Researchers found that 55% of oral nicotine direct-mail advertisements used claims like “tobacco leaf-free” pouches or highlighted the “simple approach” of introducing extracted nicotine from tobacco leaf into lozenges. In the past, the makers of cigarettes like American Spirit have relied on strikingly similar terms to market their products as “additive free,” “natural,” or “simple.” Because these descriptions made American Spirit cigarettes appear to be a healthier alternative to other cigarettes, the FDA required marketing copy for American Spirit to remove the terms “additive free” and “natural.”
Similarly, terms like “tobacco-free” in oral nicotine marketing could suggest products are healthier and lower risk to consumers. Using language that signals a tobacco product is “free of a substance” may meet one criteria of an unauthorized modified risk claim under FDA rules.