Abstract
Overviews the cigarette industry's role in manipulating nicotine and tar content in cigarettes through the years. Traces nicotine research since the 1960's and says by the early 1980's, the industry understood that "smokers required a minimal level of nicotine within a cigarette." States industry research has shown both positive and negative effects of smoking and states "cigarettes are a nicotine delivery system." Describes the challenges of controlling nicotine levels by modifying blends or cigarette design and indicates nicotine delivery and smoker satisfaction go hand-in-hand. States industry-wide nicotine research is related to nicotine delivery and and product design. Says cigarette filters were changed to increase nicotine delivery, while various blends had specific filters that attained a predetermined nicotine/tar ratio. States the cigarette industry fully understands selective filtration. Describes the fabrication, economy and uses of reconstituted tobacco and says if the final reconstituted sheet fails to meet specifications, it can be recycled. Overviews the difficulties of optimizing the nicotine to tar ratio to provide smoker satisfaction, cautions current tobacco industry research is being hindered by the fear of lawsuits and states: "The argument is that any company should not create or be exposed to information that may come back to haunt them in civil litigation".
Fields
- Rank
- 1
- Author
- Farone, William Anthony, Ph.D. (PM Former Dir. of Applied Research, Anti-Tobacco Expert)
Hired to make safer products and to find business alternatives outside the tobacco industry for PM.
- Hypothesis
- Behavior Targeting
Cigarette's effect of enhancing/mitigating specific behaviors
- Design changes over time
Changes in cigarette design over the past half century.
- Health effects
Design changes which have measurably altered health effects of cigarette smoke, both for smokers and nonsmokers.
- Introduction of new/unconventional products
Research and development of novel nicotine delivery devices and experimental tobacco designs.
- Low-yield cigarettes
Modification of low yield products to assure that adequate levels of nicotine delivery are maintained, and effects of yield changes on toxicity and dependence.
- Mainstream constituent yields
Modification of selected mainstream smoke constituents in response to health concerns.
- Measuring human smoking behavior
Measuring the effects of changes in human smoking behavior on intake of nicotine and smoke constituents.
- Nicotine transport, transfer, and uptake
Design changes which alter nicotine delivery or effect how the product causes and maintains dependence, including transfer of nicotine from tobacco to smoke, and uptake into the body.
- Smoke constituent testing
Development of methods for measurement of gas and particulate yields in mainstream and sidestream smoke.
- Smoking psychology and behavior
- Toxicity and consumer intake
Development of scientifically valid procedures for measuring biological activity and neurological effects of nicotine and smoke constituents.
- Use of filters, paper, and ventilation
Modification of tobacco products through use of filters, paper, and ventilation, and measuring effects on dependence, behavior, and toxicity.
- Use of tobacco processing/ blends
Modification of tobacco products through changes in tobacco processing and use of blends, and measuring effects on dependence, behavior, and toxicity.
- Keyword
- Addiction (Dependence)
- Behavioral effects (Behavioral pharmacology)
Addiction behavior, withdrawal, and measured nicotine effects
- Benefits of Smoking
- Consumer acceptability (Consumer preference)
- Daily intake
- Delivery modification
- Flavor/ Taste (Attribute measure)
- High impact/low tar
- Low delivery (Reduced delivery)
- Nicotine delivery (Smoke nicotine or nicotine yield)
- Nicotine manipulation
- Satisfaction
- Self-administration
- Sensory response
- Smoke pH
Acidity/ baseness, scale from 0-14, 7 neutral
- Smoker behavior (Human smoking behavior)
Puff parameters, daily intake, etc.
- Smoking and Health
- Tar/Nicotine ratio (Nicotine/Tar Ratio or T/N ratio)
- Total particulate matter (TPM or Tar)
- Additive
- Ammonia
see also: Ammonium bicarbonate, Ammonium carbonate, Ammonium chloride, Ammonium hydroxide, Ammonium sulfide, Diammonium phosphate, and Urea
- Urea
- Smoke Constituent
- Nicotine
- Design Component
- Blended leaf (BL)
- Bright tobacco (Flue-cured tobacco)
- Burley tobacco
- Burn rate
- Cellulose acetate filter (CA filter, Conventional filter)
- Reconstituted leaf (RL)
PM @reconstituted_tobacco, c. 1970s-1980s
- Selective filtration
- Named Organization
- British-American Tobacco Co Ltd (British-American Tobacco Co. Ltd.)
British-American Tobacco Company Limited was a operating group under B.A.T. Industries P.L.C. in 1985.
- Applied Research
- Behavioral Research
- Philip Morris Incorporated (Philip Morris U.S.A.) (a wholly-owned subsidiary of Philip Morris Co., Inc.)
A wholly-owned subsidiary of Philip Morris Co., Inc.
- R.J. Reynolds Tobacco Co. (Cigarette manufacturer (Camel, Winston, Doral))
Cigarette manufacturer (Camel, Winston, Doral)
- Brown & Williamson Tobacco Corporation (B&W)
Subsidiary of BAT U.S., located in Louisville, KY.
- Brand
- Table
- Premier Brand Cigarettes ("Smokeless" cigarette by RJR in the early 1990s)
"Smokeless" cigartte marketed by RJR in the early 1990s.
Stationary furnace devices such as this operate by separating the combustion material (carbon) from the aerosol generating material (mostly glycerol) such that the inhaled by-products yielded upon smoking are the distilation products (glercerol and water) rather than combustion products (nicotine + smoke constituents). This is one reason why this product failed in market. Flavoring is derived from tobacco, nicotine, the paper roll and sprayed dried extract. Addition flavor of primarily rasberry ketone and chocolate was also added to enhance tobacco taste and give rise to a "pleasing aroma" in the smoke. This added flavor was a major reason that Premier failed in market as the taste was very different from conventional cigs.
- MERIT ULTRA LIGHTS
- Subject
- Ammonia (Additives)
- Bioavailability (Measures)
- Blends (Design)
- Cancer (Health Effects)
- Cardiovascular Effects (Health Effects)
- Effects—Smoking Behavior (Effects)
- Expanded Tobacco (Design)
- Filters (Design)
- Formulas (Design)
- health effects
- Low Yield Cigarettes (Products)
- nicotine technology
- Paper (Design)
- pH Manipulation (Technology)
- Receptors (Effects)
- Reconstituted Tobacco (Design)
- Respiratory Effects (Health Effects)
- Sensory Effects—Impact (Effects)
- Sensory Effects—Taste (Effects)
- Smoke Constituents
- Smoke Delivery/Transport (Measures)
- Smoke Nicotine (Measures)
- Smoke pH (Measures)
- Smoothness/Harshness (Effects)
- T/N Ratios (Measures)
- Tar (Measures)
- Test/Consumer Preference (Testing)
- Test/Smoke Constituents (Testing)
- Tobacco Type (Design)
- Transfer to Smoke (Measures)
Document Images
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The Manipulation ~nd Control of Nicotine and Tar in the Design and ]Vl'znufactura
of Cigarettes: A Scientific Perspective
by William A. Farone, Ph.D.
h is well recogmzed witch th.c. cigareue industry tlmt there is one principal rc~on why
people smoke -- to experience the effects ofnicotinc, a known pharmacologically acdve
constituent in tobacco. The rccem discussion concerning the regulatory ~ams of nicotine
has led to some cort.fvsion over the role of nicodne and tar in the design and cons;ruction
ofcigarenas. As a scientist who devoted seven ye~s to the industry as the Director of
Applied Research, in the ~,esem'ch & Development departmcm of Philip Morris U. S. A.,
part of PhiJip Morris, Inc., I would llke to put forth a scientific, hopefully objective,
assessment of strides made by fallow scientists w'hhin the +ndustry.
Research inlo the impo~ance of nicotine [o |he Eobacco industry can be traced to the
1960's when the British American Tobacco Company initiated research Lo understand
some of the actividas ofnicmlne. I Clearly by the 1970"s and early 1980"s the tobacco
industry established that smokers required a minima[ level of nlcotine within a c[gare~e?
J H~selbaeh CH., el al.. "Final Report on Project H[PPO It." for the Br;t;st~ American Tobacco
Co Lid..
[3anc11¢ Memorial Institute, Geneva. March. 1963.
: Dunn W1,., "Mocives and Inccntlves m Cigaren¢ Smoking." Philip Morris, 1972.
Teague` CE. "Research Planning Memorandum on the Naeafe of the Tobacco Busi©ess and the Cnlcial
Role
of Nicotine Therein." R. J. Reynolds Tobacco Co.. April 14, 1972.
The mdusrry's unde~candi.n8 of the need for a min~um level ofnlcodnc is further reNected in paten~
held by
¢{zarecte manufacmrer,a. ~ U. S. Patenz No. 3.584.630. Inskeep OF=-. "Tobacco Product Havin8 Low
Nicotine Contenz Associated with a Release Agenl having Nicotine Weakly Absorbed Thereon." PNJJp
Morris
Inc..June 15, 1971. C1:18-20. 39-43.
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Knowledgeable industry personnel, primarily scientists and blend and development
personnel, understood that a level of nicotine had to be present to result in a commercially
successful cigarette. As publicly available documents reveal, the tobacco industry, began
to scuc~y how to design and constnact cigatez~es to ensure acceptable nicotine lcve']s.) It
was common knowledge wltldn the industry that cigarettes without nicotine would not
sell. Nicotine free cigarettes in the 1950's and 1980's were failures.4
Wh~le the negative health consequences of smoking, particularly emphysema and the
increased rate of lung cancer among smok,'rs, a~e well known, it should also be noted that
smoking, like the use of fermented beverages and bean and leaf extracts, is a centuries old
phenomenon. The fact that a wide va,"ie~ 0fplants contain chemlca]s with
pharmacological activity can either bc regcrded as positive or negative depending on
whether one is looking for a cure for disease or believes that behavior modification is a
negative result.
Research by ~he indusc~ has shov,'n that the pharmacological effects of nicotine have
been a two edged sword. The indusew understood ~hal consumers smoke cigaRttes
U. S. Patcnl No. 3,109,436. Barley A.. el el.. "Tobacco Products." Philip Morris Inc..
November 5. 1963.
C1:11-I:~. 34.39.
Eichom PA end Punn WL, "Quarterly Report of" Projecs 1600 and 2302." Philip Morris,
December ,~ ].
1970. in 14 ] Cong. ReC. H$127 ¢~ seq.
Philip Morris USA, "Research and Development Five Year Plan. 1974-1978." M~y 1973. in 141
Con~. R©c,
H$130 e: seq.
"~ Freedman AM.. "Past is Ominous fOr Substird|¢ Smokes." The Wall StTeet Journal.
31./fie 15. 1989.
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because oft.he pharmacological properties of nicotine,s Industry researchers were also
aware ,.hat the nicotine found within cig~ett¢ smoke may have negative peripheral
nervous system (cardlovascular) effects .6 However, it should also bc pointed out that
industry research on nicotine's pha.n-nacological effects has shown some potential
benefits. For example, research completed by g. J. Reynolds Tobacco Company
maintains that cigarettes provide smokers with psychological benefits, such as incrca.sed
mental alermcss and anxieL'y reduction.~ In addition, research at Philip Morris analyzed
the possible benefit ofnlcotin¢ related to hyperkinetic children as well as nicotine's
beneficial effects on reducing stress experienced by smokers and improving the
performance of tasks,s
:l Ryan/Dunn Alternate. "Third Version ofBo&rd l~eaenmtioa." Philip Morris. Fall 1969. in 141
Cong,
gec. H7646 et scq.
Mr-too room JL Charles to g.B S¢ligmaa, "Ni¢oHne ReccpEor Program - Onivcrsi~ or Rochester."
March IS.
1980. in 141 Cong. Rec. H7650 a seq.
Teague. supra n. 2.
Charles. supra n..5.
Hearings on Regulation of'Tobacco Producu. ~rore the Subcomminee on Health and the Envffonmcnt of
the
Comminee on Energy and Commerce. 103d Cong. 2cl Sess.. p~. 3 a133 (April 25. 1994) (testimony of
former
Philip Morris scientist Victor John DeNoble. Ph.D.).
) Robinson JH. el el.. "The Role of Nicotine in Tobacco Use." Ps'.'ehonharmaeofoov. 105:397. 1992.
z Philip Morris Research Center. "Behavioral P, es©nrch Annual Report." July 18. 1975. in 141
Cong. gcc.
H76~2 el seq.
Memo from FJ Ryan |o ".6'L Ounn. "Proposed Research Project Smoking and Anxieiy." Philip Mort'is.
Deccmber 2.i. 1969. in 141 Cong. ge¢. H'/648 et scq.
Eichom PA. ¢t el.. "Ouartcrly Repe'~ -- Projects 1600 and 2302," Philip Morris. October ,5. 1972.
in lot
Cong. R:c. HTf~49 c~ seq.
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If we accept the premise -- as the cigarette industry, sute]y does -- that ciga.rencs are a
nicotine delivery system, and that current laws do not forbid the self administration of
nicotine via smoking by adults, then it becomes a desirable mchnical challenge to
decrease the "tar" in a cigararte while mainmirdng the delivery ofnicofine. This has been
a key objective of the cigare~e industry over the last 20-30 years, aS some industry
documents now publicly raveal.9 Minimizing the exposure to the potential negmive
health effects of the undesirable chemical components in tar while maintaining an
acceptable and pharmacologically active nicotine level is thus a valid and useful technical
challenge that i and many of my former colleagues in the cigarette industry considered a
top pdofiP/.
Achieving this acceptable and pharmacologically active nicotine level was an enormous
challenge. It required cigarette manufactu.r,'rs to deliberately control the levels of
nicotine in their products in order to overcome the naturally-occurring variabJlhy of
nicotine in tobacco plants. Since [obacco is a natural product and the contenl of nlcofine
varies from year to year. by type of tobacco, by varieties within types, and from farm to
farm, it is also necessao' to be able to control nicotine levels and the ratio of nicotine to
'~ Memo from TS Osdene Io WL Dunn. "'~.Year Plan." Philip Moffis, Oclober 29. 1973. in 14 t Cong.
Rcc.
H 8149 et seq.
Teague, supra n. 2.
Morini HA. "'Cigateacs wiih He01th Assurance," BATCO, 19~6.
U. S. Patent 4.676~$9. Ellls l',lP., et aL "Nicotine Enhanced Smoking Device," Advanced Toba:eo
Produccs
Inc., .lone 30, 1957. C h2]-22. 5~-55.
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tar to be able to make a consistent product and to accurately label the product for nicotine
and mr as rcquircd by law.
Cigm-eue manufactu.rcrs have invested enormous 1"~nancial resources to achieve the
desired level ofc~ntrol over ~cotine and tar in ~e[r products. The indus'uy employs two
pdnclpal means of comrolllng.the mcotlne levels:
1. By modification and cons'o/of the tobscco blend, i.e., the ratio of BttrIcy (air cured),
Bright (flue cured), Oriental, stems, expRnded tobacco products, and reprocess=d tobacco
products such as tobacco sheet made ~om stems and waste lea.f.
2. By modification oflhe construction of the cigaret"(e such as filter type, the type of
filter ma[c6.al used, the number and placement ofvemilation holrs, the density,
composldon and porosi~/of the cig~rene paper, the ]ength and diameter of the paper, and
the types and &mounts of flavor additives.
Over the years, these techniques have been described or discussed in the public domain at
various meetings and by publications in books, palents, scientific papers, and
newspapers.~°
m T~C I'ol~o~ving references cover a wide varie~ of the published methods for modil'ylnz the
nico*ine to tat
ratio:
t
Spears AW.. "Factors Affecting Smoke De}ivery of Nicotine and Carbon Monoxide." presem~d tit
the "197~ Symposium - Nicoiine l.qd Carbon Monoxide." presented by' ;he Tobacco and Heakh
Research tnsclcu~e and The Kentucky. Tobacco Research Board. November 17-18. 1975.
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The s~ongly held conviction of most industry scientists and product developers was d~st
nicotine was the primary reason why people smoked. This was sometimes openly
expressed." In fat:, it wax commonly understood within the industry ~at the smoker's
Spears AW and Jones ST, "Chemical mad Physical Criteria fat Tobacco Leaf of Modem Day
Cig~e'~.s." Recent Adv~nee~ in Tobacco Sclen¢~, 198 l, 7:19-39.
Halmr I'SM., et al., "Effect of Tobacco ReconstinJtlon and Expansion Processes on Smnka
Composition," in Recent Advxnee~ in Tobacco ~el~nce. ]2nd Tobs¢¢o ChemlsCs' Research
Conference, October ~0 - November l, 1978, voL 4, pages [ 13, 126.
Freedman AM., et sl., "Why Don't Low-Tar Cigarencs Have Lower Nicotine?" Th¢ Wall gh'eet
Journal. July 14, 1995.
Freedman AM, "Impact Boos[at' Tobacco Firm Shows How Ammonia Spurs Dcllvary of Nico~,"
The Wall Street Journal. October I g, 1995.
"Filter Material Red~ces CO/Tar Ratio Wichout Pressure Drop," Tobacco Reporter, April
19$$; 112(4):30.34.
Kiet'ar .rE.. "Ventilated Fihers and the~" Effect on Smoke Composition," Rr..scarch Laboratories.
Tennessee East?nan Company, pa=oes 69-83.
McMu~ie A.. et aL. "Ci~arenc Paper Effects on Tar/Nicotine and COCl'ar Ratios," Abstracl flora the
351h Tobacco Chemists' R, ese~teh conrerenc¢. Winston-Salem. NC. Paper No. 17. 198 I.
S,'Ike WA. "Making lh¢ C~g~ene Do Just What You Want It To Do." Jouenol TobacCo
lmer.atlonal. September 16. 1983.
Norman v., "The Effect of Tip Dilution on the Fikcadon Efficiency of Upstream and Downs,'cure
Segments o/' Cigar~e Filters," 8eitroge ".ur Toba¥or.d, unX International. VoL 12, No. 4. July
1954.
Browne CL.. The De¢i~ ot'Ciearenes. Third edition, Hoechst Celanese Corporation. 1990. page 7":.
Browne CL. eta[.. "The Eff¢cx of Fihar Ventilation on Ihe Yield and Composition o1" Halnsrrcam and
Sfdesn'e,,',.m Smoke," Abstract from Ihc .32nd Tobacco Chemisu' Research Confeeen¢©. Montreal.
Canada. Paper No. 16. 1978,
Owens V/F, "Effect of Cig~rcne Paper on Smoke Yield and Composition." Abstract from the ~2nd
Tobacco Chemlsu" Research Conference. Monrre~l. Canada. Paper No, I. 1978,
Lcc BM. "Modification of' Nicotine to Tat R0.tio in Cigar¢r~c Smoke'." Abstract from Ihc 42nd
Tobacco ChcmisU' Rcsezsch Conference. Lexington. KY. Paper No..34. 1988.
Philips JA. "Fikers for Cigsrenes: An Integral Pan of the Cigarette." Tobacco Reporter. October
1981.
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acceptance ofa cigaseue was related to the amount of nicotine it contained. Exter~tve. in
some instances ground breaking, research by the tobacco industry was necessary, to
construct a cigarette that ensured an adequat,, delivery of nicotine as the cigareu¢ market
evolved from the traditional full flavored, urufhared product of the 1950's to the filtered,
low tar cigafeue demanded by many smokers for the last 30--40 years. The objective of
industry scientists and product developers, simply stated, was to provide the consumer
with the same pharmacological satisfaction derived from nicotine in the natural blends
and flavor of the full streng'~h cigarettes of the 1950's as the marketplace shifted to the
naturally less flavorful and satisfying low tar and nicotine cigarette demanded by the
more health conscious consumer.
A major contributor to this process was Dr. William Dunn, Principal Scientist and
manager of the Behavioral Research group of Philip Morris. Durra believed that nicotine
was a beneficial component of cigarette smoke,t: Tar was considered to be the
"biologically active," i.e. harmful, component of cigarette smoke. Therefore. the
development of low tar cigarettes that gave the smokers the nicotine they wanted but
exposed them to less tar were considered good research and product development
objectives. Industry scientists were proud to be working on the development of these
products. D;scussions at industry, or company sponsored meetings such as the Tobacco
" Dunn. mpr'a n. 2,
Ch:lr]es. supra n..~.
Tcaguc. supra n. '~.
J'~ Dunn. ~upn~ n. 2.
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Chemists Research Conferences o~en occu~ed among blend specialists, market
researchers) and research & development scientists on how to attain that level of
acceptability while reducing the tar, An armmpt by R. J. Reynolds to produce the
ultimate low tar cigarette wa~ the PREMIER nicotine delivery device. PREMIER, which
was test marketed by R2R, delivered virtually no tar at nicotine levels slightly lower than
ctaxently marketed fuller flavor low far cigarettes,t~ According Io news reports, Philip
Morris was also working on their own version of PILEMIERo code named TABLE.jJ
While working at Philip Morris, D~ and his behavioral scienco group promoted the
need to provide adequate levels ofalcotine in the product, and to maintain adequate
levels ofaicofine in order to keep smokers satisfied. This concept of nicotine delivery
being essential to consumer satisfaction was common "knowledge within Philip Morris
• I¢
and the rest of'the mdustry. " When consumer testing indicated that a product was
lacking in "impact" or some similar descriptor that could be associated with nicotine.
experienced market researchers and product developers would compensate by increasing
nicotine levels to provide the necessary impac~ in furore versions of that product.
,a "New Cigarette Pro{o~pes that Neat Ins[cad of Bum Tobacco." R. J. Rcyno ds Tobacco Company.
Wins{on-Salem. NC. 19gg. page 3.
" Freedman AM., "Phillp hlorr;s blemo Likens Nicotine to Cocaine," The Wall Srree{/oumal, December
$. 1995. BI.
)s OunN. Supra n,2.
Charles. supra n. ~.
Tcagua. supra n. 2,
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As in any discipline, basic ph~macologlcal resem'ch was necessary to properly
unders~nd a phenomenon. The iodusu'y applled considerable eHor~ and manpower to the
study ofmcotine in order to unders~nd t~s relationship between nicotine and lhe
smoker's needs. Many internal ind~s~y documents that have recently become publicly
available reflect, in pan, he novel and extensive research conducted. Philip Morris
undertook resc~ch into nicotine's effect on brain waves, brain receptors, the
cardiovascular systcm, physlologlcal impact, juvenile hyperidnesis, aJlevlating anxieP/,
su'ess, and aggression, the smoker's motivation to continue smo~ng, as well as on the
smoker's cognitive abilitiesJ6 R. J'. Reynolds (P,.J'R) research involved human
experimentation including analyzing rdcodne blood levels and nicotine urlnc levels as
,,yell as the identification of specific brain receptor locations involving the binding sizes
for nicotine. ,7 British American Tobacco Company (BATCO), the patent company of
U. S.-bascd Bro~ & Williamson Tobacco Co., sponsored pioneering work into the
addictive nature of nicotine more [han 30 years aso and Philip Morris lazer conducted
state-of the-an an{ms[ studies demonstrating that nicotine is a "positive reinforcer." and
,o 141Cong. Rec. 7646 (rcprindng Philip Morris rcscarch documents). July "!f 1995.
,7 R.J. Reynolds Tobacco Company, New Ci_oarene ProtoP.,oes Ihat Hen( [nszeod ot'~rn T~bacco, $up~
n. 13. al pp. 4J7-557.
#
Fluhler. e~. a[. "A Hybrid PBPIOPD Model /'or Ni¢o mic Receptor Dynarnica in the Rat Brain." Duke
Unlvars[ty Medical Center lind P,. J, Reynolds Tobacco Co.. Absol¢~. Society for NrurosrJrnce. 22nd
Ar~ua[
Meeting. Anaheln~. CA, Vol. [$. Pa~ h O¢lobcr 25 - 30, 1992.
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that this effect is centrally mediated, one of the deriving ch~ac:cdstics of addictive
drugs.Iz
This basic research provided product developers with the scientific foundation that was
necessary to help construct a low tar.cigarene that ma/ntzined an adequate level of
pharmacological activity from nicotine in reduced tar products. Product developers and
blend and leaf specialists were responsible for manipulating and controlling the design
and production of cigarettes in order to satisfy the consumer's need for nicotine in lower
yield products.
Blend changes were an especially import~'mt tool used to ensttr¢ desired nicotine levels.
Tar is e function of tobacco weight. However, an all-burley cigarene will produce a
higher nicotine level than an all-bright tobacco cigarette of the same ,.valghL The
industry "knew that by using a higher percentage ofhlgher nicotine tobacco in their low
tar cigareaes they could achieve an increase of their nicotine levels. Therefore a blend
change incorporating the greater use of higher nicotine tobacco while reducing the overall
tobacco weight, such as through the use of expanded tobacco, could produce a low tar
cigarerle with the desired pharmacologically active level of nicotine associated with a
conventional full flavor cigarette. An example is the Merit Ultra Light. which was
,i H~dbach C.. ec ol.. "A Tentativc Hypo:hes;s on Nicotine Addiction,'" Soulha/nplon, England.
May 30,
1963. pages 1-3.
Hearings on Regulation of Tobacco Produc~. April 2g, 1994, supra n. 6. at 5. 6, 20.
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