Flavors (Including

Issue
Brief

Menthol) in
Global

Tobacco Products

May 2022

Adding flavors to tobacco Introduction

products makes them more Flavors added to tobacco products include fruit, spice,
appealing to young people herbal and floral, but by far the most popular is menthol.
and harder to quit. The Menthol-flavored cigarettes account for around 10%1 of
the global cigarette market. Thus menthol cigarettes are
tobacco industry develops
an important flavored product for the tobacco industry.
enticing flavored products, Jurisdictions such as Canada, the EU and the U.K. have
markets them to targeted specifically included menthol in flavor bans given the
extent of the evidence that menthol, as well as other
groups and prevents and
flavors, is harmful.2
weakens flavor bans. Despite
objections from the tobacco These flavors make tobacco products more dangerous
industry, countries have because they make smoking more palatable, less harsh-
feeling, and more appealing to young people, increasing
begun to implement flavor
smoking uptake and reducing quitting.3
bans. Strong policies can
maximize the effectiveness In this brief, we describe tobacco industry development of
flavored products, who the tobacco industry targets with
of tobacco flavor bans.
marketing and how the industry fights to keep flavors on
the market.

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The Dangers of Flavors

• Flavored cigarettes and their marketing, • Research suggests that young people who
including gimmicks such as capsules and use menthol-flavored cigarettes smoke more
colorful packaging that emphasizes choice cigarettes and have a higher intention to
and technology, appeal to young people.4 keep smoking than those using non-menthol-
flavored products.8 Young people who smoke
• Many tobacco product users, especially
menthol-flavored cigarettes are 80% more
young people, reported experimenting,
likely to become lifelong smokers than those
initiating and continuing to use flavored
who smoke unflavored cigarettes.9
products because of the taste and variety
of the flavors. Users of flavored tobacco • The addition of fruit and herbal flavors,
products also showed decreased likelihood including menthol, may lead to the mistaken
of intentions to quit compared with non- conclusion that such products are healthier
flavored tobacco product users.5 than standard tobacco products.10
• Menthol flavor has a desensitizing effect,6
reducing irritation in the lungs and airways,
and may also encourage deeper and longer
inhalation.7 Its cooling and soothing effects
mean smokers of menthol are less aware of
the harmful effects of tobacco, and therefore
less likely to quit.

As well as menthol and the more traditional flavors

like fruit and spices, capsules now offer “concept”
flavors like “arctic air” and “tropical breeze.”

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FCTC Guidelines for Flavored Designing dangerous flavored

Tobacco Products products
The World Health Organization Framework Traditionally, flavors were added to tobacco leaves
Convention on Tobacco Control (WHO FCTC) during processing. But as far back as the 1960s,
includes guidance on regulating the contents of cigarette companies were experimenting with
tobacco products including ingredients which different ways to add flavors to their products.13
give flavors. Articles 9 and 1011 require the 182 In 2007, a new product was introduced in Japan:
Parties to the treaty to: a cigarette with a flavor capsule embedded in the
filter that users could crush to release the flavor
• Regulate the contents of tobacco products. at the time of their choice. As well as menthol
and the more traditional flavors like fruit and
• Require manufacturers and importers to
spices, capsules now offer “concept” flavors like
disclose the contents of tobacco products.
“arctic air” and “tropical breeze.”14 These new
• Independently test and measure the contents capsule products have become very popular: In
of tobacco products. some countries, current or ever use of capsule
cigarettes among young smokers exceeds 50%.15
The Partial Guidelines for Implementation of Tobacco companies have also introduced flavors
Articles 9 and 10 recommend regulation to via infusing flavors into the packaging or through
prohibit or restrict ingredients that may be used flavored accessories which allows them to work
to increase palatability in tobacco products. around bans.
The Guidelines state: “From the perspective
of public health, there is no justification for Marketing flavor to targeted
permitting the use of ingredients, such as
demographics
flavoring agents, which help make tobacco
products attractive.”12 Research shows that flavors have been marketed
specifically to targeted populations, including Black
Laboratories for industry disclosure of Americans and young people.
tobacco product ingredients and government
compliance testing should meet international From the 1950s onwards, cigarette companies
standards and compliance testing laboratories in the U.S. have deliberately and consistently
should be independent of the tobacco industry. marketed menthol cigarettes to Black consumers
in Black media and neighborhoods.16 As a result,
The Guidelines further recommend reducing the menthol smoking prevalence rose among Black
tobacco companies’ ability to market flavors by smokers from under 10% in the 1950s to 85%
implementing restrictions on packaging design, in 2021.17 Tobacco use is a major contributor to
including flavor descriptors and advertising three of the leading causes of death among Black
(Articles 11 and 13). Americans: heart disease, cancer and stroke. Black
Americans die from these conditions at higher
rates than other Americans.18

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The Black community has fought back against may explain the high prevalence of use among
the tobacco industry. In June 2020, the African adolescents and young adults noted in the first
American Tobacco Control Leadership systematic review.
Council and Action on Smoking and Health
filed a lawsuit against the U.S. Food & Drug Starting smoking at a young age has serious long-
Administration (FDA) to compel regulatory action term consequences. Evidence shows that the
against menthol-flavored cigarettes.19 The National younger someone is when they start smoking, the
Medical Association and American Medical greater the harm is likely to be,25 as early uptake
Association later joined the lawsuit.20 In April 2021, is associated with subsequent heavier smoking,
reportedly prompted by the lawsuit, the FDA higher levels of dependency, a lower chance of
announced it would promulgate a rule banning quitting and a higher risk of premature death.
menthol cigarettes.21 In April 2022, the FDA
announced proposed rules to prohibit menthol as a Finding new markets in low- and
characterizing flavor in cigarettes.22
middle-income countries
Recent research on the use of capsule cigarettes In response to these concerns, and in line with
suggests that these also have a target market: WHO recommendations, many countries and
young people. A first-of-its-kind systematic jurisdictions regulate flavored products with full or
review on use and perception of flavor capsule partial bans. While both low- and middle-income
cigarettes23 found clear evidence that capsule countries (LMICs) and high-income countries
cigarettes are mostly used by young people. The (HICs) have implemented full or partial bans, such
research shows that these products function as legislation is more common in HICs, where tobacco
“starter cigarettes.” Reasons for use and appeal use is generally falling.26 In LMICs, tobacco use
have to do with positive perceptions about the remains persistently high. Nearly 80% of all
product, such as better taste, smoothness on the smokers live in LMICs27 and most deaths from
airways, the choice of flavors, if/when to crush the tobacco use occur in those countries.28
capsule and the enjoyment of clicking the capsule.
To date, there has been little research on flavored
A follow-up systematic review by the same authors tobacco products in LMICs, but recent research
examined the marketing tactics behind capsule by the University of Bath analyzed market data
cigarettes24 and found tobacco companies were to understand flavored products’ market share
taking a comprehensive marketing approach. in LMICs.29 There appeared to be a marked
Once again, the evidence showed that these increase in market share in LMICs in the run up to
products were deliberately targeted at the youth the 2016 EU menthol ban.
market, with sweet and fruity flavor options and
a focus on the novelty of the products. These The University of Bath researchers concluded that,
were reinforced by visual marketing: colorful “Young people in many LMICs have menthol/flavored
packaging and product names, packaging and tobacco products available to them with fewer of
advertising that emphasized the user’s choice to the tobacco control policies in place which would
change the flavor. Furthermore, some countries limit their attractiveness and misrepresentation of
had cheap options, which suit the lower budgets harmfulness.” Given that it is mostly HICs that have
of many young people. These choices in product implemented bans on such products, it’s possible
variations, packaging, price and advertising factors that, faced with restrictions in these countries,

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tobacco companies have turned their attention to Ways in which the tobacco industry has responded
markets with more relaxed policy regimes. include:

The research highlights the easy availability of 1. Pushing back on bans in the Americas
flavored cigarettes, including menthol, in LMICs, Jurisdictions that have not yet managed to
and suggests that the growth in market share was implement legislation include Brazil, Chile and
due to tobacco industry activities. These activities the United States.
include marketing, particularly in stores and on
packaging, and interference in policymaking. Brazil was the first country in the world to
Guatemala, Nigeria, Peru and Russia were pass a law banning flavored tobacco products
identified as countries with both “high market including menthol in 2012, but was unable to
share” and “high market share growth,” indicating enact it due to industry interference and a
that these countries are likely to be key target lengthy court battle instigated by Philip Morris
markets for transnational tobacco companies. Brasil.33 The Brazilian government finally won
However, companies reveal very little publicly the court case in February 2018, although to
about their strategies for these products. date the ban has not been implemented.34

The availability of flavored products presents The Ministry of Health in Chile, a country with
a risk, particularly to young people, and an high use of menthol cigarettes, tried to introduce
opportunity for the tobacco industry to attract a menthol ban under an existing law in 2013. The
more consumers, notably in LMICs where health ban was rejected after lobbying from the tobacco
inequalities are already significant. industry.35 A new bill was introduced in 2015,
supported by data showing very high use of
Flavor bans and the tobacco menthol cigarettes by young people. In response,
British American Tobacco (BAT) threatened
industry’s attempts to undermine
to withdraw its operations from Chile. Despite
them passing the law in the Senate, as of April 2022 it
As of 2021, around 40 countries had active or has yet to be implemented.36
pending policies on flavor.30 Some countries such
as Canada have completely banned all flavored In the U.S., a federal ban on menthol cigarettes
additives. Other bans only prohibit “characterizing is moving closer to approval with proposed
flavor,” whereby ingredients can be added as long standards announced in April 2022.37 The FDA
as the smoker cannot sense that they are there. has proposed extending the 2009 flavored
There is evidence that such ingredients make cigarette ban to menthol cigarettes and widen
smoking more palatable even if the smoker cannot the flavor ban to include cigars and cigarette
sense them.31 Not surprisingly, the industry lobbies components such as filters and papers. The
for these weaker bans and supports the more proposal includes banning characterizing
ambiguous term “characterizing flavor.”32 flavors rather than ingredients.

The influence of the tobacco industry has brought While the federal ban is yet to be approved,
significant challenges to the implementation of bans have already been enacted by
these new policies. various states and cities. These have faced
interference, not least in San Francisco,

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In the EU/U.K. where there where the first comprehensive prohibition

on the sale of flavored tobacco products,
is a characterizing flavor including menthol, was passed.38 RJ Reynolds
(part of Reynolds American, owned by BAT)
ban, tobacco companies funded most of a US $12 million campaign
have introduced new which collected enough signatures to force
a referendum on the issue.39 The electorate
cigarette variants which supported the ban but the referendum delayed
government bodies and implementation from April 2018 to July 2018,
with enforcement not starting until April 2019.40
even other tobacco The ban led to a 96% reduction41 in sales of
companies have argued do flavored products and total tobacco sales
declined further than in neighboring cities
have a characterizing flavor. without bans.

Such products still remain More recently, the Bureau of Investigative

on the market due to a Journalism and the Los Angeles Times revealed
a comprehensive lobbying strategy underway
complex regulatory process by Reynolds American to deter lawmakers and
being developed and the voters from supporting proposed bans.42

products undergoing the By October 2017 Canada had banned flavor,

new process. The industry including menthol, in cigarettes, most cigars
and wraps for roll-your-own tobacco.43
has taken advantage This ban applies to the entire country and
bans flavor as an ingredient rather than a
of the difficulties of characterizing flavor.44 However, the tobacco
determining and regulating industry was able to “transition” menthol
cigarettes to non-menthol brands by changing
“characterizing flavors.” pack colors from menthol-related green to
blue, white and silver, cellophane wrappers
advertising “smooth” alternatives and non-
menthol cigarettes with capsules to expose
menthol smokers to the taste of standard
tobacco cigarettes with no flavor (before they
clicked the capsule).45 Had Canada adopted
standardized packaging (including banning
capsules) at the time of the ban, rather than in
2020, much of this “transitioning” would have
been unavailable. Nevertheless, the ban did
increase quit success and prevented relapse
among former menthol smokers.46, 47

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2. Pushing back on EU legislation Where bans only include cigarettes, other

Interventions by the tobacco industry delayed tobacco products have been marketed with
the European Union’s Tobacco Products Directive flavor. These include flavored little cigars52
(TPD) flavor/menthol ban (which the U.K. in the U.S. after the flavor ban in 2009 and
implemented before leaving the EU). An initial cigarette-like cigarillos with capsules53 that
May 2016 deadline for countries to enact the appeared in the EU and U.K. around 2020.
flavor ban in national law was extended for all EU
countries. Retailers were allowed a year to sell Bans have currently only applied to tobacco
existing stocks of other flavors but the phase- products and not accessories. These can
out period for menthol-flavored products was be placed in or near the tobacco to create
extended for a further three years.48 a flavored smoking experience. Flavored
cigarette accessories include cards that can
Instead of using the time to reduce stock in be inserted into cigarette packs, capsules
time for the ban, research from the University sold separately for the smoker to insert
of Bath shows that the delay was used by themselves54 and filter tips for inserting in
tobacco companies to continue promoting specially designed filters55 on boxed cigarettes.
menthol cigarettes.49 During the phase-out In addition, there are flavored filters and papers
period, the market share of flavored capsules, for roll-your-own cigarettes.56
including menthol, in the U.K. grew.50 The delay
undermined a public health policy aimed at
saving lives.

3. Circumnavigating bans with new products

Tobacco companies have responded to flavor
bans by developing a range of new products
that circumvent weak points in existing bans.

In the EU/U.K. where there is a characterizing

flavor ban, tobacco companies have introduced
new cigarette variants which government
bodies and even other tobacco companies
have argued do have a characterizing flavor.
Such products still remain on the market due to
a complex regulatory process being developed
and the products undergoing the new process.
The industry has taken advantage of the
difficulties of determining and regulating
“characterizing flavors.”51

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Weak ban Tobacco industry Interim response Optimum response

work-around

Bans flavored Introduces other Standardized Ban all flavored

cigarettes flavored tobacco packaging: includes tobacco products
products no flavor capsules

Bans flavored Introduces Point of sale display Ban all flavored

tobacco flavored ban for tobacco tobacco
products accessories accessories accessories

Bans Introduces Standardized Ban flavor

characterizing tobacco products packaging: includes ingredients
flavor with low flavor ban of brand names
levels referencing flavors

Bans flavor Introduces new Marketing ban Ban all flavors

except menthol menthol products including menthol

Flavor policy recommendations

The WHO FCTC requires governments that are For more information on menthol and flavored
Parties to the treaty to develop the most effective products, please visit these pages on Tobacco
legislation. Researchers who have reviewed Tactics:
existing bans and policies57 make the following
policy recommendations: • Flavoured and Menthol Tobacco

• Flavoured and Menthol Tobacco in LMICs

1. All flavored tobacco products should be
banned. • Menthol Cigarettes: Industry Interference in the
EU and U.K.
2. All flavored tobacco product accessories such
as filters and papers should be banned. • Promotion of Newer Products Around The U.K.
3. Flavor bans should prohibit ingredients, not just Menthol Ban
characterizing flavors.
4. Accelerate implementation to stop sales of
flavored tobacco quickly.
5. Implement standardized packaging and ban
marketing, as these can make flavors more
appealing.

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Dedication
This brief is dedicated to the memory of Dr. Mateusz Zatoński (1987-2022). Mateusz was a Research
Fellow with the Tobacco Control Research Group at the University of Bath (a partner in STOP). His
research, much of which is cited in this brief, has made a significant contribution to our understanding
of the impact and use of menthol and flavored tobacco products. Through collaborating with colleagues
in the United Kingdom and across the world, Mateusz exposed how the tobacco industry threatens
health and demonstrated how this can be countered by governments, policymakers and public health
advocates.

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Endnotes
1 World Health Organization [Internet]. WHO advisory note. Case studies for regulatory approaches to tobacco products: menthol in tobacco products,
WHO advisory note, 2018 [accessed 2022 March 11]. Available from: https://www.who.int/docs/default-source/regulating-tobacco-products/who-
nmh-pnd-18-1-eng.pdf?sfvrsn=632b7704_2

2 U.S. Food and Drug Administration. Tobacco Product Standard for Menthol in Cigarettes [Internet]. Washington DC: Food and Drug Administration;
2022 May [cited 2022 May 4]. 49 p. Available from: https://www.federalregister.gov/documents/2022/05/04/2022-08994/tobacco-product-
standard-for-menthol-in-cigarettes

3 World Health Organization [Internet]. Partial guidelines for implementation of articles 9 and 10 of the WHO Framework Convention on Tobacco
Control: regulation of the contents of tobacco products and of tobacco product disclosures. 2017, [accessed 2022 April 11]. Available from: https://
fctc.who.int/docs/librariesprovider12/meeting-reports/guidelines_articles_9_10_2017_english.pdf?sfvrsn=1ee182e4_1&download=true

4 Hersey JC, Wen NS, Nonnemaker J, et al. Are Menthol Cigarettes a Starter Product for Youth? Nicotine Tob Res. 2006 [accessed 2022
March 11], 8(3):403-413. Available from: https://academic.oup.com/ntr/article-abstract/8/3/403/1100200?redirectedFrom=fulltext.
DOI:10.1080/14622200600670389

5 Huang L, Baker HM, Meernik C, et al. Impact of non-menthol flavours in tobacco products on perceptions and use among youth, young adults and
adults: a systematic review. Tobacco Control [Internet]. 2017 Oct. Available from: https://tobaccocontrol.bmj.com/content/26/6/709

6 Ahijevych K, Garrett BE. Menthol pharmacology and its potential impact on cigarette smoking behavior. Nicotine Tob Res. 2004 [accessed 2022
March 11], 6 (suppl 1):S17–S28. Available from: https://academic.oup.com/ntr/article-abstract/6/Suppl_1/S17/1124528?redirectedFrom=fulltext.
DOI: 10.1080/14622200310001649469

7 Food and Drug Administration [Internet]. Preliminary Scientific Evaluation of the Possible Public Health Effects of Menthol Versus Nonmenthol
Cigarettes, 2013 [accessed 2022 March 16]. Available from: https://permanent.access.gpo.gov/gpo39032/Preliminary Scientific Evaluation Menthol
508 reduced.pdf

8 Azagba, S, Minaker, LM, Sharaf, MF et al. Smoking intensity and intent to continue smoking among menthol and non-menthol adolescent smokers
in Canada. Cancer Causes Control, June 2014 [accessed 2022 March 11], 25, 1093–1099. Available from: https://link.springer.com/article/10.1007/
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9 Kabbani N. Not so Cool? Menthol’s discovered actions on the nicotinic receptor and its implications for nicotine addiction. Front Pharmacol. 2013 Jul
[accessed 2022 March 16], 23;4:95. Available from: https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3720998/. DOI: 10.3389/fphar.2013.00095. PMID:
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10 Kopa PN, Pawliczak R. Menthol additives to tobacco products. Reasons for withdrawing mentholated cigarettes in European Union on 20th may 2020
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11 World Health Organization [Internet]. Partial guidelines for implementation of articles 9 and 10 of the WHO Framework Convention on Tobacco
Control: regulation of the contents of tobacco products and of tobacco product disclosures. 2017, [accessed 2022 April 11]. Available from: https://
fctc.who.int/docs/librariesprovider12/meeting-reports/guidelines_articles_9_10_2017_english.pdf?sfvrsn=1ee182e4_1&download=true

12 World Health Organization [Internet]. Partial guidelines for implementation of articles 9 and 10 of the WHO Framework Convention on Tobacco
Control: regulation of the contents of tobacco products and of tobacco product disclosures. 2017, [accessed 2022 April 11]. Available from: https://
fctc.who.int/docs/librariesprovider12/meeting-reports/guidelines_articles_9_10_2017_english.pdf?sfvrsn=1ee182e4_1&download=true

13 Tobacco Tactics [Internet]. Flavored and Menthol Tobacco, Tobacco Tactics, updated 08 March 2022, [accessed 2022 March 11]. Available from:
https://tobaccotactics.org/wiki/flavored-and-menthol-tobacco/

14 Pankow JF, Luo W, McWhirter KJ, et al. Menthol-Plus’: a major category of cigarette found among ‘concept’ descriptor cigarettes from Mexico,
Tobacco Control, March 2021 [accessed 2022 March 11]. Available from: https://tobaccocontrol.bmj.com/content/tobaccocontrol/early/2021/03/08/
tobaccocontrol-2020-056173.full.pdf. DOI: 10.1136/tobaccocontrol-2020-056173

15 Kyriakos CN, Zatoński MZ, Filippidis FT. Flavor capsule cigarette use and perceptions: a systematic review. Tobacco Control, October 2021
[accessed 2022 March 11]. Available from: https://tobaccocontrol.bmj.com/content/early/2021/10/03/tobaccocontrol-2021-056837. DOI: 10.1136/
tobaccocontrol-2021-056837

16 Tobacco Free Kids [Internet]. Stopping menthol, saving lives: ending big tobacco’s predatory marketing to black communities, February 2021
[accessed 2022 March 11]. Available from: https://www.tobaccofreekids.org/assets/content/what_we_do/industry_watch/menthol-report/2021_02_
tfk-menthol-report.pdf

17 Villanti AC, Mowery PD, Delnevo CD, et al. Changes in the prevalence and correlates of menthol cigarette use in the USA, 2004–2014, Tobacco
Control 2016 [accessed 2022 March 16], 25:ii14-ii20. Available from: https://tobaccocontrol.bmj.com/content/25/Suppl_2/ii14

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18 Tobacco Free Kids [Internet]. Stopping menthol, saving lives: ending big tobacco’s predatory marketing to black communities, February 2021
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tfk-menthol-report.pdf

19 Action on Smoking & Health [Internet]. ASH & AATCLC File Lawsuit Against FDA, updated December 2020 [accessed 2022 March 11]. Available from:
https://ash.org/lawsuit-against-fda/

20 Action on Smoking & Health. National Medical Association (NMA) Joins AATCLC, AMA AND ASH IN LAWSUIT AGAINST THE FDA [Internet]. Action on
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21 American Medical Association. FDA agrees to ban menthol to protect African Americans. American Medical Association [Internet]. 2021 April [cited
2022 May 6]. Available from: https://www.ama-assn.org/press-center/press-releases/fda-agrees-ban-menthol-protect-african-americans

22 Office of the Commissioner. FDA proposes rules prohibiting menthol cigarettes and flavored cigars to prevent youth initiation, significantly reduce
tobacco-related disease and death [Internet]. U.S. Food and Drug Administration. 2022 April [cited 2022 May 6]. Available from: https://www.fda.gov/
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23 Kyriakos CN, Zatoński MZ, Filippidis FT. Flavor capsule cigarette use and perceptions: a systematic review. Tobacco Control, October 2021 [accessed
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24 Kyriakos CN, Zatoński MZ, Filippidis FT. Marketing of flavor capsule cigarettes: a systematic review Tobacco Control, January 2022 [accessed 2022
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25 Leonardi-Bee J, Jere ML, Britton J. Exposure to parental and sibling smoking and the risk of smoking uptake in childhood and adolescence:
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26 Zatoński M, Silver K, Plummer S, Hiscock R. Menthol and flavored tobacco products in LMICs: A growing menace. Tob Induc Dis [Internet]. 2022 April
[cited 2022 May 6]; 20(April):39. Available from: http://www.tobaccoinduceddiseases.org/Menthol-and-flavored-tobacco-products-in-LMICs-A-
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28 Action on Smoking and Health [Internet]. ASH fact sheet: Tobacco and the developing world. July 2019 [accessed 2022 March 11]. Available from:
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29 Zatoński M, Silver K, Plummer S, Hiscock R. Menthol and flavored tobacco products in LMICs: A growing menace. Tob Induc Dis [Internet]. 2022 April
[cited 2022 May 6]; 20(April):39. Available from: http://www.tobaccoinduceddiseases.org/Menthol-and-flavored-tobacco-products-in-LMICs-A-
growing-nmenace,146366,0,2.html

30 Erinoso O, Clegg Smith K, Iacobelli M, et al. Global review of tobacco product flavour policies. Tobacco Control 2021 [accessed 2022 March 11],
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31 National Institute for Public Health and the Environment (RIVM) [Internet]. Menthol facilitates inhalation of tobacco smoke, even when you cannot
taste it, June 2021 [accessed 2022 March 21]. Available from: https://www.rivm.nl/en/news/menthol-facilitates-inhalation-of-tobacco-smoke

32 OCCRP [Internet]. Japan Tobacco International Making a Mint by Circumventing Menthol Cigarette Ban, November 2021 [accessed 2022 March 21].
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33 Oliveira da Silva AL, Bialous SA, Albertassi PGD et al, The taste of smoke: tobacco industry strategies to prevent the prohibition of additives
in tobacco products in Brazil, Tobacco Control, 2019 [accessed 2022 March 11], 28:e92-e101. Available from: https://tobaccocontrol.bmj.com/
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34 Southeast Asia Tobacco Control Alliance [Internet], Brazil: Flavored Tobacco Products Banned After Long Court Battle 2018, updated 5 February 2018
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35 C. Lopez A , Cigarrillos Mentolados, letter to El Mercurio newspaper available from BAT Chile website, 2014, [accessed 2022 March 11]. Available
from: https://web.archive.org/web/20200309143521/http:/www.batchile.com/group/sites/bat_9yfd2p.nsf/vwPagesWebLive/DO9YLL3C/$FILE/
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36 Tobacco Tactics [Internet]. Flavored and Menthol Tobacco, updated 08 March 2022 [accessed 2022 March 11]. Available from: https://tobaccotactics.
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37 Office of the Commissioner. FDA proposes rules prohibiting menthol cigarettes and flavored cigars to prevent youth initiation, significantly reduce
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38 Vyas P, Ling P, Gordon B, Callewaert J, Dang A, Smith D, et al. Compliance with San Francisco’s flavoured tobacco sales prohibition. Tob Control
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Flavoured%20Tobacco%20Sales%20Prohibition.pdf

39 San Francisco to vote on flavored tobacco ban [Internet]. POLITICO. [cited 2022 May 11]. Available from: https://www.politico.com/story/2018/06/02/
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40 Gammon DG, Rogers T, Gaber J, Nonnemaker JM, Feld AL, Henriksen L, et al. Implementation of a comprehensive flavoured tobacco product
sales restriction and retail tobacco sales. Tob Control [Internet]. 2021 [cited 2022 May 6]; tobaccocontrol-2021-056494. Available from: https://
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41 Gammon DG, Rogers T, Gaber J, Nonnemaker JM, Feld AL, Henriksen L, et al. Implementation of a comprehensive flavoured tobacco product sales
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42 Stockton B, Baumgaertner E, Lindsay R. Paid protesters, free lunches and backroom chats: Inside the menthol lobbying machine [Internet]. The
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43 Chung-Hall J, Fong GT, Meng G, et al. Evaluating the impact of menthol cigarette bans on cessation and smoking behaviours in Canada:
longitudinal findings from the Canadian arm of the 2016–2018 ITC Four Country Smoking and Vaping Surveys. Tobacco Control, April 2021
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44 Health Canada. Order amending the schedule to the tobacco act (menthol) [Internet]. Canada.ca. 2017 [cited 2022 May 19]. Available from: https://
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45 Schwartz R, Chaiton M, Borland T, Diemert L. Tobacco industry tactics in preparing for menthol ban. Tob Control [Internet]. 2018 [cited 2022 May
6];27(5):577–577. Available from: https://tobaccocontrol.bmj.com/content/27/5/577

46 Chung-Hall J, Fong GT, Meng G, et al. Evaluating the impact of menthol cigarette bans on cessation and smoking behaviours in Canada:
longitudinal findings from the Canadian arm of the 2016–2018 ITC Four Country Smoking and Vaping Surveys. Tobacco Control, April 2021
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tobaccocontrol-2020-056259

47 Fong GT, Chung-Hall J, Meng G, Craig LV, Thompson ME, Quah ACK, et al. Impact of Canada’s menthol cigarette ban on quitting among menthol
smokers: pooled analysis of pre-post evaluation from the ITC Project and the Ontario Menthol Ban Study and projections of impact in the USA. Tob
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48 Tobacco Tactics [Internet]. Menthol Cigarettes: Industry Interference in the EU and UK, updated 15 December 2021, [accessed 2022 March 11].
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49 Hiscock R, Silver K, Zatoński M, et al. Tobacco industry tactics to circumvent and undermine the menthol cigarette ban in the UK. Tobacco
Control 2020 [accessed 2022 March 11], 29:e138-e142. Available from: https://tobaccocontrol.bmj.com/content/tobaccocontrol/29/e1/e138.full.pdf

50 Tobacco Tactics [Internet]. Menthol Cigarettes: Industry Interference in the EU and UK, updated 15 December 2021 [accessed 2022 March 11].
Available from: https://tobaccotactics.org/wiki/menthol-interference-eu-uk/

51 Banks, M. Member states urged to do more to enforce new tobacco legislation. Eureporter, April 2021 [accessed 2022 March 11]. Available from:
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52 Cadham CJ, Sanchez-Romero LM, Fleischer NL, Mistry R, Hirschtick JL, Meza R, et al. The actual and anticipated effects of a menthol cigarette ban: a
scoping review. BMC Public Health [Internet]. 2020;20(1):1055. Available from: http://dx.doi.org/10.1186/s12889-020-09055-z

53 Branston JR, Hiscock R, Silver K, Arnott D, Gilmore AB. Cigarette-like cigarillo introduced to bypass taxation, standardised packaging, minimum pack
sizes, and menthol ban in the UK. Tob Control [Internet]. 2021 [cited 2022 May 6]; 30(6):708–11. Available from: https://tobaccocontrol.bmj.com/
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54 Hiscock R, Silver K, Zatoński M, et al. Tobacco industry tactics to circumvent and undermine the menthol cigarette ban in the UK. Tobacco
Control 2020 [accessed 2022 March 11], 29:e138-e142. Available from: https://tobaccocontrol.bmj.com/content/tobaccocontrol/29/e1/e138.full.pdf

55 Hefler M. Menthol: Tobacco Companies are exploiting loopholes in the UK’s characterising flavours ban [Internet]. Blog - Tobacco Control. 2021 [cited
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flavours-ban/

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56 Hiscock R, Silver K, Zatoński M, et al. Tobacco industry tactics to circumvent and undermine the menthol cigarette ban in the UK. Tobacco
Control 2020 [accessed 2022 March 11], 29:e138-e142. Available from: https://tobaccocontrol.bmj.com/content/tobaccocontrol/29/e1/e138.full.pdf

57 Przewoźniak K, Kyriakos CN, Hiscock R, Radu-Loghin C, Fong GT. Effects of and challenges to bans on menthol and other flavors in tobacco
products. Tob Prev Cessat [Internet]. 2021 [cited 2022 May 6];7(November):68. Available from: http://www.tobaccopreventioncessation.com/Effects-
of-and-challenges-to-bans-on-menthol-and-other-flavors-in-tobacco-products,143072,0,2.html

About STOP (Stopping Tobacco Organizations and Products)

STOP is a global tobacco industry watchdog whose mission is to expose the tobacco industry strategies
and tactics that undermine public health. STOP is funded by Bloomberg Philanthropies and comprised of a
partnership among the Tobacco Control Research Group (TCRG) at the University of Bath, The Global Center for
Good Governance in Tobacco Control (GGTC), the International Union Against Tuberculosis and Lung Disease
(The Union) and Vital Strategies. For more information, visit exposetobacco.org.

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