Objectives To assess the ‘Massachusetts Benchmark Study’ (MBS) that the tobacco companies presented to the Massachusetts Department of Public Health (MDPH) in 1999 in response to ingredient disclosure regulations in the state. This case study can inform future ingredient disclosure regulations, including implementation of Articles 9 and 10 of the WHO Framework Convention on Tobacco Control (FCTC).

Methods We analysed documents available at http://legacy.library.ucsf.edu to identify internal communications regarding the design and execution of the MBS and internal studies on the relationship between tar, nicotine and carbon monoxide and smoke constituents and reviewed publications that further evaluated data published as part of the MBS.

Results The companies conducted extensive studies of cigarette design factors and ingredients that significantly impacted the levels of constituents. While this study asserted that by-brand emissions could be estimated reliably from published tar, nicotine, and carbon monoxide levels, the tobacco companies were well aware that factors beyond tar, nicotine and carbon monoxide influenced levels of constituents included in the study. This severely limited the potential usefulness of the MBS predictor equations.

Conclusions Despite promises to provide data that would allow regulators to predict constituent data for all brands on the market, the final MBS results offered no useful predictive information to inform regulators, the scientific community or consumers. When implementing FCTC Articles 9 and 10, regulatory agencies should demand detailed by-brand information on tobacco product constituents and toxin deliveries to users.