Smoke Free Partnership contribution to the revision process of the European Waste Framework Directive 2008/98/EC

The European Commission has launched a public consultation on the revision of the Waste Framework Directive. The aim is to achieve European targets for waste reduction, to improve the overall environmental outcome of waste management, in line with the waste hierarchy and the implementation of the polluter pays principle.

The aim of the fight against smoking is to achieve tobacco-free generations as quickly as possible – by 2032 in France and 2040 in the European Union. This policy is part of a public health perspective but also of reducing the serious environmental impact induced by the consumption of tobacco products and new nicotine products.

Smoke Free Partnership is the European coalition responsible for carrying out measures validated and supported by civil society in all Member States and even beyond in the entire WHO Euro region. As part of the public consultation launched by the European Union, various recommendations have been made by civil society.

This document is an adaptation of the document in english from Smoke Free Partnership

SUMMARY

Summary

Proposals for filters for tobacco products

1. Tobacco butts should be classified as hazardous waste;
2. Cigarette filters should be banned

• The human, environmental and waste management costs of cigarette butts;
• Opportunity and feasibility of the filter ban measure

Proposals on industry liability for environmental damage

1. Prevent any communication of the “socially responsible company” type, including in REP systems;
2. Transferring waste management costs to manufacturers;
3. Establish in each Member State a fiscal mechanism for waste management to be borne by manufacturers;
4. Impose regulatory and mandatory provisions regarding manufacturers' liability for their products;
5. Establish an independent research funding mechanism to assess the environmental damage of tobacco;
6. Require tobacco manufacturers to provide the information needed to fill the data gap on the environmental impacts of their operations;
7. Establish cooperation mechanisms between the Ministers of Health, Agriculture and the Environment to reduce the environmental harm of tobacco.

Summary

In addition to the already well-known devastating and avoidable health impacts of the tobacco industry, policy makers should now acknowledge the direct and secondary environmental costs of tobacco. These include the issue of waste from tobacco products and new nicotine products. The revision of the EU Waste Framework Directive is a unique opportunity to address the environmental costs of tobacco to Member States and to shift these costs (negative externalities) from being borne by the public sector to being borne by the industry itself, which is responsible for them.

The revision of the European Waste Directive should take measures establishing the responsibility of the tobacco industry for the costs incurred for the environment by its products and requiring this industry to reduce waste. To achieve this, fiscal/financial measures, positive obligations on manufacturers and even legal action should be retained. However, no provisions of a partnership and voluntary nature should be adopted.

Member States should strive to eliminate filters from cigarettes. They are a hazardous single-use plastic that is harmful to the environment and human health. Furthermore, extended producer responsibility (EPR) schemes should be adapted to the specific characteristics of the tobacco industry, in particular to avoid greenwashing, in line with the obligations of parties to the Framework Convention on Tobacco Control treaty. More funding should also be allocated to independent research on the environmental damage and costs of the tobacco industry, which should be required to provide the necessary information to fill the existing data gap. Finally, multi-sectoral collaboration between health, environment and agriculture ministries is essential.

PROPOSALS RELATING TO FILTERS FOR TOBACCO PRODUCTS

1. Cigarette butts should be classified as hazardous waste

Cigarette butts[1] and other tobacco products are the most commonly discarded waste in the world[2]-[3]-[4]. Every year, 4.5 trillion cigarette butts are improperly discarded. These butts are considered one of the most hazardous wastes and one of the most serious environmental threats in the world.[5].

The filters are made of cellulose acetate, a type of plastic that, when discarded, breaks into pieces, releasing microplastics. Added to this are the 7,000 chemicals and heavy metals they contain[6]. Cigarette filters are highly toxic and are one of the main sources of microplastics in our oceans.[7], thus ending up in the human food chain. When ingested, they can be fatal to marine and freshwater fish species.

Studies[8] showed that cigarette butts should be classified as hazardous waste, at least by HP 6 (toxicity) and HP 14 (ecotoxicity) according to the classification of the European Waste Framework Directive. The differentiation between beneficial products and inherently harmful or hazardous products is crucial. Therefore, the European health organisations gathered within SFP recommend to create a relevant code for cigarette butts in the harmonised list of waste (EU, 2014b).

2. Cigarette filters should be banned

A. The human, environmental and waste management costs of cigarette butts

In addition to the disastrous effects of the tobacco industry on health and the environment[9], cigarette butts pose a significant threat to our ecosystem. The main plastic that cigarette butts are made of, cellulose acetate, accumulates nicotine and other toxins from cigarette smoke and can be harmful or fatal if swallowed by children or animals. Thousands of birds die each year after ingesting discarded cigarette butts.

The health costs of a hazardous, useless but widespread waste

Cigarette filters were introduced in the 1950s[10] by the tobacco industry in response to lung cancer fears and growing criticism about the lethality of its products. Several analyses of internal tobacco industry documents and reports[11] Research has since proven that filters are nothing more than a "marketing tool" and that tobacco companies know that filters do not protect the consumer. They not only release plastic fibers when inhaled, but also pose a risk for a more aggressive type of lung cancer.

Cigarette filters mislead consumers into believing the product is safer[12]. They help make the product more attractive, especially when introducing children and adolescents. The industry takes advantage of an asymmetry of information towards consumers to make false claims about a deadly and addictive product. The Smokefree Partnership coalition considers that Member States should impose specific requirements on the design of a product where the design and components thereof are incompatible with sustainability objectives and are used to mislead current and potential consumers[13]In addition to the 8 million annual deaths from tobacco-related diseases worldwide, the approximately 700,000 deaths in the EU and the €25.3 billion in healthcare costs[14] are also to be taken into consideration at a time when the resilience of health systems is being called into question.

Cigarette butts are killing our planet

Toxic tobacco filters have been polluting oceans and land for at least five decades. In the last ten years alone, the loss of ecosystem value is estimated at around US$186 billion (€187.3 billion).[15]This estimate does not take into account environmental damage caused by toxic chemicals and metals released by cigarettes.[16]It also does not take into account other related costs, such as droughts, which cost the European Union €9 billion a year.[17].

Cigarette butts are depleting our water resources

One cigarette butt contaminates up to 500 litres of water[18]In the context of episodes of intense drought and food insecurity in the European Union, it is important to keep in mind that tobacco requires up to eight times more water compared to, for example, tomatoes or potatoes.[19]Water stress is increasing and severe drought events, which previously occurred at a frequency of once in a hundred years, are now expected to occur every five years.[20].

Managing cigarette filter waste is costly, dangerous and inefficient

Waste management services are heavily impacted by collection issues and challenges in managing cigarette butts. The emergence of cigarette butt collection companies is leading to a new waste stream consisting exclusively of cigarette butts, whereas they were previously mixed with household and municipal waste. Cigarette butts are hazardous waste that most smokers do not dispose of properly. Cigarette butts require waste minimisation, source reduction (removal of filters or toxic contents) and special waste treatment due to their toxicity. To date, there is no sustainable way to deal with cigarette butts. Tobacco company-funded anti-litter campaigns, including the distribution of bins and pocket ashtrays, have not had a significant impact on reducing tobacco litter.[21]. Conservative estimates put the management of tobacco product waste and the costs of marine pollution caused by these products in the European region at over US$2.6 billion (€2.62 billion).[22].

Recycled cigarette butts or bio-filters are not the solution

Industry-backed studies support cigarette butt recycling[23] cigarette filters, but they fail to prove their safety for humans or the environment. Indeed, even if the filters become biodegradable, they will continue to disseminate dangerous chemicals and metals [24].

Dangerous chemical toxins released by cigarette butts have raised concerns about leaving them in landfills, particularly because of the high metal content they contain. [25], or to incinerate them. In addition to the high cost of recycling hazardous products, it also presents health risks [26], whereas the precautionary principle should rather apply.

Finally, research [27] demonstrated that the industry's introduction of so-called ecological alternatives to cigarette filters essentially refers to marketing strategies and image politics. The latter aims to allow manufacturers to be present at the decision-makers' table in order to interfere in public health and sustainable development policies. In this respect, this is a violation of Article 5.3 of the World Health Organization Framework Convention on Tobacco Control (WHO FCTC), an international public health treaty ratified by the European Union and all member states and legally binding.

B. Opportunity and feasibility of a ban on filters

An easy-to-implement measure to achieve the revised targets of the Waste Framework Directive

The revision of the Waste Framework Directive is a unique opportunity to address cigarette filter plastics before they become pollution and prevent their entry into our ecosystem and the food chain. Eliminating cigarette filters would significantly reduce a major stream of highly hazardous waste, with a positive impact on human health and the environment. It would greatly improve the cost-effectiveness of the waste management system at EU level and significantly reduce the costs of negative externalities induced by the tobacco industry borne by EU governments and public authorities.

A ban on cigarette filters is feasible and necessary to ensure proper implementation of the waste hierarchy, as it promotes waste prevention. As demonstrated above, it would be consistent and coherent with the general principles of precaution and sustainability applicable to the environment. It would strengthen the protection of natural resources and preserve financial resources, with a beneficial impact on the economy, society and consumer safety. It would also contribute to the objective of the revised European Waste Directive to promote safer and cleaner waste streams.

Banning cigarette filters would be in line with European and international law

Such a ban could "denormalise" cigarette consumption, based on environmental concerns. It would contribute to achieving the objectives of the European plan to beat cancer [28], namely reducing environmental pollution - to which tobacco smoke contributes to a large extent [29] [30] and reduce the prevalence of tobacco use to 5% of the population by 2040. A ban on filters would be consistent with the WHO FCTC [31], as it would reduce the attractiveness of the product, particularly for young people (Articles 9 - 13 and 14 of the Treaty, relating to the regulation of the composition of tobacco products, the prohibition of tobacco promotion and the promotion of smoking cessation). It would protect the environment (Article 18 of the Treaty). Such a ban would also be in line with the ambition of the next global UN treaty on plastic pollution [32], which aims to eliminate single-use plastics (SUPs) and reduce virgin plastics – cigarette filters are derived from virgin plastics and primarily made from cellulose acetate, which is a single-use plastic. It would also be in line with the United Nations Sustainable Development Goals [33], since target 3.a of the Sustainable Development Goals agenda aims to “strengthen the implementation of the WHO FCTC in all countries”. According to WHO, while goal 3 is most obviously applicable to tobacco, many of the 17 goals have a direct or indirect link to tobacco control, including goals 1 (eradicating poverty), 5 (gender equality), 10 (reducing inequalities), 12 (responsible consumption) and 17 (partnerships for the global goals).

PROPOSALS ON THE LIABILITY OF THE TOBACCO INDUSTRY FOR ENVIRONMENTAL DAMAGE

1. Prevent any communication of the “socially responsible company” type, including in REP systems

Tobacco waste management programs resulting from the implementation of extended producer responsibility (EPR) [34] [35] must not become an opportunity for greenwashing for the industry. The current EPR system for tobacco product waste, introduced by the SUP Directive [36], has revealed its limitations. It violates the ban on tobacco advertising, promotion and sponsorship (Article 13 of the WHO FCTC). It implies financial liability in the form of payments to a public fund to support waste management, but it does not explicitly prohibit industry from being a stakeholder and presenting itself as socially responsible businesses (CSR). This is contrary to Articles 13 (prohibition of all advertising, promotion) and 5.3 of the WHO FCTC (on protecting public policies from tobacco industry interference).

The tobacco industry's display of a "socially responsible business" positioning is strongly condemned by the WHO [37], which recently reiterated its call for a ban on such communication, which falls under the definition of advertising, promotion and sponsorship of the WHO FCTC (Article 13). The tobacco industry's CSR is, according to the WHO [38], "an inherent contradiction, because the core activities of the tobacco industry are at odds with the goals of public health policies regarding tobacco control."

The role attributed to the tobacco industry in the management of cigarette butts in France is a good example of how, without clarification from the European Commission, Member States can entirely delegate to the tobacco industry the management, or part of the management, of its waste. France has entrusted all tobacco manufacturers, brought together in an eco-organization called ALCOME, with the management and communication around the pollution of its cigarette butts. ALCOME has already signed several dozen contracts with local authorities and is taking advantage of this to make smokers responsible for its pollution. [39].

Given the disastrous impact of tobacco products on human health, the environment and economic and financial systems, the tobacco industry should not be treated like any other industry. Imposing “social responsibility” obligations (such as EPR) on a tobacco producer could undermine tobacco control policies, particularly when this confers a positive image on the industry or allows for a form of promotion and sponsorship of its products. Also, The Smokefree Partnership coalition and its members recommend that the revised EU Waste Directive ensure that all EPR systems applying to the tobacco industry are strictly regulated to ensure compliance with Article 5.3 of the WHO FCTC.

2. Shifting waste management costs to manufacturers

Currently, with some exceptions, the costs of cleaning up tobacco products thrown on the ground are borne by taxpayers, even though they are the result of the tobacco industry's activities which created the problem.

One of the key strategies of tobacco companies' cigarette butt litter control programs is to ensure that the tobacco industry is not held liable for damages in order to protect them from practical or financial consequences. They therefore emphasize that cigarette and other tobacco product litter is "the responsibility of the user of the product for proper disposal."[40]The strategy of pointing the consumer is systematically observed when the industry is involved in communication activities on waste management, as is the case with ALCOME in France.

Given the flawed design of tobacco filters demonstrated above and their inherent toxic nature, the Smokefree Partnership coalition and its members believe that the European Union in the revised directive should apply the polluter pays principle to the tobacco industry and ensure that the costs are borne by it. The environmental damage and cover-ups of this industry have inexcusably delayed climate action. Recognising the environmental responsibility of the industry is essential to enable the environmental damage to be repaired, including by cleaning up the pollution caused.

3. Establish in each Member State a fiscal mechanism for waste management to be borne by manufacturers

The most effective measure to significantly reduce environmental damage from cigarette butts is the removal of the filter.

The introduction of a tax on cigarette butts in accordance with the polluter pays principle should also be considered, but it should not delay or prevent a ban on cigarette filters as single-use plastics.

Under the polluter pays principle, tobacco companies should bear proportional financial responsibility for cleaning up the waste they produce. WHO strongly encourages governments to impose an environmental tax on tobacco waste to hold the industry accountable for its environmental damage. [41]. Article 6 of the WHO FCTC on fiscal measures provides practical implementation guidelines based on good practices. These include the allocation of taxes to health promotion, while Article 19 of the WHO FCTC on tobacco industry liability provides for the compensation mechanism.

Some countries and cities have imposed an environmental tax on tobacco products [42]. In 2010, the city of San Francisco introduced a tax to fund the cleanup of cigarette waste, such as butts and plastic wrappers, as well as enforcement of litter restrictions and public education messages. The tax, which was 20 cents per pack in 2010, has since increased to 75 cents per pack. Other U.S. states are doing the same. [43]. About twenty countries have imposed some form of surcharge, levy or polluter charge on cigarettes and have earmarked it for various purposes. [44]. An environmental tax of 30 % on cigarettes, in view of the damage caused to the environment, is under consideration. The Commission should also provide for the introduction of ecotaxes on tobacco products - other than filters - with a high environmental impact, such as nicotine pouches or new tobacco and nicotine products.

4. Impose regulatory and mandatory provisions regarding manufacturers' liability for their products

The tobacco industry's voluntary initiatives are combined with intense communication and public relations actions aimed at improving the image of manufacturers to the detriment of public health and the environment. [45]. Entering into voluntary agreements would be contrary to Article 5.3 of the WHO FCTC Guidelines which prohibits such agreements with the tobacco industry unless they are part of a court or enforceable decision. They would also not be consistent with the obligations under Article 13 of the WHO FCTC concerning the prohibition of tobacco advertising, promotion and sponsorship, including in the form of “CSR” type communication. To ensure adequate accountability of tobacco manufacturers, the Smokefree Partnership and its members recommend that the measures in the revised EU Waste Directive applying to the tobacco industry should be regulatory and mandatory.

5. Establish an independent research funding mechanism to assess the environmental damage of tobacco

Estimating the environmental damage and costs of tobacco is crucial to holding the tobacco industry accountable for these, but data are very limited. For example, no research to date has examined the long-term effects of e-cigarettes. [46] on the environment, although these are plastic, electronic, disposable products, the manufacture of which requires a lot of energy and resources, and which are not expected to degrade for hundreds or thousands of years [47]. Most existing studies are subject to financial conflicts of interest as they are funded by the tobacco industry. However, research has shown how many studies funded by tobacco companies have results and recommendations influenced by this interested funding.[48]. Member States should therefore invest in further independent research in this area to support the development of public policies. In this perspective, The Smokefree Partnership coalition and its members recommend that funding sources for independent research into the environmental harm caused by tobacco and new tobacco products be explicitly identified and included in the revised Waste DirectiveThe tobacco industry could be required to pay for this research through environmental taxes.

6. Require tobacco manufacturers to provide the information needed to fill the data gap on the environmental impacts of their operations

In accordance with Article 5.3 of the FCTC and its implementing guidelines, Tobacco manufacturers should also be required to report information needed to "fill data gaps, with severe penalties for reporting false information." The tobacco industry standards, which are currently being developed by the European Financial Reporting Advisory Group (EFRAG), in line with the Corporate Sustainability Reporting Directive [49], could be another opportunity to include environmental disclosure requirements, such as product toxicity as well as marketing, sponsorship and research activities. These information measures should go hand in hand with monitoring by an independent third party.

7. Establish cooperation mechanisms between the Ministers of Health, Agriculture and the Environment to reduce the environmental harm of tobacco

Multi-sectoral collaboration is needed to address the environmental harm of tobacco. Addressing environmental and health concerns will require innovative cooperation processes between Member States. To optimise data collection on the environmental harm of the tobacco industry, the revised Waste Directive could propose innovative cooperation mechanisms between health, agriculture and environment ministers, while building on existing arrangements under the WHO FCTC (Articles 17, 18 and 19 of the WHO FCTC).

Keywords: Smoke Free Partnership, cigarette butts, waste, European directive, European Commission, filter, ban, environment, ecology, greenwashing

©Tobacco Free Generation

[1] A cigarette butt is made up of the filter and remaining tobacco from the smoked cigarette.

[2] Ocean Conservatory. Cleanup Reports. Available : https://oceanconservancy.org/trash-free-seas/international-coastal-cleanup/annual-data-release/

[3] Truth initiative. Why are cigarette butts the most discarded item on earth? Available : https://truthinitiative.org/research-resources/harmful-effects-tobacco/why-are-cigarette-butts-most-littered-item-earth

[4] NBCNews. J Rainey. Plastic straw ban? Cigarette butts are the single greatest source of ocean trash. (August 27, 2018). Available : https://www.nbcnews.com/news/us-news/plastic-straw-ban-cigarette-butts-are-single-greatest-source-ocean-n903661

[5] Global Journal of Environmental Science and Management. M Hazbehiean, N Mokhtarian, A Hallajisani. Converting the cigarette butts into valuable products using the pyrolysis process. (June 11, 2021). Available : https://www.gjesm.net/article_244343.html

[6] UNEP. UNEP, Secretariat of the WHO FCTC partner to combat microplastics in cigarettes (February 1, 2022). Available : https://fctc.who.int/newsroom/news/item/01-02-2022-unep-secretariat-of-the-who-fctc-partner-to-combat-microplastics-in-cigarettes

[7] Earth.org. Mr. Igini. Are microplastics harmful and how can we avoid them? (April 21, 2022). https://earth.org/are-microplastics-harmful/

[8] Science Direct. F Rebischung, L Chabot, H Biaudet, P Pandard. Cigarette butts: A small but hazardous waste, according to European regulation. Available : https://www.sciencedirect.com/science/article/abs/pii/S0956053X18305798

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[10] CNN Health. S Lazarus. Cigarette filters are the No.1 plastic pollutant ... and don't prevent cancer. https://edition.cnn.com/2019/01/24/health/dirty-truth-about-cigarette-filters/index.html

[11] Tobacco Control. Harris Bradford. (January 25, 2011). The intractable cigarette 'filter problem'. Available : https://tobaccocontrol.bmj.com/content/20/Suppl_1/i10

[12] Tobacco Control. K Evans-Reeves, Hathrin Lauber, Rosemary Hiscock. The 'filter fraud' persists: the tobacco industry is still using filters to suggest lower health risks while destroying the environment. (April 26, 2021). Available : https://tobaccocontrol.bmj.com/content/31/e1/e80

[13] Tobacco Tactics. Cigarette Filters. (December 13, 2021). Available: https://tobaccotactics.org/wiki/cigarette-filters/

[14] P 33. European Commission, DG SANCO. A study on liability and the health costs of smoking. (2008). https://health.ec.europa.eu/publications/study-liability-and-health-costs-smoking-0_en

[15] P 29. Global Center for Good Governance in Tobacco Control. Tobacco's toxic plastics: A global outlook. Available : https://ggtc.world/library/tobaccos-toxic-plastics-a-global-outlook

[16] P 4. Global Center for Good Governance in Tobacco Control. Tobacco's toxic plastics: A global outlook. Available : https://ggtc.world/library/tobaccos-toxic-plastics-a-global-outlook

[17] Corriere Della Serra. E Comelli. The “corsa” pazza dei prezzi? “Non c'è solo la guerra depends also on the siccità”. Available : https://www.corriere.it/buone-notizie/22_giugno_16/corsa-pazza-prezzi-non-c-solo-guerra-dipende-anche-siccita-bae15164-e3e0-11ec-8fa9-ec9f23b310cf.shtml

[18] Brussels.be. Survey on ashtrays: answers to the questions. (December 13, 2019). Available : https://www.brussels.be/ashtrayBXL#:~:text=It%20is%20important%20to%20note,on%20the%20environment%20is%20enormous

[19] P 3. WHO. Tobacco: poisoning our planet. (May 29, 2022). Available : https://www.who.int/publications/i/item/9789240051287

[20] La Repubblica. M Bussolati. Perché con la siccità dovremmo músico ache ache alluvioni. Available : https://www.repubblica.it/green-and-blue/dossier/siccita--gestione-acqua/2022/07/22/news/siccita_danni_economici_agricoltura_crisi_idrica-358646427/

[21] Tobacco control. EA Smith, EA McDaniel. Covering their butts: responses to the cigarette litter problem. (October 21, 2010). Available : https://doi.org/10.1136/tc.2010.036491

[22] P31. Global Center for Good Governance in Tobacco Control (GGTC). Tobacco's toxic plastics: A global outlook. Available : https://ggtc.world/library/tobaccos-toxic-plastics-a-global-outlook

[23] According to the Golden Holocaust, it is cheaper for cigarette companies to manufacture filtered cigarettes than unfiltered cigarettes of the same size. To find out more: https://ia802305.us.archive.org/21/items/geopolitique/Golden-Holocaust-La-conspiration-des-industriels-du-tabac.pdf

[24] Tobacco control. E Slaughter, RM Gersberg, K Watanabe, J Rudolph, C Stransky, TE Novotny. Toxicity of cigarette butts, and their chemical components, to marine and freshwater fish. (November 1, 2011). Available : https://tobaccocontrol.bmj.com/content/20/Suppl_1/i25

[25] P11. Global Center for Good Governance in Tobacco Control (GGTC). Tobacco's toxic plastics: A global outlook. Available : https://ggtc.world/library/tobaccos-toxic-plastics-a-global-outlook

[26] Treehugger. S Lebby. The Environmental Pros and Cons of Acetate. (August 6, 2021). Available : https://www.treehugger.com/the-pros-and-cons-of-acetate-5176132

[27] Tobacco control. EA Smith, PA McDaniel. Covering their butts: responses to the cigarette litter problem. (October 21, 2010). Available : https://doi.org/10.1136/tc.2010.036491

[28] Europe's Beating Cancer Plan. (February 3, 2021). Available: https://health.ec.europa.eu/system/files/2022-02/eu_cancer-plan_en_0.pdf

[29] European Respiratory Journal. A Ruprecht, C De Marco, P Pozzi, R Mazza, E Munarini, A Di Paco, P Paredi, Gi Invernizzi, R Boffi. Outdoor second-hand cigarette smoke significantly affects air quality. (May 26, 2016). Available : https://erj.ersjournals.com/content/48/3/918

[30] Tobacco control. G Invernizzi, A Ruprecht, R Mazza, E Rossetti, A Sasco, S Nardini, R Boffi. Particulate matter from tobacco versus diesel car exhaust: an educational perspective. Available : https://tobaccocontrol.bmj.com/content/13/3/219

[31] WHO. WHO Framework Convention on Tobacco Control. (May 25, 2003). Available : https://fctc.who.int/who-fctc/overview

[32] UNEP. What you need to know about the plastic pollution resolution. (March 2, 2022). Available : https://www.unep.org/news-and-stories/story/what-you-need-know-about-plastic-pollution-resolution

[33] WHO. (2019). Tobacco control & the sustainable development goals. https://www.euro.who.int/__data/assets/pdf_file/0020/340193/TOBACCO-CONTROL-AND-THE-SUSTAINABLE-DEVELOPMENT-GOALS_Edited.pdf

[34] Extended producer responsibility is a "polluter pays" concept that aims to make manufacturers responsible for the waste they put on the market. (Accessed 23 August 2022) Available: https://leshorizons.net/responsabilite-elargie-producteurs/

[35] In accordance with the polluter-pays principle, the European Union adopted a directive on single-use plastic products, including cigarette filters, in 2019. Among other obligations, this text requires tobacco producers to cover the costs associated with cleaning, transporting and treating cigarette butts and Member States to develop awareness-raising measures on this subject.

[36] EUR-Lex. Directive on the reduction of the impact of certain plastic products on the environment. (June 5, 2019). Available : https://eur-lex.europa.eu/eli/dir/2019/904/oj

[37] STOP. Talking Trash: Behind the Tobacco Industry’s “Green” Public Relations. (May 2022). Available : https://exposetobacco.org/wp-content/uploads/Talking_Trash_EN.pdf

[38] WHO. Tobacco industry and corporate responsibility… an inherent contradiction. (2004). Available : https://escholarship.org/uc/item/6kf7q7v9

[39] The eco-organization ALCOME, a greenwashing tool for the tobacco industry in France, (May 24, 2022) Available: https://cnct.fr/communiques/eco-organisme-alcome-outil-greenwashing-industrie-tabac-france/

See also: P 17. Global Center for Good Governance in Tobacco Control (GGTC). Tobacco's toxic plastics: A global outlook. (June 9, 2022). Available : https://ggtc.world/library/tobaccos-toxic-plastics-a-global-outlook

[40] Tobacco control. E Smith, P McDaniel. Covering their butts: responses to the cigarette litter problem. (October 21, 2010). Available : https://doi.org/10.1136/tc.2010.036491

See also: Raising awareness: The challenge is the action. Raising awareness through information helps to sustainably improve smokers' behavior and consequently reduce cigarette butts on public roads to the bare minimum. The systematic "good action" of smokers will be the main target. Consulted on August 22, 2022 Available: https://alcome.eco/responsabilite-elargie-du-producteur/

[41] P 7. WHO. Tobacco: poisoning our planet. (May 29, 2022). Available : https://www.who.int/publications/i/item/9789240051287

[42] Idem

[43] Tobacco control. JE Schneider, NA Peterson, N Kiss, AS Doyle. Tobacco litter costs and public policy: a framework and methodology for considering the use of fees to offset abatement costs. (March 12, 2011). Available : https://tobaccocontrol.bmj.com/content/20/Suppl_1/i36

[44] Hebrew Environment, Science & Policy Network. N Neve. מטפלים בבדלים – הצעת חוק חדשה תתמודד עם השלכות הסביבתיות של תעשיית הסיגריות. Treat the Cigarette Butts - a new bill will deal with the environmental consequences of the cigarette industry. (June 25, 2018). Available : https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3254943

[45] Tobacco control. E Smith, P McDaniel. Covering their butts: responses to the cigarette litter problem. (October 21, 2010). Available : https://doi.org/10.1136/tc.2010.036491

[46] ASH. YH Hendlin. For an earth free of tobacco waste. (April 22, 2017). Available : https://ash.org/earth-free-of-tobacco-waste/

[47] Brighthub. How Long Does it Take Plastic to Decompose? (February 21, 2011). Available : https://www.brighthub.com/environment/green-living/articles/107380/

[48] National Library of Medicine. YH Hendlin, M Vora, J Elias 1, PM Ling. Financial conflicts of interest and stance on tobacco harm reduction: a systematic review. Available : https://pubmed.ncbi.nlm.nih.gov/31095414/

[49] EUR-Lex. Proposal for a Directive as regards corporate sustainability reporting. (April 21, 2021). Available : https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52021PC0189

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