Product Design
Questions and Answers Concerning Ingredients
Abstract
Lists questions and answers regarding ingredients added to cigarettes. Discusses types of ingredients such as casing materials and humectants. Defends the use of ingredients in the manufacture of cigarettes. Makes case for why "identity of ingredients" has not been made available to the public. Indicates the industry will "cooperate with the Department of Health and Human Services in its review of the [ingredient] list." Discusses testing of ingredients and addresses concerns about their health effects.
Fields
- Notes
Similar to Bates #2040857455. Duplicates Bates #2025597501 and #2025597446.
- Hypothesis
- Design changes over timeChanges in cigarette design over the past half century.
- FTC machine testing and ratingsDesign changes to achieve altered FTC smoke machine tar and nicotine ratings, with or without measured changes in human intake.
- Inhalation ProfileAre cigarettes designed to cater to individual inhalation profiles?
- Mainstream constituent yieldsModification of selected mainstream smoke constituents in response to health concerns.
- Measuring overall toxicityDevelopment of scientifically valid protocols and methods for testing the health and toxicity effects of changes in product design.
- Smoke constituent testingDevelopment of methods for measurement of gas and particulate yields in mainstream and sidestream smoke.
- Toxicity and consumer intakeDevelopment of scientifically valid procedures for measuring biological activity and neurological effects of nicotine and smoke constituents.
- Use of additivesModification of tobacco products through use of additives and measuring effects on dependence, behavior, and toxicity.
- Keyword
- Consumer acceptability (Consumer preference)
- Delivery modification
- Flavor/ Taste (Attribute measure)
- Generally_Recognized_As_Safe
- Inhalation (Smoke inhalation)
- Mildness (Attribute measure)
- Satisfaction
- Sensory response
- Smoking and Health Controversy
- Smoothness/Harshness (Attribute measure)
- Tobacco taste (Attribute measure)
- Additive
- Clove 1 (Clove Leaf Oil and Clove Bud Oil)
- Coumarin 2
- Eugenol
- Design Component
- Flavorant
- Top dressing (Top flavor)
- Named Organization
- United States Congress
- European Council 3
- Covington & Burling (Tobacco Industry law firm)Tobacco industry law firm. Was involved in organizing the Whitecoat Project.
- *Department of Health and Human Services
- United States Food and Drug Administration
- FEMA (Flavors and Extracts Manufacturers Association) (Trade association of flavor ingredient manufacturers)
- HHSC (Health and Human Services Commission, Austin, TX)Health and Human Services Commission, Austin, Texas
- Hunter Committee (British committee investigating tobacco issues)
- Independent Committee on Smoking and Health (The Independent Committee on Smoking and Health - U.K.)The Independent Committee on Smoking and Health is in the United Kingdom
- International Agency for Research on Cancer ("IARC") (International Agency for Research on Cancer ("IRAC"))International Agency for Research on Cancer ("IARC")
- Mother Jones 4
- Subject
- additives
- Cancer (Health Effects)
- Cocoa (Additives)
- health effects
- Humectants (Additives to maintain moisture)
- Licorice (Additives)
- Sensory Effects—Taste (Effects)
- Smoothness/Harshness (Effects)
- Sugars (Additives)Glucose/Invert Sugar/Fructose/Sucrose
- Test/Consumer Preference (Testing)
- Test/Smoke Constituents (Testing)
- Test/Toxicity (Testing)
- Transfer to Smoke (Measures)
Annotations
- 1. Clove Additive
- Description:
additive
- Description:
- 2. Coumarin Additive
- Description:
additive
- Description:
- 3. European Council Named Organization
- Synonyms:
EC
- Synonyms:
- 4. Mother Jones Named Organization
- Description:
Magazine
- Description:
Document Images
QUESTIONS AND ANSWERS CONCERNING INGR'EDIENTS
Why are ingredients used?
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ANSWER: Some ingredients aid in processingitobacco ini
the initial stages of cigarette manufacture. These
ingredients help in the processing of tobacco but remainin the final cigarette in minute quantities,
if at all.
Other ingredients are used as casing materials or
hu¢nectants. Casing materials, such as sugar, help too
smooth and balance the taste of cigarettes, while
humectaints keep the tobacco in cigarettes moist. Finalliy,,
many of the ingredients are used'to give individual
brands of cigarettes their distinctive flavor and aroma.
2. How long have ingredients been used in cigarettes?
ANSWER: Ingredients hawe been used for over 1501years.
When Europeans first learned about smoking tobacco f'romm
the Indians, the tobacco they smoked was flavored with,
citrus peels and:other spices and herbs. In the United
States, the use of flavorings has been a comnicn practice
since colonial times. Most of the principal processing
aids:, casing materials, and humectants,, for example, have
not changed' for decades.
3. Why are so many ingredients used?'
ANSWER: To put thenumber of ingredients in
perspective, it is worthwhile to note that there are some

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380 different brands and packings of cigarettes sold in
the United States'. The ingredients on the HHS list a!re
am aggregate of all the ingredients used., Obviously not
a_I ingredients are used in every cigarette.
Furthermore, twenty of those ingredients
comprise approximately 99% of the total amount, by
weight, of ingredlients uised in the industry. The other
ingredients are used irn smaller amounts, and most of the
ingredients on the list submitted to HHS are used in
extremely small quantities as part of fLavor formula-
tions. These formulations of'ten include a number of
ingredients, b~ut~ typicalindius°try-wideusag~eof` many of
these flavor components is under 10 pounds a year. This
is in contrast with the over 8'million~poyds of
'i~n the United States
tobacco employed in cigasettesCold
each year. The flavor formulations used by the companies
change occasionally as new products are int~roduced or
existing:products are reformulated in response to con-
sumer preferences.
4. Why are so many ingredients usedlin American cigarettes,
when many fewer ingredients are used in cigar'ettesmadein many other countries?
ANSWER: The very premise for this question is not true
if you are talking about U.S. style cigarettes. This iss
because American stylecig&rettes are a blend of'
different types of tobacco, some of'which call for more

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ingredients than others. Consequently, where American
style blended cigarettes are the norm, there may be only
sligiht differences in, the numbers of ingredients used by
manufacturers in different countries.
However, there are certain countries, such as
the U.K. andl its former colonies, where smokers prefer
cigarettes which do: not contain, a blend of different
types of tobacco but contain only Virginia: flue-
cured tobacco. The latter db not require as many ingre-
dients to smooth their taste as do some of the tobaccos
found,in bl!end~edcigarettes,. Nevertheless, ingredients
are used in Virginia style cigarettes as well.
5. Are ingredients used'in large amounts?
ANSWER: ewer tha twenty ingredients such as casing
materials (which smooth and balance the f'lavor of cigar-
ettes), moisturizers, and major flavors (such as
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menthol ), account for 99t of' -the weight of ingredients
actually, found in cigarettes. Certain ingredients that
serve as processing a-ids are used in volume during the
earlystages° of manufacturing but theixpresence is
virtually eliminated in the manufacturing process. Suichh
processing aids remain in the finished cigarette in tracee
quantities, if at all.
A larger number of'the ingredients are used as
aroma f'lavo~rs, to give different cigarette~ brands: . their

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distinctive aromas, but these substances are in the final
cigarette in minuscule amouints. Most of the ingredients
comprise,these propriet.aryflavor mixtu:res,and uisage~of'
many of these ingredients by the entire industry is under
10 pounds per year.
6. Haven't the cigarette manufacturers started~ usi'ng ir-)ree
and more ingredients to compensate for the reduction.of
tar and'nicotine imcigarettes?
ANSWER: Neither t~he~~ numb~er~ nor quan,ti~ty~ of~ cas~ing~~
materials (,which smooth andlbalance the taste of cigar-
ettes) nor~ moisturizing agents have changed, asa~ result
of the growing:range of~ tobacco~ product&, including the~
introduction of lower "tar" and nicotine brands. Whilee
the number of~ f'l~avor~s~ whi~ch~ cons~~titut~e,the specia~l ar~omas
s
of individual brands may have increased, it is important
to~ no~te~~ that~~ flavors are used i.n, minuscu:1e~~ amounts, the
total amount of' all flavors,used constituting less than
one tenth of one percent by weight of a finished
c~i ga~r et t:e ~.
7~. Why hasm' t the i~de~~nt~~i ty of ~ ingredients been,prov~i~died! to~
the public before?
ANSWER: Whilr the identity of the ingredients has not
been provided to~the public, the U.S. Government has had
access to the.list of' all the ingredients usedl by the sixx
major U.S. cigarette~ manufacturers.

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It is common for all companies to guard
specific product formulas, and Congress recog,nired this,
when it passed the Federal Cigarette Labeling and Adver-
tising Act. The Act requires U.S. cigarette manufacturers
to submit an annual list of their ingredients but guaran-
tees protection against d'i,sclosure.of this information.
The flavors added to foods, for example, are treated'as
trade secrets and need!not be dlisciosed on the labels of
these products.
Not only have U. S. manufacturers submitted
ingredient lists each year since 198'b in fullcompliance
with the law, but since 1979 the industry has-voluntarily
provided
KE
S with information about ingredients. Under
an agreement reached in 1982, the tnanufacturers had
provided' B&S with a list of' commonly-used ingredients
added to tobacco in the manufacture of cigarettes. The
indlustry agreed then to consult with HSS as it addressed
any questions about specific ingredients. Consequently,
the U.S. government has had access to information about
ingredients for over ten years.
Because they contribute to the taste and appeal
of individual brands, the identities of specific ingre-
dients in cigarettes are also closely guarded'trade
secrets. Disclosure of the ingredients used in cigarette
manufacture could reveal product formslas that required
years'ofresea~rch toldevelop. The Federal C'igarette

Label!ing and, AdvertisingiAct recognizes the highly
confidential nature of ingredients information by
directing HH!S to: establish procedures to protect the
confid'entialityof theingredient&liste
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6. What role did the industry have in the prepaxatio.n of'
HHS!' ing~redientreport?
ANSWEFt: We regret that the industry had no role ine
the
preparation of the report. This strikes us asparticularly unfair since as early as 1979 the industry
has cooperated with IiES'with respect to the ingredient
issue. Well.before the legislation that required that
annual lists be submitted,'the industry voluntarily
provided information to HHS. The industry has informed
FiHS' of itswillingness:s to participate in a scientific
review of ingredient usage.
Despite these repeated offers, the industry was
offered no!role in the HHS'review of the ingredient
lists. The industry was not consulted about the types,of
data that mig;htbe reviewed, and industry scientists who
are pe,rhaps the most knowledgeable persons about the use
of ingredients in cigarettes were not called upon by SMS''
to provide information., Th~us,, HSS~ ignored ap°otential
source of highly valuable informati,on, and this resulted
in numerous erroneous eonclusions.
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9. Don't consumers have the right to know what is in the
products they buy?
ANSWER: The formulas of any number of consumer products
are not treatedias public informatiom. These formulass
often have great competitive value and require
substantiall time and expense to d'evelop. T'he law
therefore allows them to be treated as trade secrets.
For example, the flavorings used in hundreds of'foods and
in fragrances are treatedlas trade secrets.
10. Why aren"t the ingredients used in cigarettes listed on
the package?'
ANSWER: The identities of specific ingredlients used in
a particular brand of' cigarettes are important trade
secrets. "The taste of a specific brand may take years of
time and!millions of dollars to develop, and the law
recognizes that such valua~ble information is entitled to
confidential treatment. For example, the flavors used in
hundreds of foods.are treated as trade secrets.
11. The list of'additives which has been supplied to HSS
consists of'those substances which are currently added to
cigarettes. Save any su!bstances been phased out of use
in cigarettes since the submission of'annual lists began?
ANSWER: Yes. Like almost all consumer products, from
frozen foods to breads or soft drinks, cigarettes undergo
constant change as new brand's are introduced and~old
brands are modlified! or phased out. Mod'ifications in
cigarette formulations may be required to compensate for
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changes ini tobacco caused by variati!ons in weather
patterns, environmental conditions, agricultural
practices, as well as in res'ponse to changes in consumer
taste. However, most of the modifications in the
composition of cigarettes affect flavors which are
already in use and which are employed'.in extremely s:nalll
quantities, less thanione tenth of one percent by weight
of'a final cigarette. For many of'thes'e ingredients, thee
amount used annually is' less than ten.po'unds for thee
entire industry. The major ingredients change less
of'ten, and many of' them have been used for years.
12'. Are there any substances currently addiedo to cigarettes
sold only in other mar'Itets, particularly Third Worldi
markets, which are not used in cigarettes sold in the
United!States?
ANSWER 1: The Federal Cigarette Labelingiand
Advertising Act "only requires that information be
submitted concerning ingredients used in cigarettes sold
in the United States, and we have not compiled
information on cigarettes soldn in other countries.
However, a number of other count'ries regulate the use of
ingredients i~n cigarettes, and the companies comply with
these regulations wherever they exist.
ANSWER' 2': The Act only requi'res that information be
submitted concerningiingredients used in ci'lgarettes sold
in the United States. However, we can assert that the
cigarettes manufactured for export and sold overseas are.

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identical to the~comparable brands manufactured for sale
in the U.S. There is no double standard., All _the
ingredients used in the manufacture of cigarettes are
acceptable in the countries in which they are used.
Indeed, many countries regulate the use of ingredients i!n
cigarettes and we comply with these regulations.
13. Are ingredients added to filters, and if so, what i'ngre-
dlients are added and what tests have been done to
evaluate theiz safety?'
ANSWER: The Federal Cigarette Labeling and Advertising,
Act requires only that information be submitted
concerningiingrediients added to the tobacco used in
cigarettes sold in the United States. However, we
believe that the additiorn of' ingred'ients to filters is
not harmful to smokers.
14. Are the ingredients used in cigarettes harmful?
ANSWER: There is no legitimate basis for the conclusion
that the:addition to cigarettes of the ingredients on the
okers Virtuai1 all substances are
~,1'' t h mf 1 t m
s
are harmf'ul..
'e:smai quantities of ingredients used in cigarettes
15. What evidence is there that the ingredients are~not
harmful?
. y
is is ar u o
toxic at very high 1-evels, but the is no evidence that
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ANSWER: Most i~ngredlients usedlin cigarettes
manufactured in the United States are commonly used in
foods, have been reviewed by the Food and Drug
Admin istrationi (FDA) and are includied~ on the FDA lists of
approved food additives or substances "generally
recognized as safe" (GRAS), or on the Flavor Extract
Manufacturers Association's GRAS list.
Furthermore, governmental bodies in other
countries, such as Gseat Britai'mand West Germany, have
also evaluated ingredients used in cigarettes i!n those
countries. The inclusion of ingredients onithese lists
reflects a careful review of available data by
scientists. For example, the British ingredients list
was developed by a medical and scientific committee
appointed by the British.government, the Independent
Scientific Committee on Smoking and Health.
Virtually all of the ingredients used'by the
six leading,U.S'. cigarette manufacturers can be found on
the accepted listsf of one or more of the following
governmentally affiliated or recognized organizations:
the U.S. Food and~Drug Administration, FEMA-GRAS, the
U.K. Independent Scientific Committee on Smoking and
Health (Hunter-Froggatt Committee), and the relevant
government departments and'agencies of'Canada, Belgium,
Switzerland, France and the Council of Europe.
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