The picture and warning must be placed on the front (top) of the pack in Urdu and on the back (top) of the pack in English. The warning must comprise 60% of the pack. (The increases in size announced in SRO 127(E)/2017 (to 50% and, subsequently, 60%) replace the 2015 notification (SRO 22(KE)/2015) that would have increased the size to 85% of packaging. This notification, however, was delayed several times and, ultimately, never implemented.)

The font of the text must be at least 2 mm, and black on white background.

According to the regulations, the warnings "shall be rotated generally every year or as may be directed by the Federal Government from time to time.” As the Ministry issued only one warning/picture in the SRO, future action by the government is needed for rotation to occur.

To more fully align with FCTC Art. 11 and the FCTC Art. 11 Guidelines, the SRO should authorize a set of messages, not just one message, on the health hazards and social and economic impacts of smoking and should require the Ministry to update the set of warnings with specified frequency, at least as frequent as every 36 months.

The 1979 Ordinance prohibits the manufacture and sale of “cigarettes” without the required health warning. SRO 127(KE)/2017, likewise, refers to “cigarette” packets only. The definition of cigarette includes bidis.

To meet FCTC Art. 11 and align with the FCTC Art. 11 Guidelines, the Ordinance and SRO should mandate health warnings on all tobacco products, not just smokeable tobacco products.