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Promotion of NTPs in Japan: How Advocacy Groups Secure Public Visibility?
Why is the new tobacco device receiving such high public exposure in Japan?
Is there a possibility that other countries will follow suit or even imitate it?
Will Japan's promotion of new tobacco products shift in the future?
Author | Charlotte Yu
Philip Morris' HNB (heat-not-burn) device, IQOS, was launched nationwide in Japan in 2016, sparking the HNB market in the country.
Currently, the three main HNB products being sold in Japan are glo by British American Tobacco and ploom by Japan Tobacco (JT). All three companies have extensively advertised their products through online banners. In fact, advertisements for IQOS and ploom have even appeared on the free streaming platform "TVer".
In Japan, traditional tobacco receives different treatment. Due to the self-regulatory standards of the industry association, advertisement of tobacco products is completely banned on television, and similar promotional content cannot be published online. Even the leading tobacco company in Japan, JT, cannot show pictures of people smoking cigarettes, and can only feature vague "impression advertisements" along with content about "smoking etiquette" and "smoke control measures" to reach the public. (Elf bar employs similar advertising strategies in the UK by using the indirect approach of promoting "disposable product recycling.")

Many individuals within the traditional cigarette industry denounce the prevalence of tobacco advertisements circulating online as "double standards." However, manufacturers argue that these are not technically "tobacco" advertisements, but rather promote "devices" instead. Whether it is through online stores or waste disposal, HNB and vape devices are categorized as "small household appliances".

Why is the new tobacco device receiving such high public exposure in Japan? Is there a possibility that other countries will follow suit or even imitate it? Will Japan's promotion of new tobacco products shift in the future?
Media: Different Standards of Control
As of March 2021, TVer has a monthly active user base of approximately 17 million with around 180 million views. With such a large platform, ploom first launched its advertising campaign in February 2020, followed by IQOS in March 2021.
In the heated tobacco market, IQOS has consistently dominated with an overwhelming 70% market share. Ploom is estimated to hold a mere 10% share and is trying to reverse the situation by advertising on emerging and promising platforms. IQOS, meanwhile, is not backing down either. This advertising platform has become a battleground where industry leaders strive to gain a competitive edge.
This seems a bit counterintuitive: why is the new type of tobacco able to appear so freely in Japan's mainstream media?
In fact, without clear legal provisions regarding novel tobacco devices, media judgments on the scale of regulation vary.
The spokesperson for internet advertising giant Yahoo has stated that both the tobacco component and device component of the HNB product can be advertised, with a continuous assessment of the existing ads' impact on users and society.

JT's Plume advertisement is being aired on ABEMA, which is invested in and provided with content by TVer and Asahi Television. Both companies stated during interviews that they "cannot review individual advertisements".
Google, on the other hand, takes a different stance. Google believes that HNB falls under its advertising policy category of "dangerous products or services," along with cigarettes and vapes, thus prohibiting businesses from placing ads including HNB devices.
According to observers and industry insiders, the policies of these giants are not static but rather fluctuate over time. This is because the decision-making process within these companies is not as lengthy as policy changes, and is primarily driven by business and public relations considerations. As commercial entities, companies like Google and Yahoo are more adaptable and will adjust their admission criteria accordingly.
Overall, the internet advertising channel is extremely friendly towards HNB devices. This relaxed approach even spills over to other types of new tobacco products outside of HNB, such as British American Tobacco and the recently launched zero-nicotine disposable products by RELX in Japan. The advertising visuals are almost indistinguishable from those of typical technological products. E-cigarettes are able to enter the view of potential consumers in this country as a beautiful, fashionable, and avant-garde way of life - completely different from the unsettling content of traditional tobacco warnings.

Controversy Surrounding "Double Standards" and Legal Basis
However, it seems that this "bonus" enjoyed by the new tobacco industry will obviously not satisfy the strictly regulated "cousin" traditional tobacco industry, with the latter openly declaring this situation as a "double standard". A senior executive from a business television network once stated that while there is a call to take tobacco advertisements off TV, the proliferation of heated tobacco products (HNB) advertisements on the internet is being overlooked, which is illogical.
Is it reasonable to treat advertisements for "traditional tobacco" and "new tobacco devices" differently in the context of Japan?
A spokesperson for the Japan Interactive Advertising Association (JIAA), a nonprofit organization aimed at standardizing online advertising, stated during an interview that as long as advertisements do not violate legal boundaries and comply with the self-regulatory standards set by the industry association, "we believe there is no issue.
However, he also acknowledged that they have indeed discussed in internal meetings of the association whether there is a substantial difference for consumers browsing advertisements between "traditional tobacco" and "new tobacco devices".
Dr. Tien Yuangui, Assistant Director of Epidemiological Statistics Department at Osaka International Cancer Center, made a similar argument stating, "There is no point in distinguishing between purchasing HNB devices and actually smoking, as the two are inherently connected.
Therefore, classifying HNB devices as "small household appliances" and separating them from "cigarettes" is somewhat of a loophole and a bit of a stretch. More than one dealer in Japan has told 2FIRSTS that such a loophole relies on the years of lobbying by the team behind the country's nicotine dominator, traditional cigarettes.

However, academia and others have also provided different perspectives on the matter. Professor Motohiro Hashimoto from the Faculty of Law at Chuo University in Japan believes that the difficulty in curbing the proliferation of such advertisements on the Japanese internet lies in "freedom of speech." He has previously stated that smoking by adults is a legal behavior. Therefore, he argues that "the judgment of tobacco products should first and foremost be left to individuals.
Stricter in Future?
One of the strongest arguments in Japan's support for the new tobacco device "Network Exposure Freedom" is that internet advertisers have the means to confirm the age of their audience and deliver targeted advertisements, thereby avoiding any moral or legal complications.
Dr. Tian Yuangui points out that simply preventing minors from being exposed to advertisements is not enough. The purpose of advertising regulation is to prevent the harm caused by smoking on health. Considering the environmental changes brought about by new products such as heated tobacco, he believes that it is time to reconsider the content of regulations, including advertising.

Such relaxed regulations have certainly helped HNB products gain a dominant position in the Japanese market over the past decade. However, the crucial question remains: are these new tobacco alternatives, including HNB, actually reduced-risk products? What kind of impact do they have on health? Can they truly assist adult smokers in quitting smoking? On these matters, further research is needed to provide more conclusive evidence. It seems that Japanese regulators are also awaiting additional evidence to determine their next course of action, including the implementation of "zero nicotine" regulations.
2FIRSTS will continue to track the promotional activities and regulatory policies related to the new tobacco in Japan and around the world.
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