Contribution and Influence of the Civil Society for the New Health Warning Label of Tobacco Products in Brazil

Abstract

Background and context: In April 2017, National Agency for Health Surveillance (Anvisa) launched a public consultation for the revision of Resolution Number 335/2003, on health warning labels. Aim: A group of representatives from civil society and tobacco control advocates in Brazil met in person and virtually to make contributions to the Anvisa´s proposal for new health warning label for tobacco products packages, considering the civil rights for participation and collaboration to Brazilian policies provided by public consultation. Strategy/Tactics: The advocates and researches consulted the Framework Convention on Tobacco Control of the World Health Organization and its Guideline for Article 11 (Packaging and Labeling of Tobacco Products) implementation adopted in 2008 based on scientific studies and successful experiences in other countries. In addition, international researchers and representatives of international institutions were also consulted to collect successful examples of health warnings in the world. Program/Policy process: In October 2017, the Anvisa Board of Directors at a public ordinary meeting approved the new health warnings and in December of the same year, published the new resolution about it. Outcomes: In a comparative analysis, even if all the recommendations made in the CP have not been complied with, the influence of the contributions of the group of tobacco control advocates to the final version of the warnings is evident. The main contributions considered by Anvisa were: 1) to increase the effectiveness of the health warnings using colored images instead of black and white images, 2) the use of yellow in the upper and lower tiers was also one of the points suggested by the group, and 3) the concept proposed by the group for side warnings was fully complied. What was learned: Civil society participation for the agency´s public policy implementation process is essential and has been possible through the regulatory agenda, public consultations and regular public meetings. However, as is expected, the regulated sector has been quite active. The group recognizes the importance of the Anvisa measure in proposing new health warnings, however, significant recommendations have not been adopted and it may interfere with the goals of the measure. Anvisa´s strategy of allowing the social participation is essential, in accordance with Universal Health System principles and must be maintained. Regarding to the next health warnings and messages on packages of tobacco products, it would be greater to consider higher frequency of updating the images and recover the scientific process of development of the 3rd round of health warnings labels coordinated by the National Institute of Cancer in 2007/2008.