Last updated: September 17, 2019

Other Packaging and Labeling Requirements

Warning requirements on unit packaging and labeling (e.g., packs)

Yes
Analysis

Law No. 174, in conjunction with Decree No. 8991, requires health warnings on all tobacco product packages. "Packaging" is defined as any pack or packet in which tobacco products are sold, and therefore warnings will be required on all unit packaging.

The law meets FCTC Art. 11 in this respect.

Warning/messages required on outside packaging and labeling (e.g., cartons)

Yes
Analysis

Law No. 174, in conjunction with Decree No. 8991, requires health warnings on all tobacco product packages. "Packaging" is defined as any pack or packet in which tobacco products are sold, and therefore warnings will be required on outside packaging.

The law meets FCTC Art. 11 in this respect.

Warning texts must be in the principal language(s) of the country

Yes
Analysis

Law No. 174 requires tobacco product packaging to carry health warnings in Arabic.

The law meets FCTC Art. 11 with respect to warnings in the principal language of the country.

A requirement that warnings or messages may not be placed where they may be permanently damaged or concealed when opening the pack

No
Analysis Law No. 174 provides that it is prohibited to hide the health warning in any way. Under Decree No. 8991, it is prohibited to remove, erase, or hide the warnings by any means. However, neither the law nor the decree affirmatively requires that health warnings may not be placed where they may be permanently damaged upon opening the pack.

To align with FCTC Art. 11 and the FCTC Art. 11 Guidelines, the law should affirmatively state that health warnings may not be placed where they may be permanently damaged or concealed upon opening the pack.

A requirement that tax stamps or other required markings may not be placed where they may conceal warnings or messages

Yes
Analysis Law No. 174 expressly states that the health warning may not be hidden in any way, and Decree No. 8991 affirmative prohibits printing the warnings on tax or financial stamps existing on the product packaging. Together, these provisions are interpreted as prohibiting the health warning from being concealed by tax stamps and other markings.

The law aligns with FCTC Art. 11 and the FCTC Art. 11 Guidelines in this respect.

A requirement to display qualitative (descriptive) constituents and emissions messages

No
Analysis

The law does not require qualitative (descriptive) constituent and emissions messages.

To align with FCTC Art. 11 and the FCTC Art. 11 Guidelines, the law should require that qualitative statements be displayed on each unit packet or package about the emissions of the tobacco product.

Prohibition on the display of figures for emission yields (including tar, nicotine, and carbon monoxide)

No
Analysis

The law does not specifically prohibit or require the display of figures for emission yields.

To align with FCTC Art. 11 and the FCTC Art. 11 Guidelines, the law should prohibit the display of figures for emission yields as these figures can be misleading to consumers.

Plain or standardized packaging

No
Analysis

Plain packaging of tobacco products is not required in Lebanon. The FCTC Art. 11 Guidelines provide that Parties should consider adopting plain packaging measures that restrict or prohibit the use of logos, colors, brand images, or other promotional information on packaging other than brand and product names displayed in a standard color and font style. Plain packaging aims to reduce the appeal of tobacco products, to increase the noticeability of health warnings, and to reduce the ability of the packaging of tobacco products to mislead consumers about the harmful effects of smoking.

Prohibition on misleading tobacco packaging & labeling including terms, descriptors, trademarks, figurative or other signs (logos, colors, images that directly create a false impression that a tobacco product is less harmful than other tobacco products)

Yes
Analysis

Law No. 174 prohibits on tobacco product packaging “any misleading element about [the] characteristics, effects, risk factors, emissions, including any expression, description or symbol implying that one tobacco product is less dangerous than another, such as ‘light’, ‘ultra light’, ‘mild’, or any other term in Arabic or any other language.”

The law meets FCTC Art. 11 in this respect.