During public consultation: 2010–2011
Discursive strategyDomainArgument
Unanticipated costs to economy and societyThe economyLoss of jobs (specially farmers) and sales, impossibility to grow burley tobacco.
Loss of tax revenue due to increase in illicit trade.
Law enforcementRise of illicit trade as adults who smoke flavoured cigarettes will purchase them in illicit market, thus increasing contraband.
The lawANVISA has no mandate to ban additives.
Intended public health benefitsThere is not enough evidence of public health benefits from additive bansThere is no scientific evidence about the relation between the use of additives in tobacco products and attractiveness of tobacco products, particularly to youth.
Policy (ban) will not workThe additive ban will be ineffective to prevent youth uptake of tobacco use.
Unintended benefits to undeserving groupsSmugglers will profitThe additive ban will rise illicit trade and will only benefit smugglers and crime.
Expected tobacco industry costsAdditives ban will reduce sales and jobsThe additive ban will increase illicit trade, and it will prevent the growing of burley tobacco, generating poverty, job losses and loss of tax revenues.
Impossibility to manufacture cigarettes without additives, thus the ban will lead to job losses in the industry and rise in unemployment.