The key arguments used by TI against the additive ban in Brazil
| TI arguments | Comments/counter-arguments |
| Additives do not increase toxicity of tobacco products | ANVISA, following FCTC partial guidelines to implement articles 9 and 10, did not use the issue of the toxicity of additives in its proposed ban—it focuses on how additives increase attractiveness and palatability of tobacco products. Despite research published by TI106–108 showing no increased toxicity associated with additives, independent research indicates that there could be an increased toxicity, or at a minimum, that additives are not innocuous,110 111 thus making this TI argument controversial. Increased attractiveness of tobacco products facilitates initiation and deep inhalation of smoke,27 thus it is currently undeniable that additives negatively affect public health. |
| The additives ban would make it impossible to grow Burley tobacco | The TI already produces cigarettes using Burley tobacco without using any of the additives prohibited by ANVISA’s resolution. In Brazil, these “additive-free” cigarettes emerged in 2012.112
Internal TI documents show a patent application from the 1990s to recompose Burley tobacco’s sugars (lost during the curing process) without the use of additives.113 According to data from the TI, over 80% of the tobacco leaf production in Brazil is exported.114 The resolution has no impact on tobacco that is grown for export, as it only applies to tobacco products manufactured for sales and distribution in Brazil. |
| It is not possible to manufacture ‘American blend’ cigarettes without additives, as this blend requires the use of Burley tobacco | As described above, the argument that the resolution would ban the growth and use of Burley tobacco was not supported by evidence. |
| ANVISA has no mandate to ban additives | The Supreme Court found in favour of ANVISA’s mandate to regulate tobacco products, including the ban of additives. |
| The resolution banning additives will lead to an increase illicit trade | There is no evidence to support this statement. |
| Additives are not used to attract teenagers to use tobacco products | The use of additives in tobacco products facilitates tobacco use, enhances the effects of nicotine and uses false claims of properties associated with health and well-being.27–32
Data from the TI33 show that flavourings are added to cigarettes to improve their flavour and aroma.34 TI documents show that additives are used to reduce airway irritation caused by smoke.23 33–35 |
TI, tobacco industry.