Big Question 8 - What is the Role of Flavours in Smokeless Products and THR?

Flavours Must Be Adult Orientated

Flavours that have no relevance to adult smokers do not belong in Smokeless Products, especially flavours that predominantly appeal to underage individuals. The flavours used by adult Vapour Product consumers in the UK in 2025 were assessed by Action on Smoking and Health (ASH) which found that approximately 80% of adults use Fruit, Mint / Menthol, and Tobacco flavours^[2]. That is why we propose limiting flavours to adult-orientated flavours and support an outright ban on Smokeless Product flavours such as confectionery, candy-like, desserts or soft drink brands.

This approach recognises the role of flavours as an important driver of adoption for adult smokers seeking alternatives, while ensuring the removal of specific flavours that appeal predominantly to anyone underage.

Toxicological Assessment of Our Flavours

Our product stewardship process includes a scientific assessment of flavours. We assess our flavours in both consumables (Heated Product consumables, Vapour e-liquids, and Oral Nicotine Pouches) and product aerosols (from Heated Products and Vapour Products) to understand the impact of the aerosolisation process on flavour ingredients.

Scientific Evidence Underscores the Importance of Flavours to Adult Smokers Making the Switch to Smokeless Products

Vapour Products, which entered the market in Europe in 2006 and the U.S. in 2007, are available with a wide array of e-liquid flavours.

A review of U.S. flavour use conducted by Mok et al. ranked flavour categories in the following order for transitioning away from smoking: ‘mint/menthol’, ‘other flavours’ (e.g. fruit), and ‘unflavoured/tobacco’ flavours. These findings suggest that Vapour Product flavours may play a role in supporting adult smokers to transition away from smoking^[5].

Flavours Must Have Adult-Orientated Flavour Descriptors

Descriptors for flavours should describe the particular flavour that is in the product in a factual style.

Flavours Must Have Adult-Orientated Packaging

Packaging that looks like sweets or toys doesn’t belong on tobacco or nicotine products. That’s why our packaging is adult-orientated and simplistic in its design, so that it does not appeal to the underaged.

Retail Enforcement is Required to Prevent Underage Access

We support restrictions on where and how tobacco and nicotine products are sold, similar to those used to regulate the sale of alcohol. In the UK, for example, this could require retailers selling Vapour Products to hold a retail licence, which would be revoked if they were found to be selling to underage individuals. Retailers could also be required to demonstrate to Trading Standards that they comply with Challenge 25 protocols or use age-verification technologies at the point of sale, such as facial recognition systems.

Unlocking Flavours Through Technology

In May 2026, the U.S. Food and Drug Administration (FDA) authorised, for the first time, a flavoured (non-menthol, non-tobacco) vapour product. As part of its review, the FDA concluded that the included device Underage Access Prevention (UAP) technologies, combined with FDA required marketing restrictions, was expected to mitigate the risk of underage use.

The FDA further noted that such innovation may play an important role in protecting young people from nicotine exposure, while enabling adult smokers to access a wider range of flavoured products that may support complete switching away from combustible cigarettes^[7].

Recommendations

We recognise that flavours in tobacco and nicotine products have been a topic of public discussion for many decades. This attention is exacerbated by the growing popularity of Vapour Products, specifically in terms of the wide variety of e-liquid flavours available. We believe that it is essential for regulation to strike a clear balance between providing options to suit adult preferences, and ensuring we have responsible marketing practices and technologies to safeguard against underage use.

Flavours play a critical role in ensuring adult consumers have a suitable alternative to more harmful tobacco products, such as combustible cigarettes.

Adult-orientated flavours can be instrumental in harm reduction strategies by further encouraging adult smokers who would otherwise continue to smoke to switch to alternatives. Partnered with a successful UAP technology and campaign, as well as regulatory oversight, flavours should be recognised as a means to encourage adult tobacco consumers to move down the risk continuum and be considered as part of a holistic Tobacco Harm Reduction approach.