During public consultation: 2010–2011
Discursive strategy	Domain	Argument
Unanticipated costs to economy and society	The economy	Loss of jobs (specially farmers) and sales, impossibility to grow burley tobacco.
	The economy	Loss of tax revenue due to increase in illicit trade.
	Law enforcement	Rise of illicit trade as adults who smoke flavoured cigarettes will purchase them in illicit market, thus increasing contraband.
	The law	ANVISA has no mandate to ban additives.
Intended public health benefits	There is not enough evidence of public health benefits from additive bans	There is no scientific evidence about the relation between the use of additives in tobacco products and attractiveness of tobacco products, particularly to youth.
Intended public health benefits	Policy (ban) will not work	The additive ban will be ineffective to prevent youth uptake of tobacco use.
Unintended benefits to undeserving groups	Smugglers will profit	The additive ban will rise illicit trade and will only benefit smugglers and crime.
Expected tobacco industry costs	Additives ban will reduce sales and jobs	The additive ban will increase illicit trade, and it will prevent the growing of burley tobacco, generating poverty, job losses and loss of tax revenues.
Expected tobacco industry costs	Additives ban will reduce sales and jobs	Impossibility to manufacture cigarettes without additives, thus the ban will lead to job losses in the industry and rise in unemployment.