Hold the tobacco industry to account

Liability can help governments hold the tobacco industry responsible for harms and costs caused by its products and conduct.

Tobacco Industry ActorsCompanies, affiliates and lobbyists

Start by identifying the actors behind tobacco-industry interests

Companies, affiliates, lobbyists, and other actors may shape markets, public narratives and policy environments.

Identify tobacco industry actors

Harms costs and conduct at issue

Tobacco products and industry conduct generate health, economic, environmental, social, and governance harms and costs.

Healthcare and economic costs

Public systems absorb direct and indirect costs linked to tobacco use.

Youth, nicotine, mental health, and novel products

Nicotine dependence and evolving products create new challenges for health and regulation.

Environment, waste, and livelihoods

Production and consumption generate environmental costs across supply chains and communities.

Human rights and labor harms

Liability can intersect with rights, labor conditions, and harms within tobacco supply chains.

Tax avoidance, evasion, and illicit trade

Financial and trade practices can undermine public revenue and tobacco-control objectives.

Industry interference, misconduct, and deception

Policy influence and misleading claims can delay or weaken effective public-health action.

Article 19 pathways

Article 19 calls on Parties to consider legislative action or promote existing laws to deal with criminal and civil liability, including compensation where appropriate.

Later COP decisions and Expert Group work have advanced administrative and other non-judicial approaches to implementation.

Three questions guide implementation

What does the national system already provide, how can administrative liability operate, and how can tobacco-related costs be recovered?

01 / Self-assessment

Identify what the national system already provides

Review existing legal authority, institutions, sanctions, compensation arrangements, and cost-recovery tools, then identify the gaps.

Explore details

Map legal mandates, responsible institutions, available sanctions, compensation arrangements, financial measures, and implementation gaps.

02 / Administrative liability

How can liability operate beyond courts?

Where domestic law permits, competent authorities or tribunals may determine liability, impose administrative sanctions and provide or facilitate remedies.

Explore details

Consider administrative orders, penalties, licensing consequences, corrective measures, and appeal safeguards.

03 / Cost recovery

How can governments recover attributable costs?

Estimate attributable costs, identify the legal basis for recovery and examine available mechanisms, including levies, fees, and surcharges where legally available.

Explore details

Explore cost recovery methods, cost calculators, and evidence that puts industry claims in context.

From treaty provision to practical implementation

See how Article 19 implementation has developed alongside GGTC research, tools, and convening on tobacco-industry liability.

WHO FCTCYearGGTC
WHO FCTC adopted; Article 19 addresses liability.
2003
COP5: Expert Group established.
2012
COP6: Expert Group mandate extended.
2014
COP7: Civil Liability Toolkit advanced.
2016
2020
Tobacco Industry Accountability and Liability in the Time of COVID-19
COP10: Expert Group re-established.
2024
Towards Health with Justice: Making the Tobacco Industry Accountable through Administrative Liability

Parts of the research were presented at a COP10 Article 19 side event.

Supporting item: Implementation of Article 19 of the WHO FCTC: Liability — COP10 resource material.
Expert Group work continues under the renewed mandate.
2024–2025
Expert Group report and membership.
COP11: further work on non-judicial liability and cost recovery.
2025
Non-Judicial Pathways to Article 19 Implementation: Accountability & Liability

Side event / policy material

GGTC BRIEF on Liability (Article 19 of the WHO FCTC)

Evidence tools and guidance

Browse GGTC and partner materials for Article 19, administrative liability, cost recovery, and safeguards.

Showing 30 resources

Preventing Tobacco Industry Interference: A Toolkit for Advocates and Policymakers (2023)

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Implementation of Article 19 of the WHO FCTC: Liability Resources Package (2024)

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Accountability and Liability of the Tobacco Industry (2023)

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Tobacco Industry Accountability and Liability as a COVID-19 Response (GGTC, STOP) (2020)

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An Inherent Contradiction: The Tobacco Industry’s Environment, Social & Governance Activities (2022)

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How can people living with NCDs make tobacco companies pay? (2021)

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