Menthol Capsule Case

The Federal Office of Consumer Protection and Food Safety denied a tobacco company's request to sell a cigarette that contained a menthol capsule that releases a burst of flavor whenever the smoker crushes the capsule during smoking. The tobacco company appealed the government decision.  In this decision the court upheld the agency's denial. The court found that the flavor capsules violated the principle of the Framework Convention on Tobacco Control that the attractiveness of tobacco products should not be increased by novel products. The court found that the effect of the releasing the refreshing flavor on demand encourages the smoker to remain dependent. Additionally, occasional smokers or young smokers may become addicted to cigarettes with the flavor capsule where they would otherwise be discouraged by the harsh and unpleasant tobacco taste. The court found that cigarettes with flavor capsules are more hazardous than conventional cigarettes, and upheld the ban. 

File number 5 A 206/11

  • Germany
  • Sep 26, 2012
  • 5th Chamber of the Administrative Court
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Parties

Plaintiff

Defendant

Legislation Cited

International/Regional Instruments Cited

Related Documents

Type of Litigation

Tobacco Control Topics

Substantive Issues

Type of Tobacco Product

None

"Insofar as the Defendant cites the harmfulness of menthol in connection with the smoking of cigarettes, it does not however thereby give evidence of the compelling reasons of health protection. The fact that the additive menthol has a cooling, pain-relieving and slightly numbing effect, which makes the inhalation of the severe and irritating tobacco smoke easier and according to American studies, an increased potential for addictiveness (see Kahnert et al., Effects of Menthol as an Additive in Tobacco Products and the Need for Regulation, Federal Health Bulletin (Bundesgesundheitsblatt) 2012, 409-415), is not sufficient to prohibit the marketing of a new cigarette with a menthol capsule, because these effects also arise when smoking the "traditional" menthol cigarettes that are allowed on the German market."
"In the interpretation of the "compelling reasons of health protection" criterion, for tobacco products it must be considered that in contrast to food there is the fact that the smoking of each cigarette with or without a menthol additive is damaging to health and addictive. The free movement of goods for tobacco products has therefore also been qualified from the outset. That is roughly what is said in the recitals 4 for the Directive 2001/37/EG of 06/05/2001 for the alignment of the legal and administrative regulations of the member states regarding the manufacture, packaging and sale of tobacco products (- L194, 26 -), that in light of the particularly harmful effects of tobacco, in this context, priority should be given to health protection and all new findings supported by scientific results must be considered. According to these principles, in the present case there are compelling reasons of health protection considering the Defendant's degree of discretion. For this, the Defendant does not have to prove that the consumption of the Plaintiff product itself is more harmful than traditional menthol cigarettes permitted on the German market due to certain substances in the smoke. Rather, it is sufficient that there is information on this type of cigarette which shows significantly greater harmfulness and or risk of addiction compared to traditional cigarettes."