The proposal by the World Health Organization Study Group on Tobacco Product Regulation (TobReg) for the setting of limits on emissions of certain toxicants in cigarette smoke1 is certain to generate heated debate. Product regulation remains the most fraught policy area in tobacco control. In other areas, public health dictates are clear. Ongoing contests tend to be primarily either ones of competing values, political will or the details of implementation. Regulation of cigarette smoke emissions is fundamentally different. It is not clear how, or even if, regulation can advance public health, and there are substantial risks in getting things wrong.

In such circumstances, how does policy move forward? In its report, TobReg asserts that its approach is “based on the well-accepted precautionary approaches used in public health”, with known harmful constituents of products to be reduced “to the extent technically feasible” without need for “proof of a specific linkage between a lower level (amount) of any individual constituent and a lower level of human disease (response)”. Burns et al reiterate this point in their paper describing the proposal.2 They argue that, while “[e]xisting science does not allow a definitive conclusion that reduction of nitrosamines, or any other individual toxicants in cigarette smoke, will reduce cancer incidence, or the rate of any other tobacco related disease, in smokers who use cigarettes with lower levels of these toxicants”, TobReg’s proposed strategy is “based on sound precautionary approaches of reducing toxicant levels wherever possible”. In papers that question the wisdom of setting emissions limits, Chapman3 and Hammond et al4 nevertheless accept that the approach enjoys the support of the “precautionary principle”.

Risks of the TobReg proposal

Neither TobReg’s report nor the Burns et al paper elide the risks of the TobReg proposal. TobReg, acutely aware of the history …