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WHO’s FCTC is still set on its mission to stop people from being able to choose to smoke cigarettes. This now seems to extend to reduced risk products as well. Photo credit: Lindsay Fox, CC2.0.
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WHO has now broadened the FCTC treaty to cover nicotine and products that aren’t even combustible. Photo credit: Mmmaaarrrttt, CC4.0.
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Highlights among the 16 proposed “forward-looking measures” for COP11 include generational smoking bans, a phase-out of tobacco sales within jurisdictions, bans on all flavoring agents and additives, a ban on cigarette filters, and an end to government support for tobacco farming. Photo credit: Pixabay.
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The provisional agenda offers little hope that COP11 will recognize that reduced-risk products such as vapes could benefit public health. Photo credit: SmileSmith25, CC4.0.
At COP11, WHO is expected to officially broaden FCTC to non-combustible nicotine products.
During November 17-22, Geneva will host the 11th Conference of the Parties (COP11) to the World Health Organization’s (WHO) Framework Convention on Tobacco Control (FCTC). The event, marking the global treaty’s 20th anniversary, should be a celebration of progress in the fight against tobacco use and tobacco-related diseases. Yet there is little to celebrate: in the 20 years since FCTC entered into force, the global number of smokers has declined by only about 100 million, while some 1.2 billion people still smoke.
Given WHO’s fierce anti–tobacco harm reduction stance and its commitment to a dangerous status quo, there is no indication that this will change soon. In many respects, COP11 will resemble its predecessors: the event is expected to be opaque and secretive, excluding media, public observers, consumer advocacy groups—and, of course, industry representatives—from plenaries and side events. (Parties with state-owned tobacco companies will still be allowed at the table, though.) Only a few general sessions, such as the opening plenary and the announcement of the next COP’s date and venue, will be webcast.
On June 17, WHO released the provisional agenda for COP11, drawn up by the Convention Secretariat to guide discussions. It offers little hope that WHO will finally endorse tobacco harm reduction (THR)—quite the opposite. Two agenda items stand out: under “Treaty instruments and technical matters,” item 4.1 covers “forward-looking tobacco control measures” (in relation to Article 2.1 of the FCTC), based on a report by the Expert Group; item 4.5 addresses the implementation of measures to prevent and reduce tobacco consumption, nicotine addiction, and exposure to tobacco smoke, and to protect such measures from “commercial and other vested interests of the tobacco industry in light of the tobacco industry’s narrative on ‘harm reduction’” (Articles 5.2(b) and 5.3 of FCTC).
For the upcoming COP, it seems, the Secretariat has found a particularly clever way to tweak and combine FCTC articles to eliminate the subject of THR once and for all. Harm reduction is an evidence-based public health strategy—in fields such as drug use or HIV prevention—and even appears as one of the three strategic pillars of tobacco control in the FCTC preamble (Article 1(d)). Article 5.2(b) calls for parties to adopt effective measures and cooperate with others to prevent and reduce tobacco consumption, nicotine addiction, and exposure to tobacco smoke, while Article 5.3 seeks to protect tobacco control policies from “commercial and other vested interests of the tobacco industry.”
Conflating three issues together
“Introducing tobacco harm reduction through the lens of Article 5.2, and placing the term in scare quotes, implies that the approach is an invention of the tobacco industry,” GSTHR.org wrote in a September briefing paper. “It is only presented as a threat, allowing no recognition that safer nicotine products could offer many benefits to public health.”
“What they’re doing with this is basically elevating tackling nicotine addiction above the harms of tobacco smoke and combustible use,” says Martin Cullip, international fellow at the Taxpayers Protection Alliance’s Consumer Center. “They claim harm reduction is merely an industry construct, not a legitimate public health strategy—which is odd, given that harm reduction is widely accepted in nearly every other health domain. But they’re intent on ignoring it. Their goal seems clear: to push delegations to obstruct access to safer nicotine products at every turn.”
“As I reviewed and downloaded all the available papers ahead of COP11, I found myself reflecting on how far we’ve come,” says Jeannie Cameron, managing director of JCIC International, who attended all Intergovernmental Negotiating Bodies and most COP meetings until she was excluded. “Having been involved since COP1 and even earlier, during the FCTC negotiations in 2000, this particular COP feels like a turning point—a moment where the focus shifts toward what I’d call the final battle in global tobacco control. The early COPs in 2006 and 2007 made real progress: we developed guidelines and built a framework for action. But over the past decade, COPs have felt stagnant—lots of discussion, but few concrete outcomes. COP11, though it hasn’t happened yet, feels different. To me, it’s poised to be a breakthrough—a COP where meaningful decisions are finally made.”
She adds that while nicotine was barely mentioned in the early days of FCTC—and appears only 3 times in the agreement—WHO has now broadened the treaty to cover nicotine and products that aren’t even combustible. “It’s almost like it’s accepted now,” she notes.
Playbook of endgame strategies
The expert group report on forward-looking measures under agenda item 4.1 confirms Cameron’s and Cullip’s views. It was established after COP10, held in Panama in February 2024, with its members selected by the Convention Secretariat—“cherry-picked,” as Cullip points out. “The expert group includes just about every prohibitionist in the world, but no one who believes harm reduction could be useful.”
Consequently, their report appears to be a sweeping catalogue of “endgame” strategies, some raising questions about evidence, feasibility, legality, and unintended consequences. Highlights among the 16 proposed “forward-looking measures” include generational smoking bans, a phase-out of tobacco sales within jurisdictions, bans on all flavoring agents and additives, a ban on cigarette filters, and an end to government support for tobacco farming. Notably, the cited “evidence of impact” for many measures is based largely on modeling studies.
“It’s very clear where they’re going and no longer a hint,” Cameron comments. “What’s deeply concerning in these documents is the push to ban cigarette filters—a move that, frankly, isn’t grounded in health science. It’s astonishing that an organization like WHO, dedicated to public health, would advocate for removing filters. If such a policy goes forward, it risks taking us back to an era where unfiltered cigarettes—the most harmful form—are effectively promoted. It’s hard to believe.”
She hopes that countries will see how damaging such a measure would be for public health outcomes. “It’s a very extreme step,” she says. “Most of the measures proposed in the report have always been in FCTC, but not to this extreme.”
“Originally, the treaty made it clear: nothing in FCTC prevents governments from going further,” Cullip notes. “Article 2.1 explicitly says the treaty doesn’t limit parties from adopting additional measures—like generational bans or filter restrictions—if they choose to. But now, with the proposed decision at COP11, they’re reinterpreting Article 2.1 to imply that parties are expected to adopt a whole set of measures that aren’t actually part of the treaty. It’s a subtle shift—turning optional actions into perceived obligations. If this decision is noted, it gives them leverage to say, ‘COP11 endorsed this, so you should comply,’ and opens the door to naming and shaming countries that don’t implement policies like generational bans or third-hand smoke prevention. It turns a freedom clause into an obligation.”
He adds that parties have been effectively sidelined from the process. “The Convention Secretariat has almost handed everything over to a bunch of NGOs, such as the Global Alliance for Tobacco Control. These NGOs are doing all the work. There’s no work for the parties between COPs anymore because the Secretariat just installs expert groups. By contrast, there are no longer working groups where parties have a say.”
At COP10, he recalls, St. Kitts and Nevis proposed creating a working group on harm reduction. “The Secretariat didn’t discuss it at all—they simply ignored it. Instead, they held four other discussions and ended up proposing an expert group. But parties have already made it clear: they don’t want an expert group on harm reduction; they want a working group.”
Coordinated efforts required
Both Cullip and Cameron are confident that several parties will find FCTC’s stance unacceptable and share their own countries’ experience with THR. At COP10, New Zealand, El Salvador, and the Philippines spoke in favor of harm reduction, while the UK did not—a silence observers viewed as a missed opportunity to counterbalance the dominant anti-THR narrative.
“We think WHO is going down the wrong path,” Cullip says. “So I hope more people will mention it in their statements. It would be interesting to see, because I heard that between 30 and 40 countries objected to some of the things WHO did at the last COP. I’m hoping parties will stand up and say, ‘No, that’s not how the treaty is supposed to work. We’re meant to be the decision-makers here. You should be choosing proper science.’”
Cullip will co-organize the TPA’s second “Good COP (Conference of the People)” counter-conference in Geneva, concurrent with COP11. Thirty-eight experts from 22 countries—including scientists, consumers, policymakers, and doctors—will share their views in panels and sessions.
“As we saw at COP10, a lot of governments made positive statements on tobacco harm reduction, but we don’t know what will happen at COP11,” Cameron says. “My personal view is that more countries will do so. I think many have seen the benefits of allowing harm reduction messaging and products.”
She adds: “Part of the reason we’re in this situation is because no one ever truly stopped it. If industry, consumers, and advocates had united—grounded in science and evidence—they could have pushed back against what WHO is doing. But that never happened. Each company went its own way—PMI doing one thing, BAT another, consumer groups doing theirs. There’s never been a coordinated global campaign. And that’s exactly what tobacco control has exploited: a fragmented message that should be unified but isn’t. This moment was foreseeable—it’s been building for years. Everyone’s doing great work, generating evidence, but it’s not organized. Meanwhile, WHO has run a consistent, strategic campaign. The moment one COP ends, they’re already planning the next. On the outside, we wait until something hits the calendar—then scramble to get our ducks in a row.”