The World Health Organisation has published a paper titled Exposing marketing tactics and strategies driving the global growth of nicotine pouches. As you can imagine, it’s the sort of all-out assault on meaning, truth, and even language that has become a hallmark of the WHO’s approach to nicotine.
Let’s take a look at this most poisoned of wells.
The paper
While I’d stop short of recommending you trawl through the 150-odd pages of the paper, it’s worth knowing what the WHO thinks about pouches. The paper walks us through what pouches are, but soon gets straight to the point, fretting about pouches' “addiction” potential and pairing that message with exaggerated claims about youth “targeting,” before calling for… more regulations, of course!
You can roughly break the paper into two core sections. We’ll explore both below.
Section 1
Section 1 covers the first six chapters. There is a lot of lanyard-class poetry about how pouches are “reshaping the global landscape of tobacco and related products,” which is strange phrasing for a product that contributes as little as less than 1% of annual sales.
These opening chapters function as a twisted frame for Section 2, by talking about pouches as a “new threat” and “urgent public health concern,” without providing justification for these positions, such as toxicology data. In fact, branding pouches as “non‑therapeutic oral nicotine products” is little more than word games if we think about the pharmacological difference between a pouch and an NRT lozenge.
There are lots of weak arguments, such as a section that questions pouches as being truly tobacco-free because they may contain some contaminants from manufacturing. The WHO treats this issue as if we’re talking about allergies in food rather than asking does this product expose you to the same order of magnitude of carcinogens and combustion products as smoking?
However, Section 2 is where the paper really goes off the rails.
Section 2
Section 2 is focused on pouch marketing. A lot of the WHO and subsequent downstream analysis of nicotine marketing comes from a place of paranoia and suspicion. That situation is largely a function of how this work is funded, which in this case comes from the Bill Gates Foundation.
However, the other interesting thing is that you rarely get a sense that the critics of pouch marketing have first-hand experience of running campaigns, a strong sense of the basic principles of marketing, or how economics work.
Here are five big problems with the marketing section.
#1. Youth appeal paranoia
The WHO sees any youth appeal of these products as the end of days. The logic is built on a utopian fantasy that assumes that the competition to pouches is tobacco or nicotine-free adolescents. Instead, the markets that pouches are slowly disrupting are cigarettes, illicit market tobacco, or vapes.
There is no relative harm data from different tobacco and related products provided. However, there is an almost begrudging admission that pouches are healthier than lethal cigarettes. More broadly, it just treats any youth awareness of pouches as a public health catastrophe and makes recommendations based solely on that alternative reality.
#2. “Playbooks”
The irony of the WHO’s obsession with “tobacco industry playbooks” is that it’s clearly part of a well-rehearsed set of strategies for criticising pouches and vapes. The paper casts pouch marketing motifs (lifestyle, discretion, convenience, etc.) as very sinister; in reality, they are pretty innocuous.
Indeed, the authors are far more concerned about the form of marketing rather than the truth of the claims, which really highlights the paucity of the overall argument. Let’s be honest about what the WHO are saying: The tobacco industry is not lying, but we just don’t like that they include concepts like “anytime, anywhere” in their marketing of pouches.
#3. Misleading claims about misleading claims
The document is very focused on the idea that pouch marketing is misleading. Many of its points describe ads as giving a “false perception of safety”, because pouches are branded as “tobacco-free.” Other complaints centre around the suggestion of pouches being clean, pure, modern, and so on.
Again, part of the marketing of pouches is going to be in the context of being an alternative smoking product. For the WHO, any positive framing of these products is seen as trickery, which begs the question: How can companies market them to smokers looking for a tobacco-free alternative to cigarettes?
In essence, the WHO wants companies to market pouches as highly addictive and with “unknown” health risks. You can tell these people would struggle in the private industry.
#4. Aesthetics
The big brand companies that produce pouches are self-regulating and pretty aware of the perception of their marketing. As such, there isn’t a whole lot for the WHO to criticise.
For example, aggressive discounting, loyalty schemes, or targeted ads to minors just isn’t something you see. The WHO and this paper are all the way down to worrying about silly April Fool’s Day posts, puns, and saturated colour palettes. In other words, bog standard Instagram marketing for under-40s.
#5. Unintended consequences
As mentioned above, the WHO’s solution to everything is more regulations. In this case, they recommend an advertisement, sponsorship, and flavour ban for pouches. They also believe any positive imagery around the product should be outlawed. That approach is reckless for several reasons.
- Excessively harsh restrictions for harm-reduction products help cigarettes by granting them a state‑sanctioned competitive moat.
- Banning fruit flavours hurts adults because it makes the safest way to consume nicotine less appealing. Helping adults transition away from smoking and providing a product that ensures they never start is vital for public health.
- Advertisement bans will affect legitimate pouch manufacturers, giving less compliant operators an edge.
- If public health frameworks outlaw any type of communication that is not totally apocalyptic, then the public won’t understand the relative risk of nicotine products.
It’s clear that treating nicotine pouches as if they are in the same ballpark as cigarettes serves to only misinform the public and harm legitimate industry. If anything, pouches are more like NRT, such as lozenges and gum, which curiously escape WHO outrage.
Final thoughts
The WHO paper ignores substitution and relative risks of nicotine products. They treat any youth use as the end of the world, rather than understanding how they might replace cigarettes among experimental youths, ensuring they never smoke at all.
The lack of understanding of marketing and the general conspiratorial tone of the paper is a disservice to the public they are meant to serve. Sadly, health professionals, the media, and legislators around the world will be influenced by this paper, which will poison discourse with bad arguments even further.
