Canadian Cancer Public Comment

Canadian Cancer Society comment on Docket No.FDA-2011-N-0867

In Belgium, legislation requires that ingredients of all tobacco products and their
quantities be reported to the Belgium government on a brand by brand. In the case of
cigarettes, this includes ingredients in the filter, paper and tobacco portions of the
cigarette.
The Belgium Government has established a website to provide public accessibility to this
reported information:
http://www.health.belgium.be/pls/apex/f?p=EMTOC_SEARCH:1::CHANGELANGUA
GE:::FSP_LANGUAGE_PREFERENCE:fr
Here is an example for Marlboro:
http://www.health.belgium.be/pls/apex/f?p=342:30:3299694417865889::NO::P30_EMT
OC_ID:401138
(It is in French, but one can get the general idea of the additives listed – 61 in all – at the
bottom, you can click to get to the next 15 in the list).
On this website, in the case of cigarettes, information for ingredients weighing less than
0.1% of the product is not expected to be provided for each ingredient, but is instead
grouped. For cigars, information for ingredients weighing less than 0.5% of the product
is not expected to be provided for each ingredient, but is instead grouped.
While ingredient reporting by tobacco companies to the Belgium government is required
by law, ingredient reporting on this website is not required by law. Instead, the website
depends on voluntary participation by companies. British American Tobacco, Japan
Tobacco International, Imperial Tobacco, and Philip Morris International are among the
companies participating voluntarily.
The Belgium website became live during the fourth quarter of calendar 2011. The new
Belgium website has received only a small number of visits. The Belgium government
made a deliberate choice not to publicize the website.
In the United States, if the FDA were to establish a website with lists of information
pertaining to individual tobacco products, the FDA should ensure that tobacco
manufacturers, importers and retailers (1) conform to section 911 of the Family Smoking
Prevention and Tobacco Control Act regarding modified risk product claims related to
any characterization of the contents of lists/information on or not on the website, and
(2) conform to any prohibitions on advertising, promotion that is false, misleading or
deceptive.