Introduction

Cigarettes are inherently unsafe and no amount of tinkering and product modification over decades has made them safe or even less hazardous. Indeed, evidence suggests they have become more hazardous.1 But as there are now new substitute nicotine products available, it has been suggested that the viability of phasing out cigarettes should be re-assessed.2 This paper proposes one way this could be done.

Unlike many other consumer products, no safety standards have been set for cigarettes or other tobacco products. The Framework Convention on Tobacco Control (FCTC) acknowledges the role of regulating the toxicity of tobacco,3 and the WHO scientific committees on tobacco regulation (TobReg and SACTob) have repeatedly called for such regulations to be developed.4–7 Despite this, no country or scientific authority has yet set out a path ‘to establish actual rather than theoretical control of product design’,7 and parties to the FCTC have yet to receive any guidance on how to do so.8 In the absence of such regulations, tobacco companies have continued to design their cigarettes without regulatory obligations to address their inherent harmfulness.

Nonetheless, in the absence of any product standards, some of these companies have recently developed and are now marketing nicotine and tobacco products that they describe as reduced risk.9 10 These include tobacco products variously described as tobacco heating products (THPs) or heat-not-burn (HNB) products, which use battery-powered heating elements rather than combustion to release nicotine and other compounds from a processed tobacco leaf.

The design and marketing of these products is evidence that manufacturers have achieved the technical capacity to reduce the quantity of toxins inhaled through tobacco use. Manufacturers’ reports to investors claim that these new tobacco products are economically viable, and that smokers can be persuaded to use them.11 12 Whether they …