Skip Navigation

Comment to the World Health Organization regarding Noncommunicable Diseases and Their Risk Factors

May 16, 2018

The Heartland Institute's Comment to the World Health Organization's Independent High-level Commission on NCDs

May 15, 2018

WHO Independent High-level Commission on NCDs
World Health Organization
Avenue Appia 20
1202 Geneva

RE: Noncommunicable Diseases and Their Risk Factors

The Heartland Institute applauds the World Health Organization’s (WHO) efforts to reduce premature mortality from noncommunicable diseases (NCDs) in its 2030 Agenda for Sustainable Development. Such goals will not only promote better health practices, they will improve economic conditions in communities around the world.

Smoking significantly contributes to the development of NCDs, including cardiovascular disease, strokes, cancer, and chronic respiratory diseases. Approximately six million people die worldwide each year from tobacco use. WHO estimates this number will increase to 7.5 million by 2020, “accounting for 10% of all deaths.”[1]

Since the United States began its anti-smoking campaign in 1964, the federal government has required tobacco companies to include warning labels on cigarettes and has banned cigarette advertising. In the 1990s, numerous states sued cigarette companies, resulting in 1998 “Master Settlement Agreement,” in which tobacco manufacturers agreed to “annual payments in perpetuity”[2] to states. Federal, state, and local governments have also imposed excise taxes on cigarettes to decrease their use, but they have also increasingly come to rely on them when facing budget shortfalls.

Despite the U.S. government’s continued taxation and regulation of cigarettes, approximately 39 million Americans continue to smoke. The current system of taxation and regulation has been remarkably ineffective in helping smokers quit. Growing evidence from the U.S. and other countries suggests the use of less-harmful alternatives to cigarettes—such as smokeless tobacco, heat-not-burn, and electronic cigarettes—are viable alternatives to combustible cigarettes and far more effective smoking-cessation tools. Tobacco harm reduction products “explicitly [include] the use of tobacco or nicotine and [are] designed to reduce the health effects of tobacco use.”[3]

Smokeless tobacco products have been used for centuries and remained “the dominant form of tobacco used in the U.S. until early in the 20th century.”[4] Today, the most popular forms of smokeless tobacco include moist snuff, chewing tobacco, and Swedish and American snus.

Based on data from Sweden and other countries around the world, we now know smokeless tobacco poses considerably fewer risks than combustible cigarettes. Brad Rodu, a senior fellow at The Heartland Institute, has over two decades of experience researching smokeless tobacco. According to Rodu’s research, smokeless tobacco is “at least 98 percent safer than smoking, even though most Americans are misinformed about the differences in risk.”[5]

E-cigarettes and vaping devices pose a significantly lower health risk than combustible tobacco, and many public health organizations are now acknowledging these products and their benefits to public health. The American Cancer Society noted in February 2018 that “based on currently available evidence, using current generation e-cigarettes is less harmful than smoking.”[6] Earlier in 2018, the National Academies of Sciences, Engineering, and Medicine found e-cigarette use to result in “reduced short-term adverse health outcomes in several organs.”[7]

Other public health organizations from around the world have reached the same conclusion. In 2017, NHS Health Scotland found using e-cigarettes is “less harmful than smoking.”[8] In 2016, the Tobacco Advisory Group of the Royal College of Physicians in the United Kingdom determined the health hazards associated with THR products are “unlikely to exceed 5% of the harm [caused by] smoking tobacco.”[9] In 2015, Public Health England declared e-cigarette use as roughly “95% safer than smoking.”[10]

Recently, the Food and Drug Administration announced a comprehensive strategy placing “nicotine … at the center of the agency’s tobacco regulation efforts.”[11] While addressing the cause of addiction by tobacco cigarettes, the agency’s new approach notes a continuum of risk, and recognizes there are products that deliver nicotine less harmfully.

We believe products such as smokeless tobacco, heat-not-burn, and electronic cigarettes have significant potential in aiding the WHO in its mission to eradicate NCDs. As the evidence for their potential as effective cessation tools continues to grow, public health agencies should focus on policies that promote their use. Not only should these products be regulated differently than traditional cigarettes, public health groups should inform the public of their health potential and use these tools to combat smoking.

The Heartland Institute recommends the WHO:

  • Assist nation-states with the creation and oversight of tobacco-control programs that promote the use of less-harmful products for cessation aids. Significant health gains will be lost without the promotion of these products, as there is ample evidence indicating they are some of the most effective cessation tools.
  • Governments should promote policies that encourage the use of less-harmful alternatives to cigarettes, rather than creating regulatory hurdles that prevent smokers from using these products.  
  • WHO should encourage governments to continue working with the private sector to find free-market alternatives to combustible tobacco cigarettes.


Lindsey Stroud
State Government Relations Manager
The Heartland Institute




[1] “10 Facts on Noncommunicable Diseases,” World Health Organization, March 2013,

[2] “The Master Settlement Agreement: An Overview,” Tobacco Control Legal Consortium, August 2015, p. 1,

[3] “Tobacco Harm Reduction” (webpage), Harm Reduction International, n.d.,

[4] Brad Rodu, “Swedish Tobacco Use: Smoking, Smokeless, and History” (webpage), American Council on Science and Health, May 12, 2004,

[5] Brad Rodu, “Helping Smokers Quit: The Science Behind Tobacco Harm Reduction,” American Council on Sciences and Health, December 1, 2011,

[6] “American Cancer Society Position Statement on Electronic Cigarettes,” American Cancer Society, February 2018,

[7] “Public Health Consequences of E-Cigarettes,” National Academies of Sciences, Engineering, and Medicine, 2018,

[8] “Consensus statement on e-cigarettes,” NHS Health Scotland, 2017,

[9] “Nicotine without smoke: Tobacco harm reduction,” Royal College of Physicians, April, 2016,

[11] “FDA’s Plan for Tobacco and Nicotine Regulation,” U.S. Food and Drug Administration, July 28, 2017,