Analysis
Pictorial health warnings are required to cover 100% of the back of all tobacco product packages. The warnings must appear sequentially, either simultaneously or on a rotating basis. If the warnings appear on a rotating basis, they must vary at most every five months. In addition, text-only warnings must occupy 30% of the lower front of tobacco product packages.
Nine rotating messages are required to display qualitative (descriptive) constituents and emissions information including: benzene, ammonia, heavy metals, arsenic, nitrosamines, formaldehyde, cyanide, nicotine, and carbon monoxide. Messages are required to be printed on 75% of one lateral side of the package. Each of the nine messages is to be printed along with a specific pictorial health warning label on the same package.
The law meets FCTC Art. 11, with warning labels displayed on both the front and back and occupying at least 30% of each principal display area. However, to more fully align with FCTC Art. 11 and the FCTC Art. 11 Guidelines, pictorial health warnings should occupy at least 50% of each principal display area.
Although the smokeless tobacco market in Brazil is small, these products are available in the country. It is uncertain to what extent smokeless tobacco products carry health warnings and messages. Health warnings specific to smokeless tobacco products should be developed for use on these products.
