Disclaimer
1.This article was submitted to 2Firsts by the authors. The views expressed in this piece are solely those of the authors and do not represent the views or positions of 2Firsts. 2Firsts publishes this content to encourage diversity of perspectives and informed dialogue within the industry.
2.The news headline, summary, and key points were prepared by 2Firsts for reader clarity, while the original title supplied by the authors has been retained for the main text.
Key Points:
The authors present the following key views and recommendations in this article:
1.Warn that several COP11 proposals led by high-income countries may not align with the realities of low- and middle-income countries (LMICs).
2.Say prohibition-focused measures on e-cigarettes, heated tobacco and nicotine pouches could expand illicit markets and reinforce the dominance of combustible cigarettes.
3.Note that “endgame” measures—such as generational bans and mandated low-nicotine cigarettes—are impractical for LMICs due to limited enforcement capacity and the absence of nationwide age-verification systems.
4.Highlight the persistent “10/90” research gap and raise concerns about the influence of private donors, especially Bloomberg Philanthropies, on policy development in LMICs.
5.Call for a global funding mechanism, similar to the Green Climate Fund, to support evidence-based and context-appropriate tobacco control measures in LMICs.
FCTC COP11: Rich Nations Set to Coerce Global South into Adopting Ineffective Policies
Samrat Chowdhery & Joseph Magero
As delegates gather in Geneva for the Eleventh Session of the Conference of the Parties (COP 11) to the WHO Framework Convention on Tobacco Control (FCTC) from November 17-22, 2025, a troubling dynamic, painfully familiar from global climate negotiations, is taking shape.
In the climate arena, this dynamic is defined by broken promises; developed nations repeatedly failed to meet their landmark $100 billion annual climate finance pledge, leaving the Global South, which contributed least to the crisis, to bear the brunt of climate impacts without the promised support. This gap between high-income country (HIC) pledges and low- and middle-income country (LMIC) reality has eroded trust and forced developing nations to divert scarce domestic resources to a crisis they did not create.
A stark parallel is now emerging in global health. At COP 11, the agenda is dominated by a suite of aggressive, top-down policy proposals championed by HICs and their well-funded philanthropic backers. While presented as the gold standard in public health, these measures are profoundly disconnected from the realities of the Global South.
For these nations in Africa, Latin America and Asia, which bear nearly 80% of the global tobacco burden, the COP 11 agenda risks becoming an exercise in futility and harm. Just as with climate, policies designed in Western capitals are being pushed onto countries that lack the capacity to implement them. It threatens to trigger a cascade of negative consequences, from empowering criminal networks to deepening economic hardship.
This raises a critical question: Is the global tobacco control movement, in its zeal, repeating the failures of climate action by bullying the Global South into adopting policies that are not only ineffective but actively detrimental?
Let’s review the four key issues around which this year’s conference will revolve.
War on "Harm Reduction" Forecloses Lifelines for Global South
A central battle at COP 11 will be fought over Agenda Item 4.5, which addresses novel nicotine products like e-cigarettes, nicotine pouches and heated tobacco. The FCTC Secretariat has provocatively framed the entire concept of tobacco harm reduction not as a public health strategy, but as a deceptive "tobacco industry narrative". This sets the stage for a global push towards outright prohibition.
For a wealthy nation with middling smoking rates and extensive, state-funded cessation services, a precautionary ban might seem logical. For the Global South, it is a death sentence for millions. In countries like Indonesia, where nearly two-thirds of adult men smoke, or across the WHO's South-East Asia Region, which has the world's highest smoking prevalence, safer alternatives represent a pragmatic and life-saving off-ramp for smokers unable or unwilling to quit.
A prohibitionist mandate from COP 11 would have disastrous outcomes in these regions. First, it would trigger the explosive growth of dangerous, unregulated black markets. LMICs, already struggling with limited state capacity and porous borders, cannot possibly enforce a ban on products for which consumer demand already exists. This would not only strip governments of potential tax revenue but would also eliminate all product safety standards, leaving consumers at the mercy of illicit suppliers.
Second, by treating all nicotine products as an equal evil, a ban inadvertently protects the dominance of the most lethal product on the market: the combustible cigarette. It is a policy that, in the name of public health purity, would deny the world's most vulnerable smokers a chance to escape the fire.
"Endgame" Illusion Designed for a Different World
Under Agenda Item 4.1, Parties will consider a menu of so-called "forward-looking" or "endgame" measures. These include radical policies such as generational sales bans (prohibiting sales to anyone born after a certain date) and mandating a reduction of nicotine in cigarettes to non-addictive levels.
While these policies may be viable in a handful of HICs with single-digit smoking rates and vast enforcement resources, they are a fantasy for the Global South. Implementing a generational ban requires a robust, nationwide age-verification system that is simply non-existent in LMICs. Regulating the nicotine content of every cigarette sold requires sophisticated laboratory testing and supply chain controls that are far beyond the capacity of most governments. Many of these nations are still struggling to implement the FCTC's foundational measures, such as effective tobacco taxes and comprehensive smoke-free laws.
Attempting to impose these "endgame" solutions to nations where smoking rates are still rising in some regions or demographics would lead to catastrophic negative outcomes. The most immediate would be a massive surge in illicit trade. A policy that makes legal cigarettes non-addictive or unavailable to entire generations would create an unprecedented business opportunity for smugglers providing full-nicotine illicit products. In states with weak enforcement, this would lead to a complete loss of regulatory control over the tobacco market.
Further, aggressive supply-reduction mandates, without locally proven and well-funded alternative livelihood programs for the millions of smallholder farmers in LMICs who depend on tobacco cultivation, would trigger severe economic dislocation and social unrest.
Unattainable Liability and Environmental Distractions
The agenda's disconnect from the reality of the Global South extends to industry accountability and environmental protection. The discussion on liability (Agenda Item 4.2) continues to focus on complex, North American-style litigation, a path that is functionally impossible for most LMICs due to prohibitive costs and systemic legal barriers. This focus diverts attention from more feasible administrative and fiscal liability mechanisms like "polluter pays" levies that could actually hold the industry accountable and generate sustainable domestic funding.
Similarly, while the focus on environmental protection (Agenda Item 4.3) rightly addresses the global scourge of plastic cigarette filter pollution, it downplays the far greater environmental burden borne by the Global South during tobacco cultivation. For LMICs, the most pressing issues are deforestation, soil degradation and water pollution caused by growing the crop. Pushing LMICs to manage post-consumer waste without addressing the upstream devastation is unjust and unachievable.
Elephant in the room: The “10/90” research gap
At the centre of this malaise is a long-understood research funding gap between the west and Global South. In his seminal analysis of tobacco globalisation in 2000, Derek Yach et al identified a stark imbalance: while the tobacco industry had effectively globalised its marketing and research to capture developing markets, tobacco control research remained largely fragmented within Western contexts (the ‘10/90’ gap).
Yach termed this gap a “failure of science,” arguing that although the necessary scientific knowledge existed, the failure lay in adapting and applying it to non-Western political and social realities. As a result, interventions developed in the West such as taxation or cessation programs often faltered in LMICs due to the absence of locally grounded implementation research.
Appallingly, as with the number of smokers, this ratio too hasn’t budged much in 25 years despite FCTC and private donors’ efforts. However, a fallacy has been created by China producing massive volumes of research through its tobacco monopoly, whose findings are dubbed government research since China National Tobacco Corporation (CNTC) and the regulatory body (State Tobacco Monopoly Administration) are the same entity. For emerging products, the ratio is much worse, with almost 95% research being conducted in western nations.
No surprise then that most of FCTC’s recommendations and guidelines are based on research in specific settings and among a small subset of tobacco users, whose findings, and the policy recommendations that follow from them, are grossly mismatched with environments and experiences of majority of people who use tobacco or nicotine.
Call for a New Funding Paradigm
Though FCTC offers development assistance through various programmes, the funding gap – in range of $13.8 billion to $27.4 billion depending on various estimates – is too large for the effort to be of consequence. To fill this vacuum, FCTC’s flawed and harmful agenda is now being bankrolled and driven by a narrow group of private donors, most notably Bloomberg Philanthropies, which has committed over $1.5 billion to a rigid, prohibition-only model of tobacco control.
This funding flows through a network of partner organisations that lobby governments in the Global South to adopt these pre-defined, one-size-fits-all policies, often ignoring local context, consumer behaviour and contradictory evidence. This approach has been rightly criticised as a form of "philanthro-colonialism," where the priorities of a wealthy Western donor are imposed on sovereign developing nations.
This model has led to demonstrable failures. In Pakistan, a Bloomberg-backed push for a massive tax hike, without accounting for illicit trade, led to a 44% increase in the black market, costing the government revenue while smoking rates remained stagnant. In the Philippines, a government agency admitted to receiving funds from Bloomberg-backed charities to implement their preferred policies, raising serious questions about regulatory capture and conflicts of interest.
These are not isolated incidents; they are the result of forcing policies based on Western-centric research onto environments where they are ineffective and harmful. These private donors come with their own narrow, prohibitionist agendas, bypassing multilateral processes and use their financial clout to force policies onto environments where they are ineffective, backfire, and cause harm.
Philanthro-colonialism to Institutional Support
It is time to end this damaging dependency. Like in climate action, where the principle of differentiated responsibility is recognsed, global tobacco control needs a new, sustainable, and equitable funding mechanism. Rich nations, which for centuries profited from the tobacco trade and whose multinational corporations continue to drive the epidemic in the Global South, have a historical responsibility.
Instead of allowing private, agenda-driven philanthropy to dictate policy, HICs – even in this era of dwindling development finance, keeping the enormous cost of 8 million lives lost annually in mind – must commit to a significant financial obligation for global tobacco control, analogous to the Green Climate Fund. Such a fund, managed transparently and not by private interests, would empower LMICs to build the capacity they actually need: to implement the foundational, evidence-based FCTC measures, while also developing contextually effective measures such as regulated access to safer alternatives with risk-proportionate taxation.
Just as financing has always remained on the top of every climate COP agenda, including the one taking place in Brazil, the FCTC COP too should rework its priorities to close the funding and research gaps and promote inclusion than push unrealistic and damaging west-based policies onto voiceless poor nations, who may sign on under moralistic pressure, but return home with little interest or resources to meaningfully implement them.
Authors
Samrat Chowdhery is a nicotine policy expert and Director of Harm Reduction Policy & Research based in India. Joseph Magero is the Chair for Campaign for Safer Alternatives and a harm reduction advocate focused on safer nicotine alternatives in Africa.
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