Around 1.1 billion people aged 15 and over smoke, with 80% living in LMICs (low and middle income
countries). Tobacco growing and consumption have become concentrated in the developing world where
the health, economic, and environmental burden is heaviest and likely to increase. July 2019.
Brexit: How ‘no deal’ could change tobacco warnings
The government has announced that the current graphic warnings on cigarette packets will be replaced by Australian versions in the event that the UK leaves the EU with ‘no-deal’. The current set of images will potentially need to be replaced after Brexit because the copyright is owned by the European Commission.
According to the Department of Health and Social care: [In the event of a ‘no-deal’ Brexit] “manufacturers will need to ensure that tobacco products produced from exit day onwards feature new picture warnings, which have been secured by agreement with the Australian government. Tobacco products featuring pictures from the EU library, produced before exit day, may be sold for 12 months after exit day.”
Source: BBC, 9 October 2018
Daily Bulletin 2: Framework Convention Alliance at the WHO FCTC Meeting of the Parties
Today is Day 2 of the Meeting of the Parties (MOP) to the Illicit Trade Protocol (ITP). Today’s bulleting discusses the involvement of the tobacco industry in the illicit trade of tobacco and the challenge of implementing Article 12 of the FCTC in ‘Free Zones’.
The bulletin also includes a story on the success of the UK’s anti-smuggling strategy:
“The UK Government held its nerve and continued to increase taxes, while implementing a tough anti-smuggling strategy, which included strict supply chain controls and financial sanctions very much along the lines of the Protocol. Between 2000 and 2016, the last year for which there are figures, the size of the illicit market for cigarettes fell by nearly 60 per cent from 17 to 7 billion sticks, with revenue losses down from US$3.67 billion to US$2.36 billion (at current exchange rates). Illicit trade is a major and growing global problem but the lesson from the UK is clear. The Illicit Trade Protocol can help countries raise taxes, increase revenues and drive down smoking prevalence.”
Ireland: Tax rise on cigarettes in budget
The Irish government has published their Budget for 2019 which includes a €0.50 increase in the excise tax on cigarettes.
This follows a recent survey showing high levels of public support for higher taxes on cigarettes. Amarách Research surveyed over 1000 adults and found that 71% of people want the cost of cigarettes to be increased by €5 in the 2019 budget and the extra money to be ring-fenced for cancer treatment.
Source: Irish Times, 9 October 2018
New anti-smoking TV adverts hit the screens
Two ex-smokers are appealing to the public to quit, in a hard-hitting new campaign launched by tobacco control organisation Fresh. Maggie Bratton, from Newcastle, was diagnosed with smoking-related mouth cancer at just 45, which led to her undergoing a gruelling operation to remove her palate. The mother-of-two is now forced to wear a piece of plastic in the roof of her mouth every day just to be able to eat and speak. Father Tony Osborne, who was diagnosed with cancer of the voice box on his 52nd birthday, also features.
The campaign was put together by Fresh who are the regional tobacco control office in the North East. Fresh’s director, Ailsa Rutter OBE, said: “Tony and Maggie are two incredibly brave people who want their experiences of smoking to be heard. They don’t want other people to have to go through the pain and the life-limiting surgery they went through at a relatively young age. Tony and Maggie’s stories do not make comfortable viewing, but campaigns are one of the most powerful ways to encourage people to stop and young people not to start in the first place.”
Source: Daily Mail, 8 October 2018
BBC investigation: Children sold vaping products
BBC 5 Live followed investigations by Camden trading standards, to see if shops would sell nicotine products to a 16-year-old girl. The age of sale for vaping products is 18.
Hazel Cheeseman, Director of Policy at ASH, was interviewed as part of the station’s reflections on the investigation which found 1 in 3 shops sold to a 16 year old.
See also: 5 Live, Children Sold Vaping Products (Hazel can be heard from 18 minutes, 30 seconds in)
Source: BBC, 8 October 2018
Vapers to get the same insurance rates as non-smokers for the first time
Most insurance companies treat e-cigarette users the same as smokers. However, a new comparison targeted at e-cigarette users will give them the option to save almost half of what they currently pay for life and critical illness insurance.
David Mead, chief executive of Future Proof Insurance who have launched the comparison website, said: “We wanted to bring an easy to use price comparison site to help vapers save money. The biggest winners are people who have only been vaping and… not been using tobacco products for at least 12 months.”
Source: The Sun, 8 October 2018
WHO vows broader action against tobacco industry interference
The World Health Organization (WHO) unveiled a global strategy on Saturday to scale up the tobacco control agenda and to prevent further interference by tobacco industry in public health policies.
The strategy, titled the Medium-Term Strategic Framework (MTSF), aims to strengthen implementation of the WHO Framework Convention for Tobacco Control (FCTC), with a roadmap to guide the work of the convention parties, the secretariat and other stakeholders with regards to tobacco control from 2019 to 2025.
“The adoption of this strategy marks a key milestone in strengthening the FCTC,” said Vera Luiza da Costa e Silva, head of the WHO FCTC Secretariat. “This strategy provides a very clear path forward, with priorities and objectives to reinforce government policies and accelerate global action for more effective implementation of the tobacco control treaty.”
The strategy was concluded during the eighth session (COP8) of the FCTC, which brought together over 1,200 participants, including delegations from 148 parties to the global tobacco control treaty and representatives of UN agencies, other intergovernmental organisations and civil society.
Source: The Asian Independent, 7 October 2018
Daily Bulletin 1: Framework Convention Alliance at the WHO FCTC Meeting of the Parties
The first Meeting of the Parties (MOP) to the Illicit Trade Protocol (ITP) starts today, 8 October. There will be an FCA Bulletin released each day of the MOP. This bulletin focuses on the background to the ITP.
“The ITP aims to eliminate all forms of illicit tobacco but has a particular focus on securing the supply chain of legally manufactured tobacco products. Latest estimates suggest that approximately 60–70% of the illicit market is tobacco industry product, indicating that, at the very least, tobacco companies are failing to control their supply chain in the knowledge that their products will end up on the illicit market.
The ITP requires a global track and trace system to reduce tobacco smuggling which will be achieved by each party requiring that every pack manufactured in or imported to their territory has a unique, secure marking providing information on manufacture, shipping and distribution.”
Daily Bulletin 6: Framework Convention Alliance at the WHO FCTC Conference of the Parties (Saturday 6 October)
Saturday was the final day for the WHO FCTC Conference of the Parties. The final bulletin highlights the new Global Strategy and funding issues.
“There have been significant achievements at COP8, most notably the new Global Strategy to Accelerate Tobacco Control, which should guide our collective efforts through to 2025. And yes, that will include an implementation Review Mechanism (IRM), albeit only as a pilot project. We hope we will learn from that pilot and be in a position to endorse the IRM at COP9.
In Committee B, there were also successes. Parties agreed to shift core funding so that some of the work outlined in the Global Strategy can begin in 2020. They also mandated the Convention Secretariat to explore new mechanisms for fundraising for the Secretariat’s workplan and budget.
There were disappointments too, such as the COP’s decision to keep the budget frozen for another biennium. We can only hope that future budgets, closely tied to the Global Strategy, will convince governments to loosen the purse strings.
And then there was the atmosphere of COP8. The frustration of enduring industry proxies’ efforts to delay, distract, and obstruct – in this respect, a sad repeat of COP7. And too much time – even amongst the good-faith delegates – spent haggling over words, rather than discussing our shared objective of reducing tobacco-caused deaths as quickly as possible.”
Link of the week
Norfolk: Shop owner admits selling counterfeit cigarettes from Great Yarmouth shop
A shop owner has admitted selling fake cigarettes after raids at his Great Yarmouth store uncovered hundreds of illegal products.
The defendant appeared at Norwich Crown Court nearly 5 years after searches of the shop found 110 pouches of tobacco and 205 packets of cigarettes on March 1, 2013. The owner was cautioned but, after a second search uncovered 158 packets of cigarettes and 53 pouches of tobacco on April 10 2013, he was charged with unauthorised use of a trademark. The defendant was arrested after returning from Iraq in January 2018.
Source: Eastern Daily Press, 4 October 2018
Daily Bulletin 5: Framework Convention Alliance at the WHO FCTC conference of the parties
Today is the last full day of the COP8 negotiations in Geneva and the bulletin highlights the final flurry of work needed to conclude this year’s conference.
Deborah Arnott, ASH, and Laura Hucks, Cancer Research UK, have written an article for the final bulletin. They highlight the leadership that Australia and the UK have contributed to the FCTC and the funding that both countries have pledged to provide.
“At COP7 the UK launched its FCTC 2030 project, providing 5 years funding from its aid budget to the Convention Secretariat, specifically to support low and middle-income Parties to achieve Sustainable Development Goal target 3.a. This is the target that calls for a strengthening of implementation of the FCTC.
Two years on, Australia has joined the UK in funding the project, providing a great example for other Parties to follow. This financial support is focused on the achievement of the general obligations and the time bound measures of the Convention, strengthening tobacco taxation, implementing other articles of the WHO FCTC according to national priorities, and building strong links to the 2030 Agenda for Sustainable Development.”
Australia: senior advisor to former prime minister lobbying for PMI, but role ‘invisible’ under lobbying regime
A former senior adviser to ex-PM Tony Abbott is working as an in-house lobbyist for the tobacco giant Philip Morris, but flaws with the lobbying rules mean he is invisible to the oversight regime covering federal parliament.
Murray Cranston was a long-time adviser to Abbott, including during the Liberal MP’s time as health minister and opposition leader, and in the lead-up to his successful 2013 election campaign. Cranston is not listed on the federal register of lobbyists, the public’s only window into the world of lobbying.
This is because Australia’s lobbying rules do not cover individuals who work directly for a company like Philip Morris as in-house lobbyists. They only cover third-party or consultant lobbyists, who work for a professional lobbying firm and are engaged by another company to act on its behalf.
The failure of the federal system to cover in-house lobbyists has been widely criticised. Even the body representing lobbyists, the Australian Professional Government Relations Association, wants change.
Source: The Guardian, 4 October 2018
USA: Juul files lawsuit against ‘Copy-Cat Products’ marketing to underage users
E-cigarette company Juul Labs filed a complaint on Wednesday with the U.S. International Trade Commission alleging that 18 companies have infringed on the company’s patents. The lawsuit claims that the listed companies “blatantly emulated the distinctive design” and urges the ITC to stop these products from being imported and sold on the US market.
Most of the companies listed in the lawsuit are located in the U.S. and China with one other based in France. Juul filed a similar lawsuit earlier this year against 30 companies in China for allegedly selling counterfeit Juul products on eBay. According to the lawsuit, the companies were using the Juul design or name brand to sell the products.
The latest lawsuit comes days after the FDA conducted a surprise inspection on the Juul headquarters in San Francisco, where it seized “thousands of pages of documents” related to how the company markets its products. The FDA earlier this month described Juul’s popularity among teens as an “epidemic.”
Source: Fortune, 4 October 2018
Link of the week
Public Health England Commissioning Support Pack: Alcohol, drugs and tobacco
This commissioning support guidance will help commissioners and local authorities develop strategies to reduce the harm caused by smoking, drinking, substance misuse in both adults and children.
For each of these topics, there are a set of good practice principles and indicators or questions to help local areas assess need and plan and commission effective services and interventions.
North West: School gates ban for smokers
Tameside Council is calling on the borough’s schools to sign up to a Smokefree Gates policy. Council Leader Brenda Warrington said: “Everyone must be aware of the dangers of tobacco. It’s the biggest cause of preventable death and linked to many diseases including cancer. Children exposed to smoking are significantly more likely to take up the habit themselves.
That’s why we want Tameside’s schools to sign up to a Smokefree Gates policy in addition to any other no-smoking or Smokefree measures they already have in place.
Teachers and pupils regularly say that they want to do their learning in green and healthy places. It’s a belief encapsulated in the term ‘little lungs matter’.”
Source: Tameside Metropolitan Borough, 03 October 2018
North West: Morecambe vape shop’s cessation scheme gains NHS support
A new scheme is aiming to help people stop smoking with the use of e-cigarettes. Up In Smoke, a vape shop in Morecambe, offers a free “pen type e-cigarette” to anyone wishing to try it and has launched a ‘Smokebusters’ scheme support service, which encourages people to visit the premises every week and blow into a Carbon Monoxide (CO) and lung age monitor.
Mike Zorab, general manager at Up In Smoke, explains: “We’ve been backed by Lancashire Quit Squad, which is jointly run by the NHS and Lancashire County Council… Lancaster Quit Squad organised for 20 of their staff to come in for a training session to learn more about e-cigarettes.”
The shop is also working with local NHS organisations to provide e-cigarettes to smokers. Mark Zorab explains that local NHS services are “now referring straight to us as a last resort if patches and gum don’t work. People can come in, fill in a form, there’s a series of questions, and a set of rewards. People have to return every seven days, and if their CO reading has decreased, they get a stamp which can be exchanged for free liquid or vouchers.”
Source: Lancaster Guardian, 04 October 2018
Daily Bulletin 4: Framework Convention Alliance at the WHO FCTC conference of the parties
According to today’s bulletin, yesterday “the Committee took a gigantic step forward for FCTC implementation by endorsing the first ever Global Strategy for Tobacco Control. That’s a big deal: identifying priorities from now until 2025, with a clear and ambitious objective of reducing prevalence sharply, will help the COP, the Secretariat and individual Parties organise their work and raise funds.”
The bulletin goes on to add: “As we head into budget and workplan discussions, it’s critical to prioritise activities and funding to reflect our newly agreed Global Strategy – activities that will actually help to close the gap between where we currently stand and the desired future – a world free from tobacco-caused death and disease.”
Other highlights from today’s bulletin include ‘Unlocking the power of tobacco taxes’, ‘In pursuit of viable alternative livlihoods for tobacco farmers and farm workers’ and ‘Escalating the tobacco-free finance conversation’.
Cost of cigarettes must rise to reflect environmental damage from tobacco industry, WHO says
A new report published by the WHO has recommended that the cost of cigarettes should rise to reflect the wide-ranging environmental damage caused by the tobacco industry, and compares the industry’s carbon footprint to that of an entire country. In the UK, which has very little domestic tobacco production, smoking cigarettes “is done entirely at the expense of other nations’ resources and environmental health”, the report said.
Cigarette production and consumption has risen in recent decades with around 6 trillion cigarettes manufactured annually for an estimated 1 billion smokers. Tobacco farms take up more than 20,000 square miles of land globally and use over 22 billion tonnes of water. This is in addition to a range of environmental and social costs including high levels of pesticide use, soil depletion and child labour.
Professor Nick Voulvoulis, co-author of the report, said: “The environmental impacts of cigarette smoking, from cradle to grave, add significant pressures to the planet’s increasingly scarce resources and fragile ecosystems.” Dr Nicholas Hopkinson, co-author of the report, added: “Tobacco transnationals based in high income countries are literally and metaphorically burning the resources and the future of the most vulnerable people on our planet.”
Source: Independent, 2 October 2018
Daily Bulletin 3: Framework Convention Alliance at the WHO FCTC conference of the parties
Highlights from today’s agenda include implementing the ban on Tobacco Advertising, Promotion and Sponsorship – in the digital age; Switzerland’s relationship with the tobacco industry; PMI’s Foundation for a Smoke-Free World; the financial case for investment in tobacco control; the WHO’s new report on the environmental impact of the tobacco industry (see above); and tobacco price fixing in Sri Lanka.
Article 13 – A comprehensive ban on Tobacco Advertising, Promotion and Sponsorship (TAPS) – is key to reducing the uptake of tobacco and reducing tobacco-related harm. Changing patterns of media consumption present challenges to effectively banning TAPS, particularly cross-border TAPS.
US: FDA seizes documents from Juul in latest e-cigarette crackdown
On Tuesday the US Food and Drug Administration (FDA) seized over 1,000 pages of documents from e-cigarette manufacturer Juul Labs, as part of its ongoing investigation into the company’s sales and marketing practices.
Last month the regulator announced that it was considering a ban on flavoured e-cigarettes due to concerns around youth uptake.
Juul makes up around 72% of the US e-cigarette market and has come under increasing scrutiny for its marketing practices, having released over 50,000 pages of documents to the FDA since April.
Source: Reuters, 2 October 2018
Philip Morris lobbying on e-cigarettes hidden from Australian public
Philip Morris International (PMI) has been lobbying Australian MPs to overturn the ban on vaping. This has been effectively hidden from the public due to a loophole in the Australian lobbying oversight system which allows companies to avoid signing up to the country’s lobbying register if they use lobbyists from within their own company rather than hiring a third party lobbyist.
PMI has been seeking meetings with MPs to discuss the vaping ban and engages a number of former government officials, including one registered lobbyist. The company argues that these merely provide advice and do not lobby on PMI’s behalf.
PMI has also taken advantage of an exemption in Australia’s tobacco advertising ban by placing prominent job ads in two major newspapers calling for staff to help it achieve a “future without cigarettes” and a “smoke-free Australia”.
Source: The Guardian, 2 October 2018
Study: US teenagers’ use of e-cigarettes and tobacco linked
A new study by the Rand Corporation has suggested that use of e-cigarettes among teenagers is linked with increased regular cigarette use, and vice versa. Youths who reported vaping at 17 years of age (8%) had a cigarette smoking rate of 6%. By the time they reached 19 years of age the proportion of young people who vaped increased to 9%, whereas the proportion who smoked cigarettes increased to 12%.
The study surveyed over 2,000 youths in California from when they were teenagers continuing until they were young adults.
Study author, Michael Dunbar said: “This highlights the importance of taking steps to prevent youth from vaping in the first place.”
The UK currently bans all forms of tobacco advertising and restricts advertising for e-cigarettes. Age of sale of both tobacco and e-cigarettes is 18.
Source: The Guardian, 2 October 2018
Editorial note: The researchers found that use of e-cigarettes increases the likelihood of youth smoking and vice versa and that there are common risk factors for both.
A recent survey conducted by ASH found that 0.3% of 11-18 year olds who had never smoked were currently using e-cigarettes.
Smoking rates among young people in the UK continue to fall.
See also: ASH survey on youth e-cigarette use
Stoptober 2018: Public Health England Campaign to quit smoking revealed
PHE’s Stoptober campaign, aimed at helping people to quit smoking, has launched this week.
Launched in 2012, the campaign offers free support and resources for those looking to stop smoking, including through medications, apps, social media groups and personal support from local health services. Today, the campaign is the largest and most popular event in the UK aimed at getting masses of people to give up smoking.
Since launching in 2012, Stoptober has led to more than 1.5 million quit attempts in the UK. In addition, a 2017 report by the University College of London has showed that quitting success rates in the UK are the highest they’ve been in at least a decade, up to 19.8% for the first six months of 2017 and considerably higher than the ten-year average of 15.7%.
See also: Birmingham Mail, Stoptober is here – here’s what happens to your body when you quit smoking
Source: MSN News, 01 October 2018
London: Southwark Council issues shisha warning this Stoptober
There are many misconceptions that surround shisha and this Stoptober Southwark Council is highlighting how smoking shisha tobacco can affect your health.
Research data suggests that the vast majority of people do not realise the dangers of smoking shisha, often seeing it as a safer alternative to regular cigarettes. A 2014 survey of 1,200 people in south east London found that 64% of people did not know that shisha usually contains tobacco. A further 53% of people did not think that shisha represented any danger to their health.
In partnership with ‘It’s Still Tobacco’, a community and advocacy group, Southwark Council will be raising awareness of the health impacts of smoking shisha tobacco on social media and via posters around the borough.
Source: Southwark Council, 01 October 2018
North West: First hospital to offer addiction therapy to all smoking patients
Wythenshawe Hospital in Greater Manchester has become the first in the UK to offer addiction treatment to all of its patients that smoke. Patients admitted to the hospital, which is part of Manchester University NHS Foundation Trust, will be prescribed medication and offered intensive support to stay smokefree. This is part of the CURE programme being launched at the hospital to coincide with the first day of Stoptober.
The CURE is modelled on the Ottawa Model for Smoking Cessation which has helped 35% of smoking patients to quit and led to marked falls in re-admissions and mortality rates in Canada.
CURE forms part of Greater Manchester Health and Social Care Partnership’s Making Smoking History programme. Following an initial six-month phase at Wythenshawe, the programme is due to be rolled out in hospitals across Greater Manchester by 2020. As well as transforming lives, the trust noted that the initiative would free up thousands of hospital beds each year and save the NHS in Greater Manchester an estimated £10m a year.
Source: Nursing Times, 01 October 2018
Daily Bulletin 2: Framework Convention Alliance at the WHO FCTC conference of the parties
The eighth session of the Conference of the Parties (COP8) to the World Health Organisation (WHO) Framework Convention on Tobacco Control (FCTC) is now onto its second day.
Today’s bulletin is titled ‘Global Strategy and IRM – Let’s Shift Gears’. It refers to the proposed ‘Global Strategy to Accelerate Tobacco Control’ which calls for coordinated action on a small number of high-impact interventions in order to reduce tobacco use between now and 2025. According to the bulletin, if endorsed the strategy will be an important tool for raising the visibility of the treaty and for helping to fund tobacco control at the global and national level.
The bulletin goes on to add that the kind of problem-solving and knowledge exchange such a strategy would make possible “is truly valuable and will support implementation of the FCTC.”
Philip Morris sues South Korea over heat-not-burn info disclosure
Philip Morris Korea has filed a lawsuit against the South Korean government, demanding the disclosure of information from recent tests that concluded heat-not-burn products contain harmful substances.
Seoul’s Ministry of Food and Drug Safety said in June after a study that up to five cancer-causing substances were found in the heated smoking devices, and the level of tar discovered in two products, including Philip Morris’ iQOS, exceeded that of regular cigarettes. The ministry’s announcement ran counter to the U.S.-headquartered company’s claim that its heated tobacco product is less likely to cause disease than traditional cigarettes, citing studies conducted in Germany, Japan and China.
Philip Morris said the government study wrongly centered on tar, which is only applicable to smoke created by regular cigarettes, while the electronic devices do not generate smoke.
See also: Financial Times, Philip Morris sues Seoul over e-cigarette information disclosure
Source: Reuters, 01 October 2018
Campaigners urge WHO to give vaping a chance
Seventy public health experts and tobacco control campaigners have urged the World Health Organization (WHO) to adopt a more sympathetic attitude to e-cigarettes and other alternatives to smoking in a letter to the WHO Director General, stating that the devices “have the potential to bring the epidemic of smoking-caused disease to a more rapid conclusion”.
Their joint letter to Tedros Adhanom Ghebreyesus, WHO director-general, is intended to influence this week’s conference of the Parties to the Framework Convention on Tobacco Control.
In their letter, the advocates of harm reduction, most of whom are university or medical school professors, urged the WHO not to let uncertainty about long-term effects of e-cigarettes block their introduction: “It is true we will not have complete information about the impacts of new products until they have been used exclusively for several decades — and given the complex patterns of use, we may never,” they wrote. “But we already have sufficient knowledge based on the physical and chemical processes involved, the toxicology of emissions and exposure markers, to be confident these non-combustion products will be much less harmful than smoking.”
Source: Financial Times, 01 October 2018
Tobacco control measures are working, but too slowly in less-developed countries
“Great progress” has been made in tackling tobacco consumption and saving lives but more needs to be done to challenge the industry’s attempts to “bypass” international regulations, the World Health Organization (WHO) said on Monday.
The 181 Parties to the WHO Framework Convention for Tobacco Control (WHO FCTC) have developed strategies “to prevent tobacco industry interference with tobacco control policies”. As a result of the treaty, countries have increased taxes on tobacco, established smokefree spaces and made it obligatory for manufacturers to show graphic health warnings on their products, as well as using plain packaging.
Despite these advances, “this is not a time to be complacent,” said Dr Vera Luiza da Costa e Silva, head of the WHO FCTC Secretariat. “With astronomical budgets, the tobacco industry continues its furious efforts to undermine the implementation of our treaty.”
See also: Mail on Sunday, Battle for lungs and minds as tobacco control treaty meeting opens
Source: UN News, 01 October 2018
This fact sheet summarises tobacco control policy formulated by the European Union. Aug. 2016.20. Tobacco Policy and the European Union
A briefing for Local Authorities to help them meet their obligations as parties to the World Health Organization treaty on tobacco, the Framework Convention on Tobacco Control (FCTC – article 5.3) and to the Local Government Declaration on Tobacco Control.ASH Briefing: Developing a policy on contact with the tobacco industry
While most forms of tobacco advertising and promotion in the UK are banned, the tobacco industry has continued to promote its products through packaging and “below the line” marketing.
ASH submission to the Department of Communities and Local Government on tobacco litter.ASH-submission-to-inquiry-on-litter.pdf
At its third session in November 2008, the Conference of the Parties (COP) adopted guidelines for implementation of Article 11 of the WHO FCTC on “Packaging and labelling of Tobacco Products” (decision FCTC/COP3(10)).
This briefing summarises the requirements of Parties under Article 11 of the FCTC to adopt health warnings and to ensure that packaging does not promote tobacco products by false, misleading or deceptive means.