LANGUAGE
Last updated: February 12th 2020

Regulated Forms of Advertising, Promotion and Sponsorship

Domestic TV and radio (including all broadcast media such as satellite and cable)

Banned
The listed form of tobacco advertising, promotion & sponsorship is completely banned.
Analysis:

Law 2002, Art. 2 (which amends Law 1981, adding Art. VI Bis) prohibits all forms of tobacco advertising and promotion. The Bylaw specifically prohibits tobacco advertising and promotion “in all means of publicity, including newspapers, magazines, stationary or moving pictures, television, radio or any other way intended.” Thus, tobacco advertising and promotion via domestic TV, radio, and other forms of broadcast media is banned.

The law aligns with FCTC Art. 13 and the FCTC Art. 13 Guidelines with respect to tobacco advertising and promotion on domestic TV, radio, and other forms of broadcast media such as satellite and cable. However, this would be made clearer by defining the term “tobacco advertising and promotion” in accordance with FCTC Art. 1(c).

Domestic newspapers and magazines

Banned
The listed form of tobacco advertising, promotion & sponsorship is completely banned.
Analysis:

Law 2002, Art. 2 (which amends Law 1981, adding Art. VI Bis) prohibits all forms of tobacco advertising and promotion. The Bylaw specifically prohibits tobacco advertising and promotion “in all means of publicity, including newspapers, magazines, stationary or moving pictures, television, radio or any other way . . . .” Thus, tobacco advertising and promotion via domestic newspapers and magazines is banned.

The law aligns with FCTC Art. 13 and the FCTC Art. 13 Guidelines with respect to tobacco advertising and promotion in domestic newspapers and magazines. However, this would be made clearer by defining the term “tobacco advertising and promotion” in accordance with FCTC Art. 1(c).

Other domestic print media, such as pamphlets, leaflet, flyers, posters, signs (not including print advertising at the point of sale)

Banned
The listed form of tobacco advertising, promotion & sponsorship is completely banned.
Analysis:

Law 2002, Art. 2 (which amends Law 1981, adding Art. VI Bis) prohibits all forms of tobacco advertising and promotion. The Bylaw specifically prohibits tobacco advertising and promotion “in all means of publicity, including newspapers, magazines, stationary or moving pictures, television, radio or any other way . . . .” Thus, tobacco advertising and promotion via domestic print media, such as pamphlets, leaflets, flyers, posters, and signs are banned.

The law aligns with FCTC Art. 13 and the FCTC Art. 13 Guidelines with respect to tobacco advertising and promotion via domestic print media. However, this would be made clearer by defining the term “tobacco advertising and promotion” in accordance with FCTC Art. 1(c).

International TV and radio (including all broadcast media such as satellite and cable)

Uncertain
The status of the regulation is uncertain due to lack of clarity in the law or inability to obtain all relevant laws.
Analysis:

Law 2002, Art. 2 (which amends Law 1981, adding Art. VI Bis) prohibits all forms of tobacco advertising and promotion. The Bylaw specifically prohibits tobacco advertising and promotion “in all means of publicity, including newspapers, magazines, stationary or moving pictures, television, radio or any other way . . . .” Although the law bans tobacco advertising via domestic TV, radio, and other forms of broadcast media, it is uncertain whether the ban applies to international broadcast media.

To align with FCTC Art. 13 and the FCTC Art. 13 Guidelines, the law should explicitly apply the ban on tobacco advertising and promotion to both domestic and cross-border broadcast media. In addition, the law should define “tobacco advertising and promotion” in accordance with FCTC Art. 1(c).

International newspapers and magazines

Uncertain
The status of the regulation is uncertain due to lack of clarity in the law or inability to obtain all relevant laws.
Analysis:

Law 2002, Art. 2 (which amends Law 1981, adding Art. VI Bis) prohibits all forms of tobacco advertising and promotion. The Bylaw specifically prohibits tobacco advertising and promotion “in all means of publicity, including newspapers, magazines, stationary or moving pictures, television, radio or any other way . . . .” However, it is uncertain whether the ban applies to all means of cross-border advertising, including via international newspapers and magazines.

To align with FCTC Art. 13 and the FCTC Art. 13 Guidelines, the law should explicitly ban tobacco advertising and promotion in both domestic and cross-border newspapers and magazines. In addition, the law should define “tobacco advertising and promotion” in accordance with FCTC Art. 1(c).

Internet communications

Banned
The listed form of tobacco advertising, promotion & sponsorship is completely banned.

Internet communications (not sales)

Analysis:

Law 2002, Art. 2 (which amends Law 1981, adding Art. VI Bis) prohibits all forms of tobacco advertising and promotion. The Bylaw specifically prohibits tobacco advertising and promotion “in all means of publicity, including newspapers, magazines, stationary or moving pictures, television, radio or any other way . . . .” Thus, tobacco advertising and promotion via internet communications is banned.

The law aligns with FCTC Art. 13 and the FCTC Art. 13 Guidelines with respect to tobacco advertising and promotion via internet communications. However, this would be made clearer by defining the term “tobacco advertising and promotion” in accordance with FCTC Art. 1(c).

Internet tobacco product sales

Allowed
There is no ban and there are no restrictions whatsoever applicable.
Analysis:

The law does not specifically prohibit or restrict the sale of tobacco products through the internet; therefore, the law is interpreted as permitting internet tobacco product sales.

To align with FCTC Art. 13 and the FCTC Art. 13 Guidelines, the law should prohibit internet tobacco product sales, regardless of age, as internet sales are an inherent form of tobacco advertising and promotion.

Outdoor advertising (e.g., billboards, posters)

Banned
The listed form of tobacco advertising, promotion & sponsorship is completely banned.
Analysis:

Law 2002, Art. 2 (which amends Law 1981, adding Art. VI Bis) prohibits all forms of tobacco advertising and promotion. The Bylaw specifically prohibits tobacco advertising and promotion “in all means of publicity, including newspapers, magazines, stationary or moving pictures, television, radio or any other way . . . .” Thus, tobacco advertising and promotion via outdoor advertising is banned.

The law aligns with FCTC Art. 13 and the FCTC Art. 13 Guidelines with respect to tobacco advertising and promotion via outdoor advertising. However, this would be made clearer by defining the term “tobacco advertising and promotion” in accordance with FCTC Art. 1(c).

Point of sale advertising/promotion

Banned
The listed form of tobacco advertising, promotion & sponsorship is completely banned.

Point of sale advertising/promotion (other than product displays)

Analysis:

Law 2002, Art. 2 (which amends Law 1981, adding Art. VI Bis) prohibits all forms of tobacco advertising and promotion. The Bylaw specifically prohibits tobacco advertising and promotion “in all means of publicity, including newspapers, magazines, stationary or moving pictures, television, radio or any other way . . . .” Thus, point-of-sale tobacco advertising and promotion is banned.

The law aligns with FCTC Art. 13 and the FCTC Art. 13 Guidelines with respect to point-of-sale tobacco advertising and promotion. However, this would be made clearer by defining the term “tobacco advertising and promotion” in accordance with FCTC Art. 1(c).

Point of sale product display

Uncertain
The status of the regulation is uncertain due to lack of clarity in the law or inability to obtain all relevant laws.
Analysis:

The law does not address point of sale product displays specifically and “tobacco advertising and promotion” is not defined, making it difficult to determine if the law contemplates product displays as a form of tobacco advertising falling within the advertising ban, as the FCTC Art. 13 Guidelines do.

For the law to align with FCTC Art. 13 and the FCTC Art. 13 Guidelines, product displays should clearly be banned under a broad prohibition on tobacco advertising and promotion. The term “tobacco advertising and promotion” should be defined in accordance with FCTC Art. 1(c).

Vending machines

Uncertain
The status of the regulation is uncertain due to lack of clarity in the law or inability to obtain all relevant laws.
Analysis:

The law does not address vending machine sales of tobacco specifically and “tobacco advertising and promotion” is not defined, making it difficult to determine if the law covers vending machine sales.

For the law to align with FCTC Art. 13, the FCTC Art. 13 Guidelines, and FCTC Art. 16 (sales to and by minors), it should be made clear that vending machine sales of tobacco products (and other commercial product displays) are prohibited as inherent forms of tobacco advertising and promotion, as provided in the FCTC Art. 13 Guidelines para. 14. In addition, the law should define the term “tobacco advertising and promotion” in accordance with FCTC Art. 1(c).

Conventional mail

Banned
The listed form of tobacco advertising, promotion & sponsorship is completely banned.
Analysis:

Law 2002, Art. 2 (which amends Law 1981, adding Art. VI Bis) prohibits all forms of tobacco advertising and promotion. The Bylaw specifically prohibits tobacco advertising and promotion “in all means of publicity, including newspapers, magazines, stationary or moving pictures, television, radio or any other way . . . .” This is interpreted as prohibiting tobacco advertising and promotion sent via conventional mail.

The law aligns with FCTC Art. 13 and the FCTC Art. 13 Guidelines with respect to tobacco advertising and promotion via conventional mail. However, this would be made clearer by defining the term “tobacco advertising and promotion” in accordance with FCTC Art. 1(c).

Telephone and cellular phone

Banned
The listed form of tobacco advertising, promotion & sponsorship is completely banned.
Analysis:

Law 2002, Art. 2 (which amends Law 1981, adding Art. VI Bis) prohibits all forms of tobacco advertising and promotion. The Bylaw specifically prohibits tobacco advertising and promotion “in all means of publicity, including newspapers, magazines, stationary or moving pictures, television, radio or any other way . . . .” This is interpreted as prohibiting tobacco advertising and promotion via telephone and cellular phone.

The law aligns with FCTC Art. 13 and the FCTC Art. 13 Guidelines with respect to tobacco advertising and promotion via telephone and cellular phone. However, this would be made clearer by defining the term “tobacco advertising and promotion” in accordance with FCTC Art. 1(c).

Brand marking on physical structures

Uncertain
The status of the regulation is uncertain due to lack of clarity in the law or inability to obtain all relevant laws.

Distinctive words, designs, images, logos, sounds, or colors to promote tobacco products in entertainment venues, retail outlets, on vehicles and equipment, or other physical structures (brand marking on physical structures, other than on tobacco product packaging and labeling and print material)

Analysis:

The law does not address brand marking and “tobacco advertising and promotion” is not defined, making it difficult to determine if the ban on advertising and promotion applies to brand marking.

For the law to align with FCTC Art. 13 and the FCTC Art. 13 Guidelines, brand marking should be prohibited under the broad ban on tobacco advertising and promotion, and the term “tobacco advertising and promotion” should be defined in accordance with FCTC Art. 1(c).

Free distribution of tobacco products

Banned
The listed form of tobacco advertising, promotion & sponsorship is completely banned.
Analysis:

Law 2002, Art. 2 (amending Law 1981, adding Art. VI Bis (1)) specifically prohibits the distribution of a tobacco product as a free gift or prize. This provision meets FCTC Art. 16 and aligns with FCTC Art. 13 and the FCTC Art. 13 Guidelines in this regard.

Promotions with a tobacco product purchase

Banned
The listed form of tobacco advertising, promotion & sponsorship is completely banned.

Promotional discounts, gifts, prizes, rewards to consumers in conjunction with a tobacco product purchase (e.g., buy one pack, get one free or, key chains, t-shirts, coupons, points)

Analysis:

Law 2002, Art. 2 (amending Law 1981, adding Art. VI Bis (1)) specifically prohibits the distribution of a tobacco product as a free gift or prize, and prohibits the sale of a tobacco product as a means for customers to obtain other types of rewards. The law is interpreted as prohibiting promotional discounts under the general ban on advertising and promotion of tobacco products “by any other means.”

The law aligns with FCTC Art. 13 and the FCTC Art. 13 Guidelines with respect to promotional discounts, gifts, prizes and rewards to customers. However, this would be made clearer by defining the term “tobacco advertising and promotion” in accordance with FCTC Art. 1(c).

Competitions associated with tobacco products

Uncertain
The status of the regulation is uncertain due to lack of clarity in the law or inability to obtain all relevant laws.

Competitions associated with tobacco products or brand names, whether requiring the purchase of a tobacco product or not

Analysis:

Law 2002, Art. 2 (amending Law 1981, adding Art. VI Bis (1)) specifically prohibits the distribution of a tobacco product in conjunction with competitions. The law is silent, however, with regard to competitions associated with tobacco products where tobacco products are not sold or distributed. Because “tobacco advertising and promotion” is not defined, it is unclear whether competitions associated with tobacco products fall within the general ban on tobacco advertising and promotion.

To align with FCTC Art. 13 and the FCTC Art. 13 Guidelines, the law should prohibit competitions associated with tobacco products under the broad ban on tobacco advertising and promotion, and the term “tobacco advertising and promotion” should be defined in accordance with FCTC Art. 1(c).

Direct person to person targeting of individuals

Banned
The listed form of tobacco advertising, promotion & sponsorship is completely banned.
Analysis:

Law 2002, Art. 2 (which amends Law 1981, adding Art. VI Bis) prohibits all forms of tobacco advertising and promotion. The Bylaw specifically prohibits tobacco advertising and promotion “in all means of publicity, including newspapers, magazines, stationary or moving pictures, television, radio or any other way . . .” This is interpreted as prohibiting tobacco direct targeting of individuals with promotional information materials through any means. In practice, this form of advertising is not common in Egypt.

The law aligns with FCTC Art. 13 and the FCTC Art. 13 Guidelines with respect to tobacco advertising and promotion via direct marketing. However, this would be made clearer by defining the term “tobacco advertising and promotion” in accordance with FCTC Art. 1(c).

Brand stretching/trademark diversification

Banned
The listed form of tobacco advertising, promotion & sponsorship is completely banned.

Non-tobacco products or services using tobacco brand names or carrying a brand logo or other brand indicia (brand stretching)

Analysis:

The law does not specifically address brand stretching. Law 2002, Art. 2 (which amends Law 1981, adding Art. VI Bis), however, prohibits all forms of tobacco advertising and promotion, and the 2010 Bylaw specifies that such advertising is banned “in all means of publicity, including newspapers, magazines, stationary or moving pictures, television, radio or any other way . . . .” This is interpreted as prohibiting tobacco advertising and promotion via brand stretching. The law aligns with FCTC Art. 13 and the FCTC Art. 13 Guidelines with respect to tobacco advertising and promotion via brand stretching. However, this would be made clearer by defining the term “tobacco advertising and promotion” in accordance with FCTC Art. 1(c).

Reverse brand stretching or brand sharing

Banned
The listed form of tobacco advertising, promotion & sponsorship is completely banned.

Tobacco products or services using non-tobacco brand names (reverse brand stretching or brand sharing)

Analysis:

The law does not specifically address reverse brand stretching. Law 2002, Art. 2 (which amends Law 1981, adding Art. VI Bis), however, prohibits all forms of tobacco advertising and promotion, and the 2010 Bylaw specifies that such advertising is banned “in all means of publicity, including newspapers, magazines, stationary or moving pictures, television, radio or any other way . . . .” This is interpreted as prohibiting tobacco advertising and promotion via reverse brand stretching. The law aligns with FCTC Art. 13 and the FCTC Art. 13 Guidelines with respect to tobacco advertising and promotion via reverse brand stretching. However, this would be made clearer by defining the term “tobacco advertising and promotion” in accordance with FCTC Art. 1(c).

Toys that resemble tobacco products

Banned
The listed form of tobacco advertising, promotion & sponsorship is completely banned.
Analysis:

The Bylaw specifically bans sweets and toys manufactured in the shape of tobacco products.

The law aligns with FCTC Art. 13 and the FCTC Art. 13 Guidelines with regard to sweet and toys resembling tobacco products.

Candy that resembles tobacco products

Banned
The listed form of tobacco advertising, promotion & sponsorship is completely banned.
Analysis:

The Bylaw specifically bans sweets and toys manufactured in the shape of tobacco products.

The law aligns with FCTC Art. 13 and the FCTC Art. 13 Guidelines with regard to sweet and toys resembling tobacco products.

Retailer incentive programs

Uncertain
The status of the regulation is uncertain due to lack of clarity in the law or inability to obtain all relevant laws.

Retailer incentive programs (e.g., rewards to retailers for achieving certain sales volume, enhanced displays, etc.) or other payments to encourage them to sell tobacco products

Analysis:

The law does not specifically address retailer incentive programs. Retailer incentive programs may be covered under the general prohibition on advertising and promotion, under the catch-all by “any other means.” However, because “tobacco advertising and promotion” is not defined, it is difficult to determine if the ban on advertising and promotion applies to retailer incentive programs.

For the law to align with FCTC Art. 13 and the FCTC Art. 13 Guidelines, retailer incentive programs should be prohibited under the broad ban on tobacco advertising and promotion, and the term “tobacco advertising and promotion” should be defined in accordance with FCTC Art. 1(c).

Paid placement of tobacco products in TV, film or other media

Banned
The listed form of tobacco advertising, promotion & sponsorship is completely banned.
Analysis:

Law 2002, Art. 2 (which amends Law 1981, adding Art. VI Bis) prohibits all forms of tobacco advertising and promotion. The Bylaw specifically prohibits tobacco advertising and promotion “in all means of publicity, including newspapers, magazines, stationary or moving pictures, television, radio or any other way . . . .” This is interpreted as prohibiting paid placement of tobacco products in TV, film, or other media.

The law aligns with FCTC Art. 13 and the FCTC Art. 13 Guidelines with respect to paid placement of tobacco products. However, this would be made clearer by defining the term “tobacco advertising and promotion” in accordance with FCTC Art. 1(c).

Unpaid depiction of tobacco use or tobacco products in media that does not serve a legitimate purpose

Uncertain
The status of the regulation is uncertain due to lack of clarity in the law or inability to obtain all relevant laws.

Unpaid depiction of tobacco use or tobacco products in TV, film or other media that is not legitimate journalistic, artistic, or academic expression or legitimate social or political commentary

Analysis:

The law does not specifically address unpaid depiction of tobacco products. Unpaid depiction of tobacco products may be covered under the general prohibition on advertising and promotion. However, because “tobacco advertising and promotion” is not defined, it is difficult to determine if the ban on advertising and promotion applies to unpaid depiction.

To align with FCTC Art. 13 and the FCTC Art. 13 Guidelines, unpaid depiction of tobacco products should be prohibited under the broad ban on tobacco advertising and promotion, and the term “tobacco advertising and promotion” should be defined in accordance with FCTC Art. 1(c).

Tobacco industry sponsorship of events, activities, individuals, organizations or governments

Allowed
There is no ban and there are no restrictions whatsoever applicable.

Financial or other sponsorship or support by the tobacco industry to events, activities, individuals or groups (e.g., groups involved in sports, the arts, politics, charitable or welfare, or other activities, or youth smoking prevention programs)

Analysis:

The law does not have any provisions that explicitly regulate financial or other contributions that promote tobacco products or tobacco use, so such contributions appear to be allowed.

To align with FCTC Art. 13 and the FCTC Art. 13 Guidelines, the law should prohibit all contributions that have the aim, effect, or likely effect of promoting tobacco products or tobacco use directly or indirectly.

Publicity of financial or other sponsorship or support by the tobacco industry if tobacco sponsorship is not banned

Some Restrictions
There is not a complete ban on the listed form of tobacco advertising, promotion & sponsorship, but one or more limits on the form applies.
Analysis:

The law does not have any explicit provisions that restrict the publicity of tobacco sponsorship; however, the general prohibition on tobacco advertising and promotion should prohibit most forms of publicity of tobacco sponsorship. Because advertising and promotion are not defined, the full scope of the prohibition is unclear.

To align with FCTC Art. 13 and the FCTC Art. 13 Guidelines, the law should prohibit all tobacco sponsorship and publicity thereof.

Promotion by any means that are false, misleading or deceptive

Some Restrictions
There is not a complete ban on the listed form of tobacco advertising, promotion & sponsorship, but one or more limits on the form applies.

Promotion by any means that are false, misleading or deceptive or likely to create an erroneous impression about a product's characteristics, health effects, hazards or emissions (covering any term, descriptor, trademark, emblem, marketing image, logo, color and figurative, or any other indicia)

Analysis:

Article 1 of the 2007 Law (amending Art. 3 of the 1981 Law) prohibits the use of the terms “light,” “low tar,” and “very low tar” on tobacco product packaging. The law does not specifically prohibit the use of these terms in tobacco advertising, although it may be implied by the spirit of the law. However, the law does not prohibit the use of other misleading terms, descriptors, figures, or other indicia that create an erroneous impression about the health effects of a tobacco product, whether on the tobacco product package or in advertising.

By only mentioning specific terms, the law may imply that tobacco companies can use, for example, other terms, figures, colors, emblems, and other signs to accomplish the same misleading purpose or effect. For this reason, FCTC Art. 13 Guidelines para. 39 provides that Parties should prohibit not only the use of terms and descriptors, but also trademarks, emblems, marketing images, logos, colors, figuratives, and any other signs, in line with what is required regarding tobacco product packaging and labeling by FCTC Art. 11.1(a).

To align with FCTC Art. 13 and the FCTC Art. 13 Guidelines, the law should comprehensively ban all means of promoting a tobacco product that are false, misleading, or deceptive or that are likely to create an erroneous impression, as in Article 13 Guidelines para. 39. This should be done in addition to imposing a complete tobacco advertising, promotion and sponsorship ban.