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Package Warnings Worldwide
Package Warnings: Important Progress Being Made Worldwide
Rob Cunningham
Canadian Cancer Society
February 5, 2004

Tremendous progress is being made worldwide by governments to improve package warnings. The size of warnings is getting bigger. A growing number of countries require or will soon require picture-based warnings. And as countries implement the FCTC, revolutionary improvements to package warnings will continue around the world.

Pictures:
Four countries have finalized laws requiring picture-based warnings: Canada, Brazil, Singapore and Thailand. The Canadian warnings appeared on packages in 2001, Brazilian warnings appeared on packages in 2002. The Singapore warnings are required as of August 1, 2004, and the Thai warnings as of approximately February, 2005.
On February 2, 2004, Australia announced its decision to require picture-based warnings and released a series of 14 draft messages. There is a consultation period until March 19, 2004. The Australian Government has said that the regulations will be finalized by June 2004, and the new warnings will appear on packages starting June 2005.
To see the Canadian warnings, visit:
http://www.hc-sc.gc.ca/hecs-sesc/tobacco/legislation/warnings/warnings.html
To see scanned versions of the Canadian warnings on actual packages, see:
http://www.nsra-adnf.ca/news_info.php?cPath=22&news_id=78
To see the Brazilian warnings, visit:
http://www.anvisa.gov.br/divulga/noticias/040601_1.htm
To see the proposed next round of Brazilian warnings, visit:
http://www.anvisa.gov.br/divulga/noticias/2003/241003.htm
To see Thailand's warnings, visit:
http://www.thpinhf.org/packaging_labeling.htm
To see the proposed Australian warnings, visit:
http://www.treasury.gov.au/contentitem.asp?pageId=&ContentID=790
To see the Australian Government news release of Feb. 2, 2004, visit:
http://www.health.gov.au/mediarel/yr2004/tw/wor003.htm
Pursuant to a European Community Directive, member countries have the option as of September 30, 2004 to require picture-based warnings on packages. Warnings are currently text-only. The European Commission is in the process of completing a library of picture warnings from which member countries can choose for required use in their country after September 30, 2004.
The countries in the European Community are Austria, Belgium, Denmark, Finland, France, Germany, Greece, Ireland, Italy, Luxembourg, Netherlands, Portugal, Spain, Sweden, United Kingdom. Ten countries will join the EC on May 1, 2004: Cyprus, Czech Republic, Estonia, Hungary, Latvia, Lithuania, Malta, Poland, Slovakia, Slovenia. These countries will be required to comply with the EC labeling directive. Bulgaria and Romania have been approved for EC membership and hope to be members by 2007.
The three countries in the European Free Trade Association (Iceland, Norway and Liechenstein) harmonize their package warnings requirements with the EC. These countries might also choose to require pictures once the European Commission completes its library later this year.
The Governments of New Zealand, Malaysia, Taiwan, South Africa, India and Jamaica have all said publicly that picture-based warnings are under consideration. Brazil has released draft warnings for its next round of picture-based messages.

Size:
Canada, Singapore and Thailand require that warnings cover at least 50% of the front and back of the pack. In addition to the exterior messages, Canada requires one of 16 rotated messages to appear inside the package, either on an insert or on the slide.
Brazil requires that warnings cover 100% of either the front or the back of the package; in practice this means that a side without a warning is typically displayed to consumers in stores.
Australia has proposed two options: (1) 50% of the front and 50% of the back; or (2) 30% of the front and 90% of the back.
In the European Community, in unilingual countries, warnings are required on at least 30% of the front and 40% of the back. However, when a black border required to surround the warnings is counted, the percentage works out to about 43% of the front and 53% of the back (an average of 48% of the front and back).
In bilingual EC countries such as Finland (Finnish, Swedish) and Malta (Maltese, English), the warnings must be at least 32% of the front and 45% of the back, which including the border works out to about 45% of the front and 58% of the back (an average of 52% of the front and back).
In Belgium, a trilingual country (German, French, Flemish), warnings must cover 35% of the front and 50% of the back, which including the border works out to about 48% of the front and 63% of the back (an average of 56% of the front and back).
Thus, as an average of the front and back, Belgium currently requires the largest space for package warnings in the world at 56%, followed by Finland at 52%, followed by Canada, Brazil, Singapore and Thailand at 50%. It is only a matter of time before countries surpass Belgium's size requirements.
Some EC countries dispute or misunderstood the European Commission's legal opinion that the black border must be in addition to the space reserved for the warnings. A number of countries such as Germany have minimum requirements that result in the total size for the warnings, including the border, to be 30% of the front and 40% of the back of the package.
In 2003, Switzerland published draft regulations based on the EC labeling directive. Although Switzerland is neither part of the EC nor an EFTA country, it often harmonizes its laws with the EC. Switzerland is proposing to require trilingual warnings on packages (French, German, Italian) consistent with the EC Directive.

FCTC Requirements:
The FCTC states that messages should cover at least 50% of the principal display areas of the package (i.e. both the front and back), but at a minimum must cover at least 30% of the principal display areas (i.e. front and back). The use of pictures and pictograms is optional. The FCTC requires that there be a series of rotated messages. As part of the rotation, non-health messages may be included (e.g. "Quit smoking - Save money").
Even in Japan, the Japanese Government has said that it will require warnings to cover at least 30% of the front and back. The eventual warnings will be a significant improvement over the current message which states: "Please remember to follow good smoking manners. As smoking might injure your health, please be careful not to overdo it."
Egypt now requires a text-only warning that covers the bottom third of the front of the pack (based on a sample package). Although this in itself is clear progress for Egypt and most developing countries, this is still not compliant with FCTC requirements for at least 30% of both the front and back.
To underline the recent progress that has been made, it is believed that in October 2000 when the FCTC negotiations began, only Canada, Thailand and Singapore met the eventual FCTC standard of a minimum 30% of the front and back. (This would have to be confirmed.) And only Canada met the preferred FCTC standard of a minimum 50% of the front and back. Only Canada required pictures (the Canadian regulations were finalized in June 2000 and were followed by an implementation period).
What Countries Should Do
Countries should implement the largest package warnings that are politically achievable. The larger the warnings, the better. Countries can and should require that at least 80% of the front and back be reserved for package messages. The front of the pack is more important than the back. Picture-based warnings should be included as part of a rotated series. A picture says a thousand words. Rotated messages should be updated regularly to keep them fresh.
Evidence of Effectiveness
There is persuasive and ever-growing evidence that picture-based warnings are more effective than text-only warnings, and that the effectiveness of warnings increases with size. Here are some examples of studies or reports respecting package warnings.
Environics Research Group Ltd., "Evaluation of New Warnings on Cigarette Packages" Prepared for Canadian Cancer Society, 2001. Visit:
http://www.cancer.ca/ccs/internet/standard/0,3182,3172_334419_436437_langIden,00.html
Studies prepared for the Canadian Department of Health. Visit:
http://www.hc-sc.gc.ca/hecs-sesc/tobacco/research/archive/index.html
Canadian Cancer Society, "Controlling the Tobacco Epidemic: Selected Evidence in Support of Banning All Tobacco Advertising and Promotion, and Requiring Large, Picture-Based Health Warnings on Tobacco Packages" (Ottawa: Canadian Cancer Society, International Union Against Cancer, 2001). Visit:
http://www.globalink.org/tobacco/docs/packaging/
Hammond, D., Fong, G.T., McDonald, P.W., Cameron, R, Brown, K.S. "Impact of the graphic Canadian warning labels on adult smoking behaviour." Tobacco Control 2003;12(4):391-395.
2003/641/EC: Commission Decision of 5 September 2003 on the use of colour photographs or other illustrations as health warnings on tobacco packages. Visit:
http://europa.eu.int/comm/health/horiz_legal.htm#4
The Cost-Benefit Analysis accompanying the proposed Australian warnings:
http://www.treasury.gov.au/contentitem.asp?pageId=&ContentID=790

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