadsheets and in-house built legacy ERP add-ons. And, by leveraging tobacco excise tax expertise across multiple industry players, companies benefit from improved efficiency and reduced compliance risk.
    With cloud-based, automated excise tax management solutions, tobacco companies can eliminate manual entry of regulatory changes, which significantly reduces the risks associated with human error. In addition to the cost savings that come with the sharing of resources for tax research, testing and automation, there are additional savings associated with moving excise tax management to the cloud. Cloud solutions reduce the need for operational IT support and hardware resources while also providing enhanced levels of reliability and scalability over on-premises deployments.
    Embracing change in the tobacco industry
    Cloud-based, automated excise tax management solutions enable tobacco companies to leverage third-party tax expertise and state-of-the-art tax automation systems, all without massive capital and time investment. This reduces compliance risk and frees up valuable resources to focus more on strategic projects that improve business outcomes. Tobacco companies do not want excise tax management to be a core aspect of their businesses—and with cloud-based, automated excise tax management solutions, it does not have to be.
    John Beaty is the general manager of Avalara Excise.

  • Complex components

    Complex components

    Individualization, the environment and next-generation products are the key drivers of today’s filter business.
    By Stefanie Rossel
    In late July, Rhodia Acetow announced the launch of two new tow grades—7,0Y15 and 9,5Y12—complementing the company’s range of super-slim tows. With its broadened portfolio in this segment, Rhodia Acetow caters to a trend in the tobacco landscape that started roughly a decade ago and since then has gathered momentum: As consumption of combustible cigarettes continues to shrink on a global basis, customers are looking for an ever-greater variety of products.
    Individualization, customization and differentiation have become buzzwords throughout the tobacco industry, and filters play a major role in this development. In the future, special filters and filter innovations are expected to be the main differentiators and growth drivers in the traditional cigarette segment. According to data that Rhodia Acetow presented during its Filter Colloquium in April, the market of special filters was around 1,100 billion sticks in 2016, which corresponds to 19 percent of world consumption.
    Again, according to Rhodia, charcoal filters currently account for 48 percent of all special filters, super-slims rank second with 23 percent followed by recessed filters at 10 percent. With a 6 percent market share, capsule filters have now overtaken nonwrapped acetate (NWA) filters (5 percent). Among special filters, capsule filters and super-slim filters are the fastest-growing segments; the latter category is expected to stand at slightly below 700 billion sticks by 2022, with growth coming more or less exclusively from China, where analysts forecast an increase of 27 percent by 2021.
    The trend keeps filter makers and raw material suppliers plenty busy. “We’ve seen a large growth in our flavor capsule filters, our filters that include a hollow acetate tube and our Dual Sensation filter, which allows consumers to include both,” says Colin Fairs, head of the European development center of Essentra, a supplier of special filters and scientific services based in the U.K.
    “The Dual Sensation provides a number of different combinations for consumers to choose from, including either a capsule segment with a carbon segment or a capsule segment with a visually distinctive filter segment, such as the Corinthian,” says Fairs. “These have proved particularly popular as they present consumers with the choice and ability to personalize their product through several unique taste, smell and visualization options.”
    For suppliers of special filters, the ongoing desire of consumers for new and different products has brought about its own challenges. “The biggest challenge is the manufacture of so many different products, all with specific parameters that we must ensure are correct and to the highest quality standard,” he says.
    Before 2005, explains Fairs, the only parameters that were routinely considered were length, weight, circumference, pressure drop, roundness and, where applicable, carbon loading. “Now, with a rise in capsules and tube segments, we must consider all of the above plus parameters such as capability requirements for capsules, filament distribution, capsule size, capsule positioning, tube stability, tube wall thickness and tube hole centricity when manufacturing our filters,” he says. “It is an ever- expanding list, which continues to grow.”
    Stable demand
    The world market for filter tow, as highlighted at the Rhodia Filter Colloquium, decreased less in 2017 than did the global cigarette market. According to Euromonitor International, global cigarette volume sales including China declined by 1.4 percent in 2016–2017. Excluding China, they declined by 3.1 percent.
    However, thanks to volume growth in the world’s biggest cigarette market, China—which after two years of decrease returned to slow growth in 2017—the pace of overall decline has slowed down. The world’s cigarette retail volume recorded the best year-on-year performance since 2014. Euromonitor even projects a relative volume stability including and excluding China over the next five years.
    Global filter tow consumption declined by 0.3 percent to 740,000 tons in 2017, according to Rhodia Acetow. The decrease was mainly due to a 0.8 percent drop in the world’s largest cigarette market, China, which consumed about 290,000 tons of filter tow in 2017. Of that, 31,000 tons were imports, a slight reduction.
    As far as individual regions are concerned, minor growth was observed in Latin America (23,000 tons, +3 percent), Europe (131,000 tons, +3 percent), Asia (145,000 tons, +1 percent) and the Commonwealth of Independent States (36,000 tons, +1 percent) in 2017. The Middle East, one of the world’s few growth regions for tobacco products, saw an increase of only 1 percent to 35,000 tons last year, down from 24 percent in 2016. With 41 percent in 2017, Africa, which consumed 32,000 tons last year, showed an even more impressive growth rate.
    “With a large amount of strict regulation around the world, the amount of innovation is limited in some markets,” explains Fairs. “Therefore, the most interesting markets are those where there is a lot more freedom for us to create and introduce more novel filters. The Middle Eastern and African (MEA) markets are still relatively young and more open, with legislation focusing more on smoking in public places, advertising, packaging and imported goods, rather than tobacco content, ingredients and flavorings. Furthermore, according to 2017 Euromonitor data, overall the MEA region has seen a steady growth since 2011. In addition, the China market, with a strong premium sector, still offers good potential for our ‘more interesting’ filters.”
    New regulation expected
    The filter tow market is divided between a handful of international players. Eastman leads the market, with a share of 28 percent, followed by Celanese (25 percent), Rhodia Acetow (21 percent), Daicel (18 percent) and Mitsubishi (5 percent.) In addition, there are several Chinese manufacturers that together account for 3 percent, according to Rhodia Acetow.
    Concentration of the sector was almost taken to new heights in mid-June 2017 when Blackstone, the holding company of Rhodia Acetow, and Celanese were in talks to form a joint venture. In late 2016, U.S. private equity firm Blackstone Group had acquired Rhodia Acetow’s filter tow division from its holding company Solvay, a Belgium-based supplier of advanced materials and specialty chemicals.
    The deal between Blackstone and Celanese would have created the world’s largest acetate filter tow company. In March of this year, however, the companies abandoned the plan because of what they described as “excessive” divestment requirements by European Union (EU) antitrust regulators.
    In addition to the challenge of supporting the tobacco industry in its efforts to create more individualized products, manufacturers of filter tow and special filters are faced with regulatory and environmental requirements.
    Recently, titanium dioxide (TiO2), a delustering agent that has been used in paints, printing inks and many other applications including filter tow for about 100 years, made it back into the headlines as a possible cancer-causing substance. Although TiO2 has no substance-specific toxicity, is not mutagenic or genotoxic, it is currently under review by the EU for classification as potentially hazardous to health. Needless to say, such a classification would have major implications for tow manufacturers. While there is no regulation as of yet, Rhodia Acetow plans to introduce a TiO2-free standard tow in November (Also see “Filter Forum,” Tobacco Reporter, June 2018.)
    Going green
    The biodegradability of cigarette filters remains an important topic for filter and tow manufacturers. Due to its excellent retention and filtration properties, cellulose acetate tow today is the most widely used filter material. Its decomposing ability, however, is rather poor and further compromised by the synthetic glue used to bond the individual fibers together when forming the filter rod.
    The most commonly used resin is triacetin, a plasticizer. Decomposing of a cellulose acetate filter can hence take up to a decade. Cigarette butt littering is a serious environmental problem around the globe. It is estimated that three quarters of the 6 trillion cigarettes smoked annually do not end up in a dustbin, but as litter. This corresponds to a mountain of 750,000 tons of waste worldwide.
    Manufacturers of filter tow and filters have developed a range of products to tackle this problem. “With regard to biodegradability, Essentra has and still offers a wide range of filters—paper, infused, ROA, BiTech—as more degradable alternatives to cellulose acetate tow,” says Fairs. “We continue developments in this area, as well, and are working with a number of customers to continue developing alternatives in this area.”
    In June, Rhodia Acetow launched its new generation Rhodia DE-Tow, which has been designed for accelerated biodegradability in versatile environments. The tow has been recognized with three third-party biodegradability certificates.
    The segment has also attracted players that had not supplied the tobacco industry before. McAirlaids Vliesstoffe, a German manufacturer of tows, woven and nonwoven fabrics specialized in absorption materials, uses a patented manufacturing process to produce cigarette filters made from pure cellulose fibers with no glue added. The littered filters will disperse within weeks, the company claims.
    Several Chinese suppliers offer cigarette filters made from polylactic acid thathave similarly good biodegradation properties but cost more than conventional cellulose acetate tow filters. Bio Fil of the U.S. has turned to jute to manufacture an environmentally friendly cigarette filter (see sidebar).
    High hopes on HnB
    As far as future business opportunities are concerned, filter and tow suppliers are eyeing the heat-not-burn (HnB) segment, which has been growing rapidly in some markets. HnB consumables, however, require only an estimated 50 percent to 80 percent of the cellulose acetate tow used in conventional cigarette filters, which means they cannot necessarily be counted on to make up for losses in conventional product sales.
    Technologically, the filter of an HnB consumable is more complex than that of a combustible cigarette, and it has to meet different requirements. Part of the function of the HnB filter is to support aerosol formation through cooling. At the same time, it must survive the heating process. In contrast to conventional cigarette filters, filters of HnB consumables must have a low filtration efficiency to achieve the desired tar:nicotine ratio, as the tobacco weight in an HnB product is only 30 percent to 40 percent of that of a combustible cigarette. In addition, an HnB filter must have sufficient structural strength to allow for insertion into the heating device.
    Research and development in the field of HnB filters hence has top priority for most suppliers. “We are extremely active in this area across all the areas of our business,” confirms Fairs. “We are making commercial orders, working with our partners in innovation to develop new materials/filter constructions and are also developing the analytical capability within our Scientific Services business to be able to analyze exactly how these new developments and existing products perform,” he says.
     

    Biodegradable filter maker seeks investors

    When smoker Thuan Lu, who used to discard his finished cigarette butts in his backyard, realized how many butts had accumulated—and how big the problem must be on a global scale—he decided it was time to do something. “Even after months lying out in the open, the filters had not decomposed,” he says.
    Thuan, a Chinese-born U.S. citizen living in Centennial, Colorado, started researching the composition of traditional cigarette filters and their poor degradation properties. According to the Center for Marine Conservation, cigarette butt litter accounts for one in every five items collected during cleanups, making it the most prevalent form of litter on earth. Having decided to fight this environmental problem, Thuan began to experiment with various natural materials in his little workshop, searching for a fully biodegradable, organic filter.
    In the end, jute showed the best results. Jute is a long, soft, shiny vegetable fiber that can be spun into coarse, strong threads. It also features an exceptionally low thermo-conductivity—an essential property for use in cigarette filters to prevent smokers from burning their lips. As the hard fibers were unsuitable for use in a cigarette filter, Thuan developed a process for which he hopes to receive patent protection in October. The method consists of decompressing, drying and purifying the fibers and results in fibers many times thinner than a human hair.
    With this raw material, Thuan designed a filter that, he claims, is highly absorbent and has better filtering properties than conventional acetate plugs. “Filter specifications and draw strength can be adjusted as required,” Thuan says. “Compression and thickness of the filter paper will solve this requirement.”
    The filter has been designed in such a way that it will break into two parts when discarded.
    “Thus, environmental moisture can enter the filter and break up the fibers within hours,” explains Thuan. “The fibers will then disperse with the wind or water current and turn into compost. The filter will break down within six months.” Apart from its biodegradability and filtering potential, Thuan adds, the Biofilter, as he has branded it, is as inexpensive to manufacture and produce as a traditional cigarette filter. “When the FDA [U.S. Food and Drug Administration] proposed nicotine reduction in cigarettes, I came back to modify the filter. I now do believe that our filter will reduce the nicotine level in cigarettes, too.”
    To market his invention, Thuan in 2017 founded Bio Fil, which was qualified by the Securities and Exchange Commission to sell shares in March 2018. Now, the company is looking for investors.
    “Currently, we have not manufactured any filter for the market yet,” says Thuan. “To do this, we need to apply to the FDA for permission. We also need to get equipment to use in the process, and we don’t have the funds to do this.”
    Tobacco companies to whom he presented his invention said they first wanted to see some consumer tests, he relates. “So far, we only do tests of the filters by making samples of the filters attached to smoking rods and then give them out to friends to try,” says Thuan. “We have not sent the filter to the lab for a formal testing yet because we just don’t have the funds needed. If we can find and have a large investor or company who is willing to put the money to pay for all this, we won’t have any problem getting a formal test.”
    He says that Bio Fil is also actively seeking companies that will rent out their machinery to produce the product outside of the U.S. “The reason for this is that we don’t have the capital needed and we also do not have to deal with the FDA. The FDA application fee for tobacco products is at least $750,000. After all, our point is to produce a biodegradable filter to replace those on the market out of environmental concerns.”—S.R.
     
     
     

  • Only half the story

    Only half the story

    The Guardian recently published an article criticizing the tobacco industry for tolerating child labor in leaf production. The Eliminating Child Labour in Tobacco-Growing (ECLT) Foundation says the publication is not telling the whole story—and thus putting children at risk. Below is the ECLT Foundation’s response to The Guardian’s coverage.

    Child labor in tobacco growing supply chains:

    How The Guardian puts children at risk by not telling the whole story.

    Recent heightened public attention on the unacceptable situations faced by children and families working in tobacco growing shines a light on violations of human rights otherwise largely and historically kept in darkness.
    The blunt truth is that the health, safety and development of millions of children is at risk every day in countries from Malawi, to Mexico, Indonesia to the U.S. Though the spotlight is turned on the children working in tobacco fields, it is crucial to understand that this is a major threat to 152 million of the world’s children, in every sector and every region around the world, strongly linked to poverty, cultural norms, lack of access to education, disasters and conflicts. It is not limited to a single supply chain, or the sole responsibility of multinational companies.
    The international community must not be afraid to recognize and openly discuss child labor through inclusive collective stakeholder dialogues, as is mandated by the Global Sustainable Development Goals (SDGs). This is the only way to make sustainable and genuine steps forward, which bring about institutional and generational change.
    Nonetheless, there is a significant piece of the narrative missing in recent highly publicized articles such as The Guardian’s piece “Child labor rampant in tobacco industry,” which fundamentally and conveniently fails to tell the whole story. The Guardian must, therefore, be held accountable for this failing.
    The article, citing Vera Da Costa e Silva, head the WHO’s Framework Convention on Tobacco Control (FCTC), states that child labor in tobacco agriculture is “a scandal for which the multinational companies have a direct responsibility.” This assertion is true, in terms of businesses’ responsibly to respect human rights in all of their activities. This assertion is also limited and lacking context. It is potentially a real and present threat to the livelihoods of agricultural communities comprised of over 40 million farmers in 124 countries where tobacco is grown around the world.
    The Guardian’s series of articles, whether on purpose or by omission, wrongly promotes a supply chain approach to fighting child labor in tobacco growing, which goes against the comprehensive area-based approach of the UN agencies that deal with labor rights and agriculture, the International Labour Organization (ILO) and the Food and Agriculture Organization (FAO). The ECLT Foundation reached out to the author of the article, Sarah Boseley, explaining our concerns and asking for any comment. Boseley responded that “the focus of our coverage was the responsibility of the big tobacco firms.” This explains the supply-chain approach but doesn’t address concerns about the limited narrative of the article.
    The ECLT Foundation and other child labor and children’s rights experts, including The Global March against Child Labour, Stop Child Labour Coalition, UNICEF, The UN Global Compact and Save the Children International, agree with the ILO and the FAO that collaborative, multi-stakeholder area-based approaches produce measurable and sustainable results against child labor.
    Isolating the tobacco supply chain, or any single supply chain, increases the risk of “children simply moving from one supply chain to another, or into a more hidden form of child labor, or, if they are below the minimum age for work, from moving simply from hazardous to non-hazardous child labor” (ILO 2017).
    This is the inconvenient truth that neither The Guardian nor Vera Da Costa e Silva will publicly address. This makes the articles reductive and irresponsible, giving readers an agenda-driven, over-simplified glimpse of child labor in agriculture, which inconsistent with the clear, global mandate for integrated and cooperative solutions set out for the world in the SDGs.
    At best, this is biased, narrow reporting, which goes against internationally recognized best practice for fighting child labor.  When the lives and livelihoods of an estimated 1.1 billion people depend on agriculture, including tobacco growing, any reporting bias from a major newspaper must be highlighted and challenged.
    At worst, the articles place the agenda of the World Health Organization’s tobacco-control program above other internationally accepted treaties, which guarantee the full range fundamental rights including development, education, health and decent work.
    By  prioritizing evidence provided by World Health Organization experts, rather than experts in children’s rights, rural development or decent work, The Guardian seems to have forgotten the lesson it understood in the 2012 article, namely that “Eliminating child labor and improving conditions within our supply chains must be a collaborative process with all stakeholders taking on responsibility.” Governments, businesses, unions, employers’ associations, civil society, communities and children themselves all have a role to play (UNGPs, ILO).
    Children, farmers and families working in tobacco growing have the right to the same support that those farming other crops do. Governments of nations that depend heavily on tobacco agriculture must be encouraged and enabled to develop and implement strong and comprehensive policies to fight child labor, promote decent work and uphold the human rights of all of their citizens.  Including tobacco along with all other agricultural sectors, governments, unions, and other stakeholders, and expecting concrete actions against child labor is the sustainable way forward.
    Anything short of this risks violating ILO Convention 111 against discrimination, which guarantees the “equality of opportunity and treatment in employment or occupation” for all workers.  The Guardian also fails to consider this angle.
    There are many lenses through which to examine the problem of child labor in tobacco agriculture, including public health, rural development, creating shared value, or safeguarding children’s rights.  In the end, the only acceptable approach is one that favors children and that promises to best promote all children’s rights, including their right to health, as well as decent work for all workers.
     

    About the ECLT Foundation

    The ECLT Foundation is committed to collaborative solutions for children and their families that combat the root causes of child labor in tobacco-growing communities.
    The organization advocates for strong policies, share best practices to multiply our impact, and engage rural families so they can benefit from farming while ensuring that their children are healthy, educated, safe from exploitation, and encouraged to reach their full potential.
    Based in Geneva since 2000, ECLT is an independent Swiss foundation with UN ECOSOC Special Consultative Status.
    For more information, visit www.eclt.org.

  • Keeping track

    Keeping track

    The Djura, offers 99.98 percent efficiency and 100 percent reliability, according to Boikon.
    (Photo courtesy of Boikon)

    Boikon has developed technology to help tobacco manufacturers comply with the EU’s pending supply chain security requirements.

    By Taco Tuinstra

    The clock is ticking. In April, the EU published the long-anticipated technical standards for its tobacco products tracking-and-tracing system. The system and its associated security features should be in place by May 20, 2019, for cigarettes and roll-your-own tobacco. Other tobacco products must comply by May 20, 2024.

    The track-and-trace system is part of the 2014 revised EU Tobacco Products Directive (TPD2) and aims to reduce the prevalence of illicit trade, which amplifies the negative health effects of tobacco use, according to the EU. By making it easier for people to purchase tobacco products, the thinking goes, illicit tobacco products lower the barrier to consumption. Illicit tobacco products are often substantially cheaper than legal products, and they are less likely to comply with manufacturing standards and rules intended to discourage consumption, such as bans on certain ingredients and requirements to carry health warnings.

    The illicit trade also causes governments to lose income. EU tax authorities miss out on an estimated €11.1 billion ($13.05 billion) in revenue annually because of tax-avoiding tobacco products. Making matters worse, the illicit tobacco trade is believed to fund other forms of organized crime, such as human trafficking and terrorism.

    To combat illicit trade, the EU has come up with an intricate system to track all tobacco products in the EU throughout the entire supply chain, from the time they leave the production line until they are sold to the consumer at a retail outlet. Doing so, the EU hopes, will prevent stock from being diverted away from the official channels and out of sight of regulators.

    Needless to say, developing an effective system for such a large and diverse market is an ambitious undertaking. According to the European Smoking Tobacco Association, tracking and tracing tobacco products in the EU will require monitoring the movements of around 29 billion packaging units per year, or 80 million units per day.

    The system adopted by the EU requires each tobacco product to be marked with a unique identifier. In addition, each packet will have to be equipped with at least five different types of authentication elements. At least one of these elements must be visible to the human eye; at least one must be invisible—that is, detectable only with purpose-built tools or professional lab equipment—and there must be at least one “semi-covert” feature. The latter is invisible to the human eye but can be detected with nonspecialist equipment such as a UV flashlight.  

    The unique identifiers must be generated and issued by a national “ID issuer.” To ensure its independence from the tobacco industry, the ID issuer will be appointed by the government of each member state.

    In the meantime, each manufacturer and importer of tobacco products will have to recruit a data storage provider to host the traceability data of its products. Upon approval of the primary data storage provider, the European Commission will select a secondary repository. This one will store a copy of all traceability data so that all member state authorities have access to a single data set showing all product movements within the EU.

    Requiring unprecedented data transfers and a robust IT infrastructure, the EU’s plan has sent manufacturers and suppliers scrambling to reconfigure their tobacco production lines. Even before the technical standards were announced in April, engineers were drawing up solutions to accommodate every possible regulatory scenario. The track-and-trace requirements are challenging, especially for smaller manufacturers of noncigarette tobacco products, who tend to have fewer financial resources and less standardized product packs, which are harder to code with unique identifiers than cigarette packs.

    Thanks to its small footprint, the Djura can easily be fitted into existing production lines.

    Frontrunner

    One of the companies at the forefront of the effort has been Boikon of the Netherlands. The firm was founded in 1996 by brothers Jeroen and Erik Oosterhof, who started out by making technical drawings in the attic of their family home. One thing led to another, and the company quickly expanded into other activities. Today, the Boikon “family” includes 75 technicians and offers automated guided vehicles, robotics, machine vision and track-and-trace technology, among other high-end automation solutions. Its expertise extends to thermoplastic composite materials for the aviation business.

    In addition, Boikon boasts considerable experience with automation in the pharmaceutical industry, a sector that is even more heavily regulated than tobacco. The track-and-trace requirements that will soon be required in the EU for tobacco products have long been commonplace for medicines. Leveraging its knowledge gained in the pharmaceutical business, Boikon has developed what it believes to be a suitable solution for the tobacco sector—the Djura.

    The Djura laser prints unique identifier codes on tobacco products and instantly registers them in the appropriate databases at a speed of up to 160 packs per minute. According to Boikon, the system offers 99.98 percent efficiency and 100 percent reliability. Only two in 10,000 codes are applied incorrectly. Products with unreadable codes are rejected, and the codes can be reused immediately. This means that the manufacturer gets to use all of his prepaid codes—he will never “lose” one due to faulty printing.

    Careful consideration has been given to the positioning of the coding machine within the tobacco production line. Boikon’s engineers decided that the best place is at the end, after the last reject, so that the codes would be applied only to finished products at pack level. “This position, in combination with the Djura, leads to a closed system, which is not susceptible to fraud,” says Erik Oosterhof. Finished-product coding also makes the system ready for the digital tax stamp that regulators are contemplating.

    The Djura is an elegant solution because it does not require reconfiguration of the existing production line. A stand-alone unit, the machine can operate independently without having to communicate with upstream equipment. Its small footprint—less than 1 square meter—means it can easily be integrated into existing production lines. “We typically make room for the Djura by shortening an existing conveyor system,” says Oosterhof. The machine’s modular design also means it can be installed with minimal disruption to the production process. “We can get the machine up and running within one week,” says Oosterhof.

    Importantly, the Djura track-and-trace technology can handle all types of tobacco packages, including pouches, tins and stand-up bags. Pouches and stand-up bags present a challenge to coding machinery because of their non-uniform shapes; they never present themselves in quite the same way. The Djura simply measures their position and then adjusts the laser accordingly. If a pouch is tilted, the laser will tilt along the same angle, and the code is applied correctly. With the push of a button, the operator calls up the “recipe” for the product to be coded, and the machine automatically makes the required adjustments.

    Adding value, the Djura provides extra functionality, such as quality control and buffering capacity. “We can ensure the proper materials are on the production line, allowing the manufacturer to reject faulty product before it is bundled,” says Oosterhof. In case of a disruption in the production line, the Djura can buffer packages, minimizing stoppages and improving overall efficiency.

    Judging by Djura’s reception in the marketplace, Boikon is on the right track. Thirty machines are already operating at tobacco factories throughout the EU, and the company has orders for an additional 35.

    Oosterhof attributes the company’s success in part to its practice of doing everything in-house. Whereas other companies may outsource part of their projects to third parties, Boikon insists on developing its own technology. “The engineering, the controls, the after-sales—we do it all,” says Oosterhof. While outsourcing work may offer savings upfront, Boikon believes it can be costlier in the long run. “When we outsourced in the past, we frequently found ourselves re-engineering the technology, resulting in double work,” says Oosterhof.

    Operating in-house, he says, offers several advantages. For starters, it gives the customer a single point of contact. “When there are problems, you avoid finger-pointing between contractors,” he says. It also offers the company more flexibility in resolving technical issues. Because the mechanical and electrical engineers work together under one roof, they can determine the most appropriate department to fix problems. “By doing things in-house you also retain the required know-how,” says Oosterhof.

    This approach has clearly worked for Boikon. The payoff is reflected not only in the early success of its Djura track-and-trace technology but also in the company’s financial performance: Oosterhof expects Boikon’s turnover to double this year.

  • Mapping the future

    Mapping the future

    Can there be an ethical tobacco company—and what would it do?

    By Clive Bates

    Many years ago, I was scandalized when a prominent green campaigner joined a giant mining multinational to be its “sustainability champion.” How can a committed environmentalist work for a company that devastates the environment and destroys communities wherever it operates? “That’s the point,” he retorted bluntly. “You have to go to where the dirt is if you want to clean it up.” He was right, I was wrong, and I admire him to this day for making that move and for what he achieved in the role.

    The point was not that large-scale mining operations would magically no longer tread with a heavy environmental footprint. Rather, a forward-looking mining company should try to reduce its impact to the greatest extent and at the greatest rate possible, consistent with its business objectives. The businesses with the heaviest footprints offer the greatest scope to reduce their impact and therefore can do the most good when they change.

    So does this provide a useful pointer to what constitutes ethical behavior in companies that have high impacts? Should we judge the ethics of a company or an industry by the net harm its operations cause or by what it does to change to reduce harms over time? Can this logic be applied to the tobacco industry?

    The existence of a tobacco industry is a fact, a reality that is likely to persist for many years to come. Almost all governments allow a market in tobacco and therefore a tobacco industry to supply the market. To varying degrees, governments regulate it and tax it, and sometimes they own it. They show no sign of abolishing it. There will, therefore, be an industry operating in a legal market selling nicotine products for at least the medium term to the long term. But that does not mean that one to two decades from now the tobacco industry will look anything like it does today.

    Over the next two decades, I believe the industry will have to face up to and deal with the health burdens that are integral to its most successful products. But how to do this? Can we draw on advice for another industry facing an existential challenge that is fundamental to its leading products? We can turn for inspiration to a 2015 paper by energy expert Dieter Helm titled“What should oil companies do about climate change?” and draw out six strategies and how they might be applied to the tobacco industry.

    First: denial. Go into ostrich-like denial, argue against the science, and fund lobbyists and think tanks to create distraction. There is no need to dwell on this one for the tobacco industry because it has already been tried for several decades, and it does not work.

    Second: revolution. Oil companies should go “beyond petroleum,” pull out of the main fossil fuel businesses and become renewables companies. The equivalent for the tobacco industry is to pull out of manufacturing and selling cigarettes. That makes a good slogan, but it is not a viable strategy. This is because the company is owned by shareholders, and the management of the company has an obligation to protect their interests or expect to be fired. Shareholders will replace a management team that destroys their shareholding by eliminating the most profitable product line. Even if this were possible, the company would face a hostile takeover, or, alternatively, its facilities and intellectual property would have to be sold to someone else who would resurrect the business under new ownership, and nothing would be achieved. In fact, exiting the cigarette business is a common demand of health organizations. They have defined pulling out of cigarettes as the benchmark of industry credibility, even though it is impossible to achieve—or perhaps because it is impossible. Companies should even be wary of naming a date far in advance upon which they will pull out of cigarettes—they do not control the main consumer, policy and communication drivers that determine if and when this will become feasible.

    Third: Only stick to the law. This attempts an amoral passive approach. The state defines the limits of what can be done by companies, and the companies respect that and operate within these constraints. Obviously, all companies must obey the law, and tobacco companies need to comply with the letter and spirit of the law controlling tobacco and trade. In an office far from corporate headquarters, it can seem that, whatever headquarters says to the contrary, the real drivers are the quarterly numbers and the fact that there is tacit approval for any deniable conduct that makes the financials work. That cannot be acceptable. To address it means companies taking a globally concerted and proactive approach to corporate conduct—with no exceptions and with serious consequences for error. The problem with making this the only strategy is a that there are too many very poor ideas for regulating the tobacco and nicotine markets—some that will increase criminality, waste public money and cause more ill health—for companies to be passive policy-takers. In a situation where regulators are capable of outlawing safer products altogether (e.g., the European Union’s snus ban and Australian or World Health Organization (WHO)-inspired vapor product prohibitions) it is not safe to assume that governments, regulators and activists are rational actors in public health.

    Fourth: Drive technology transition. In the case of oil companies this means promoting a switch to a less harmful form of fossil fuel: a transition from coal to gas, which reduces carbon emissions by about half per unit of energy. In the case of tobacco this means running hard at a transition from combustible to noncombustible nicotine technologies (a reduction in harm that is dramatically greater than the switch from coal to natural gas) and building a business model that drives switching and cannibalization, not just a line extension. The aim is to change the market for consumer nicotine both as individual companies and collectively as an industry. But industry initiative can only take this so far: It needs a supportive policy framework.

    Fifth: Be the policy champion. In the case of oil companies this means, for example, pressing for a meaningful carbon price, which shifts the market toward low-carbon fuels and investment. For the tobacco companies it means a steep risk-related excise gradient and embracing the full spectrum of “risk-proportionate regulation.” That in turn means acknowledging and accepting a stringent regulatory environment for cigarettes. This would be done by structuring a “grand bargain”—a consensus that allows for tough measures on combustible products in return for a relatively liberal regime on the noncombustible, low-risk alternatives, with a view to migrating smokers from smoking to using vapor or smokeless products. One of the reasons to focus on policy is to address the competitive imperative that drives companies’ pursuit of market share. If tobacco advertising is permitted, companies will fight over market share by advertising, with the side effect of increasing the market. A ban on cigarette advertising takes that option off the table, but allowing the advertising of vapor products would allow competition between vapor products—and at the expense of the incumbent cigarette trade. Each of the main policy measures in the WHO’s Framework Convention on Tobacco Control armory could be assessed in this way.

    Sixth: Lead the innovation. This is about the future that companies are modeling when they spend on R&D, deploy staff, and invest in new plants and upgrades. For climate change, this means planning for greatly reduced carbon intensity and new technologies like electric vehicles, heat pumps and smart grids. For tobacco, it means seeing the world heading beyond combustion and moving into a consumer nicotine market based on the pleasure and functional rewards of nicotine use with far less damage to health, possible advantages to health (e.g., in relation to neurodegenerative diseases), and users willing and content to use it without the fear of death.

    More than 5 trillion cigarettes are smoked each year by more than 1 billion human beings. That is clearly “where the dirt is.” The opportunity to dramatically reduce the harmful footprint of the tobacco industry is without parallel in any other industry and could be among the greatest public health wins of all time.

    Can there be an ethical tobacco company? The competitive pressures to win market share in all segments, including cigarettes, make that a distant prospect. But there are, without doubt, ethical tobacco company behaviors. We should judge an incumbent tobacco company by its demonstrated commitment to change and by how aggressively it embraces the transition to noncombustible products. With millions of lives at stake, it would be unethical for governments, regulators or activists to try to obstruct it. This should be a project that unites public health professionals and the tobacco industry in a common aim, however uncomfortable that feels for veterans of the “tobacco wars.”

    “Mapping the Future” is the theme of this year’s Global Tobacco & Nicotine Forum, which will be held Sept. 11–14, 2018 in London.

  • Building bridges

    Building bridges


    The ECLT Foundation is helping Malawi keep children out of the tobacco fields.
    By Timothy S. Donahue
    It’s changing. A positive impact is being made. Projects are being completed, and complicated lives are getting a little less difficult in Malawi, where child labor in tobacco communities has been a long-standing problem. Thanks to the contributions of the Eliminating Child Labour in Tobacco-Growing Foundation ECLT, several bridges are being built across small streams that become raging rivers during the rainy season and prevent thousands of children from accessing schools and healthcare.
    It’s not just bridges; the ECLT has also completed a cooperative project to build three much-needed schoolhouses and living quarters for teachers in Mankhamba, a rural tobacco growing village in the Ntchisi district of Malawi. During Tobacco Reporter’s recent visit to the country, which is one of the poorest in the world, David Hammond, executive director for the ECLT, said that the projects fall in line with the organization’s new commitment to making the greatest local impact with its limited funding. Hammond, a non-practicing English barrister, former military seafarer and retired Royal Marines officer, took the lead at the ECLT in October 2017.
    “School teachers don’t have to walk up to 15 kilometers a day carrying books and supplies anymore. Teachers now have the ability to live in the village, and that really has a great positive effect. We have seen attendance increase in schools, and the district education office has allocated another teacher, so already things are moving just from that one small investment,” said Hammond. “Now people are getting more involved in their communities because we are showing them it is possible. It’s about the community having ownership. We can’t solve all the problems, so we must choose what we can do and make the greatest impact with what we have available.”
    The work in Mankhamba was made possible by a $15,000 investment from the ECLT, according to Innocent Mugwagwa, program manager for the organization. He said that when the foundation first arrived in the village, the school had 300 kids and only two classrooms. The headmaster’s office was also dilapidated. “Materials were getting destroyed, the teacher housing had no roofs, and the village was struggling to complete them. David [Hammond] introduced this concept of ‘see it, fix it’ so we fixed these school issues. If we see something that needs to be fixed, and even though it isn’t maybe in our budget, we put a lot of effort into finding the resources needed to fix the problem.”
    This “quick impact intervention” is part of the ECLT’s broader work in Malawi where the foundation has reached more than 190,000 children, farmers and their families since 2013. Through ECLT’s larger Clear II project, a water pump was also installed near both the school and the fields, providing safe water for students and farm workers, as well as helping with irrigation, according to Mugwagwa. In addition to improving sanitation at the school, having a well nearby allows girls to go to more classes because they do not have to spend time walking to fetch water. The parents have also started a school feeding program, which will attract students and retain them in school.
    One challenge for the ECLT is that it’s complicated to get things built in Malawi, according to Andrew Namakhoma, ECLT’s Malawi project coordinator. “This is especially true when building housing for people. You need to get the materials and do it in a way that benefits the local communities,” he said. “We don’t want to give the money to the people in a city hundreds of miles away to do the work; we want the money to become a part of the local economic community.”
    Throughout this project, ECLT has collaborated with numerous local partners, which is the key to ensure that communities are engaged and feel ownership of the projects, Namakhoma said, adding that community engagement is vital as “the sustainability of the projects is somehow guaranteed.”
    Mugwagwa explains that while the ECLT’s contribution was financial, the community provides the work and secures materials. It’s a joint effort. “Without the commitment of the local community and that important local knowledge, this would not be possible at all. We mobilize parents to form their own clubs and learn from each other and depend on each other. They pool their resources, and it’s really a benefit to the community,” said Mugwagwa. “One of the most exciting things is that the quality of education improves. It is one of the biggest problems when trying to address child labor. Kids go to school, but if they don’t learn, it doesn’t serve them well, so we are also implementing literacy programs where kids can get additional educational help outside of the school.”
    During Tobacco Reporter’s visit, the ECLT handed over completed bridges in the central Malawi villages of Mponela and Kasiya. An additional one in the northern Malawi village of Rumphi will be complete before the rainy season begins. Four bridges in total have been constructed in partnership with the Tobacco Association of Malawi (TAMA). They will make travel easier for more than 15,000 students, teachers and community members in these rural tobacco-growing areas.
    Each bridge was built by local workers using an average of $5,000 in funding from the ECLT, according to Mugwagwa, who added that great successes can be made by taking a lot of small steps. “We can’t tackle everything; we have to choose. Bridges are something that can be built and have a long-term impact,” he said. “We will continue to work in Malawi, and there is still so much more needed here. We have built a safehouse for abused women and children in Rumphi. We engage at the government level by informing policy and keeping the social dialogue going. There is so much we can do, but we need to focus on those things that make the greatest impact.” To further help improve the local community, the ECLT insisted that each village that received funding to build bridges train five locals to help with construction.
    Reality check
    The struggle is real. According to the International Labour Organization, more than 152 million children engage in child labor worldwide, with nearly 73 million doing hazardous work. Agriculture is easily the largest contributor to the issue, with over 71 percent (more than 108 million children) working in the sector, mostly as unpaid family laborers. Even with slight declines recently, sub-Saharan Africa remains the largest culprit.
    In Malawi, most of the child labor is family oriented. When children in farming communities cannot go to school, they are more likely to work in fields with their parents. It isn’t about pay. It is illegal for kids aged 5–12 to work. From ages 12–14, children can work but not doing dangerous jobs. Then, from ages 15–17, children can work hazardous jobs only as part of an apprenticeship or training.
    Founded in 2000, the ECLT provides collaborative answers for children and their families that impact the root causes of child labor. The organization is funded by grants from stakeholders in the tobacco supply chain, including growers, leaf suppliers and manufacturers. The ECLT is a member of the United Nations (U.N.) Global Compact and a holder of U.N. Economic and Social Council (ECOSOC) special consultative status.
    Hammond said that the ECLT is a team that is always learning from its experiences. According to him, it isn’t about placing blame or pointing fingers because something didn’t go exactly right. “The ‘test and adjust’ approach is learning and then improving the process the next time. It’s about always improving and making the impact matter,” he said. “Impact comes from different levels. Boots on the ground is one type of impact. Informing legislation and working with governments to fight the problem head on is another. We act as a catalyst. We act as a bridge to communities, between them and local government.”
    Looking back on the mission in Malawi, Hammond says seeing the projects on the ground has given him great faith in the ECLT system. “My biggest learning points have been that with more focused interventions, we are making a larger impact, and with a better understanding of how things are happening on the ground, we can speed up the process and cut through a lot of the red tape,” he said Hammond. “We can make sure we are meeting a community’s needs. In short, we need more eyes on the ground as we move forward. It doesn’t start and end in one community—we are here for the long haul.”
    In 2014, the ECLT adopted its Pledge of Commitment and Minimum Requirements on combatting child labor, which was signed by 13 companies. Hammond says that to make the pledge more effective, the organization needs to hold people accountable, otherwise it’s a pointless exercise. “[S]uccess starts with its integrity and longevity. The 650,000 families and children we have impacted can attest to this,” he says. “Our impact is at the front lines and ultimately is doing communities good. They take the lead on these projects. We are a trusted and objective supporting voice.”
    In the coming months, the ECLT will be starting projects in Guatemala and Indonesia and will continue on to wherever child labor is an issue. The organization needs more funding too, says Hammond. “We need to increase levels from the tobacco sector and look to diversify our funding streams. We can possibly look to being paid for consulting services to expand our offerings portfolio,” he says. “We are meant to be the leader in the fight against child labor globally. We can achieve this through showing that we really do make an impact and finish projects. We are not just an organization that has a lot of projects going on, but completing projects is very important. With a small amount of resources and a professional team, we can instigate and deliver real impact that has life-changing effects on the lives of the communities we are working in.”
    Alongside the pledge, Hammond says he can see a future where the ECLT may have satellite offices around the world—maybe they even become regional offices. “We will take all of the lessons learned, and our core values and plant those ideals in countries around the world. It’s about hiring the right people and magnifying our effect—a franchising of our social model. Our goals are to go in, leave our footprint and provide in-country community sustainability for the long term. We will deliver on our goals and promises. We will do it because we believe in what we do.”