SFP submission to the UNEP Plastics Secretariat ahead of INC-3

Tuesday, 15 August 2023

On 14 August 2023, the Smoke Free Partnership made its official submission to the United Nations Environment Programme Plastics Secretariat ahead of the third session of the Intergovernmental Negotiating Committee to develop an international legally binding instrument on plastic pollution.


Our submission was divided into two parts.

  1. Input on the potential areas of intersessional work to inform the work of INC 3

Our first submission discussed the potential areas of intersessional work to inform the activities of INC-3. We emphasized the necessity of considering the "polluters pay principle" and the industry's liability instead of accepting voluntary contributions from the industry. We recommend that governments design financing mechanisms that require mandatory payments from the tobacco industry to compensate for past, present, and future plastic pollution and the associated management and treatment costs, estimated globally at around 20 billion USD per year.

We also suggests recognizing tobacco taxes as a means to mobilize domestic resources and as a significant source of development financing. We highlight the public health benefits of increasing tobacco taxes, which could potentially lead to decreased consumption, especially among the youth, and a reduction in respiratory deaths. We propose that revenues generated from these taxes could be dedicated to health promotion.

Furthermore, we call for specific solutions to address the toxic plastics associated with tobacco, such as cigarette butt pollution and increasing e-cigarette waste. We insist that any intersessional work in the tobacco sector should be protected from the commercial and vested interests of the tobacco industry to preserve the integrity of the WHO FCTC and national tobacco control goals.


  1. Elements not discussed at INC-2, such as principles and scope of the instrument

Our second submission discusses elements that were not addressed at INC-2, focusing on the principles and scope of the UN Plastics Treaty.

Regarding the scope of the upcoming treaty, we insist on the inclusion of Tobacco Plastics as they are highly toxic, not substitutable, and not recyclable. Furthermore, the tobacco industry cannot be relied on to provide solutions.

Regarding principles, we propose the adoption of the precautionary principle, as stated in Article 3 of the United Nations Framework Convention on Climate Change (UNFCCC) and Article 15 of the Rio Declaration on Environment and Development, in the upcoming plastics treaty. This principle advocates for taking precautionary measures to prevent or minimize the causes of climate change and its adverse effects, and to prevent environmental degradation, even in the absence of full scientific certainty. Applying this principle to cigarette butts implies treating them as hazardous waste, not to be recycled further, due to their known chemical and heavy metal toxicity to plant/animal life and human health. Such policy decisions can be made without waiting for further studies on the potential for environmental or long-term harm to humans.

We also propose the adoption of the polluters pay principle, as outlined in Article 16 of the Rio Declaration. This principle encourages national authorities to promote the internalization of environmental costs and the use of economic instruments, with the polluter bearing the cost of pollution. It aligns with the WHO FCTC Article 6 Guidelines, which recommend the use of effective tobacco taxes to internalize the costs and protect tobacco tax policies from the vested interests of the tobacco industry.

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