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FEDERAL TRADE COMMISSION WASHINGTON. D. C. 20580 SUREAU OF `'iONSUMER TROTECCIQN Ernest Pepples ' General Counsel Brown & Williamson Tobacco Corporation 1600•West Hill Street P.O. Box 35090 Louisville, Kentucky 40232 Dear Mr. Pepples: June 11, 1981 The R.J. Reynolds Tobacco•Company has requested that the Federal Trade Com-rissiori modify its cigarette testing methodology by substituting the Cambridge Filter Holder Mk II ("Filtrona Holder") for the holder currently being used in the Commission's staff cigarette testing laboratory. R.J. Reynolds informs the Commission that the Cambridge Filter Holder MK II "Filtrona Holder") is manufactured by Cigarette Components, Ltd. of London and is sold in the United States by the American Filtrona Corporat.ion. The Commission•-and the.Con+mission staff have not yet eva)uated or made any determination about the merits of the R.:. Reynolds request. The purpose of this letter is to begin a dialogue between the Commission staff and the members of the cigarette manufacturing industry on the merits of the R.J. Reynolds' proposal and to provide all members of the industry with an opportunity to comment informally on the proposal at the uarliest possible stage. This procedure has been discussed with and agreed to by the General Counsel of R.J. Reynolds. R.J. Reynold.; in its request states that it believes that the use of the MK II "Filtrona holder" "will provide more accurate 'tar' and nicotine measurements for all cigarette brands" than the holder currently being used. The R.J. Reynolds request also states, "In particular, as we believe we have fully demonstrated to you, the Filtrona'holder would achieve measurements for Barclay cigarettes that are more'reliable than can be obtained on the FTC testing apparatus." ~ ~ . UZ Ifl ., ~

As explained by•a representative from R.J. Reynolds, the ~ most significant difference between the cigarette holder currently being used by the F.T.C. and the Filtrona holder proposed by them is that.the Filtrona holder applies more pressure on the inserted cigarette. in support of their position R.J.. Reynolds has provided the Commission staff with 18 ~ pages of confidential materials. Copies of these materials are attached to this letter for your review, but must be held by our -organization in confidence as the R.J. Reynolds Tobacco Company has waived their confidential status only for the purpose of permitting you to comment on their proposal. r Briefly, it is the position of the R.J. Reynolds Tobacco Company that when Barclay cigarettes are smoked, the 4 grooves which run horizontally along the filter collapse, thereby, decreasing the amount of air dilution and increasing the "tar" delivery. Accordingly, it is the R.J. Reynolds Tobacco Company's position that'•Barclay cigarettes are more comparable ~ to a 4 to 5 mg. "tar" cigarette than a 1 mg. "tar" cigarette. The first 7 pages of the Reynolds' submission involves tests of 5 cigarettes with a panel of smokers to compare the smokers' preceptions of these cigarettes in 10 different . categories. Page 8 of these materials compares "tar" and ; nicotine machine tests on 12 different cigarettes with the zurrently used holder and with the proposed holder. Page 9 of these materials compares 3 different cigarettes with Barclay when the Barclay filter is substituted for the filter normally used•on the cigarette in tests conducted with the current F.T.C.'holder and with the proposed Filtrona holder. Pages 10 ~ through 12 involve tests of Now 85 cigarettes with Now 85 cigarettes using the Barclay filter with a panel of smokers to compare their relative perceptions. Pages 13 through 15 involve tests of Barclay 85 cigarettes with Barclay cigarettes using the Now filter with a panel of smokers to compthre their relative preceptions. Pages 15 through 18 compare test results of the impact of increasing the pressure on the filter on Now 84's and Barclay 85's on "tar" and C.O. delivery. In conclusion, the R.J. Reynolds Tobacco Company suggests that only Barclay cigarettes would be affected by the switch to the Filtrona filter, that this filter•provides a more accurate measurement of the "tar" and nicotine delivery of Barclay cigarettes and that the use of the Filtrona filter would not decrease the accuracy of the measurements now being obtained on all other cigarette brands. i Y

I ) Before the staff prepares a recommendation to the Commission on the R.J. Reynolds proposal, it would like to solicit your comments on this proposal and any supporting information or empirical data which you believe should be considered. Your comments should be submitted within 21 days. After reviewing your comments, the staff will prepare a recommendation for the Commission to consider. If the proposal requires further consideration, it may be published in the Federal Register to solicit formal comment.on the proposal from any interested party. If you have any questions, feel free to contact me on this matter. Very truly yours, ) Matthew L. Myers Attorney ! ) ) ) Division of Advprtising Practices .N . ~ • N . P+ . t~. ~ .~ ~ ~ r N

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