LANGUAGE
Last updated: December 27th 2019

Health Warnings/Messages Features

Type of product: Smoked Tobacco Product
Type of Warnings / Messages Required
Pictures (Photos), Text Warnings/Messages
Location and Size of Warnings / Messages on Unit Packaging
50% of front, 50% of back
Rotation Required
Required
Number of Warnings / Messages Authorized to Be Displayed at Any Given Time
4
Length of Rotation Period
Specified - 1 year
Analysis

The law requires a photo or color image to cover at least 50% of the front surface of the packaging unit, as well as a text-only warning covering at least 50% of the lower rear surface of the packaging unit. Interministerial Order No. 13.674/2017 contains seven health warnings. The warnings are broken into two rounds of four warnings each (one of the warnings is repeated in both rounds), with the warnings within a round to be used simultaneously for a period of one year.

On cartons, the law requires the text portion of the health warnings to cover at least 50% of the main surface of the carton.

The law meets FCTC Art. 11 with respect to size and rotation of warnings on unit packaging and labeling. However, the law could more closely align with the FCTC Art. 11 Guidelines if it required pictorial warnings to be displayed on both principal display areas rather than just one principal display area, as suggested in para. 14 of the Guidelines. In addition, the law would be clearer if it contained a definition of “outside packaging and labeling” in accordance with the definition provided in FCTC Art. 11, and required pictorial health warnings on each main surface of all outside packaging and labeling.

Type of product: Smokeless Tobacco Products
Type of Warnings / Messages Required
Pictures (Photos), Text Warnings/Messages
Location and Size of Warnings / Messages on Unit Packaging
50% of front, 50% of back
Rotation Required
Required
Number of Warnings / Messages Authorized to Be Displayed at Any Given Time
4
Length of Rotation Period
Specified - 1 year
Analysis

On packages of snuff, the law requires a photo or color image to cover at least 50% of the front surface of the packaging unit, as well as a text warning covering at least 50% of the lower rear surface of the packaging unit. Interministerial Order No. 13.674/2017 contains seven health warnings for packages of snuff. The warnings are broken into two rounds of four warnings each (one of the warnings is repeated in both rounds), with the warnings within a round to be used simultaneously for a period of one year. On cartons of snuff, the law requires the text portion of the health warning to cover at least 50% of the main surface of the carton.

On packages of chewing tobacco, the law requires a text-only health warning to cover 50% of the rear surface. Interministerial Order No. 13.674/2017 contains two health warnings for packages of chewing tobacco. The warnings are broken into two rounds of two warnings each, with the warnings within a round to be used simultaneously for a period of one year. On cartons of chewing tobacco, the law requires one of the text-only health warnings to cover at least 50% of the main surface of the carton.

The law meets FCTC Art. 11 with respect to size and rotation of warnings on unit packaging and labeling. However, the law could more closely align with the FCTC Art. 11 Guidelines if it required pictorial warnings to be displayed on both principal display areas rather than just one principal display area, as suggested in para. 14 of the Guidelines. This should apply to all types of smokeless tobacco. In addition, the law would be clearer if it contained a definition of “outside packaging and labeling” in accordance with the definition provided in FCTC Art. 11, and required pictorial health warnings on each main surface of all outside packaging and labeling.