Heated Tobacco Products: Use and Regulation in Pakistan
Author: Alishba Naeem Ansari (Research Assistant)
The Heated Tobacco Products (HTP) are alternatives to common cigarettes that use aerosols containing nicotine and tobacco. The producers of HTPs claim that it is less harmful compared to common cigarettes as tobacco is heated up to 350° and not burned (600°) like conventional cigarettes. However, citing lack of sufficient evidence World Health Organization (WHO) cautions against concluding that HTPs are less harmful (WHO, 2020).
Comparison with Conventional Cigarettes
Independent studies from Germany, Netherlands and United Kingdom have found that although level of toxicants are low in HTP emissions, additional toxins are found in the smoke of HTPs. As for absorption of nicotine in blood, level of absorption (nicotine delivery) is less for HTPs than conventional cigarettes with exception of IQOS (WHO, 2020). Given these findings, the Conference of the Parties to the Framework Convention on Tobacco Control (WHO FCTC) recognizes HTPs as “tobacco products” subject, to the provisions of WHO FCTC (WHO, 2020). Regardless of the degree of nicotine delivery and emission of toxins, the addictive nature of nicotine cannot be overlooked.
State of HTP acceptance around the World
HTPs are categorized as Reduced-Risk Products (RRP) alongside E-cigarettes and Vapes and are regarded as instrumental in harm reduction strategy and quitting (cessation aids) by Tobacco Industry. However, in disguise of marketing slogans like “heat not burn” and “harm reduction” the HTPs use is being normalized around the world (Janjua & Naqvi, 2020). For example, United States recently authorized IQOS sale in the country (Center for Disease Control and Prevention, 2022). While some countries have resorted to ban E-cigarettes and HTPs alike, others have resorted to devise regulations that control its growth. India, Australia, Brazil, Norway and Singapore are among the countries that have banned it.
HTP Regularization in Pakistan
HTPs are unofficially available in Pakistan and not restricted or banned. The Ministry of National Health Services Regulations and Coordination in Pakistan proposed to regulate and legalize the products through a Statutory Regulatory Order. The SROs having been approved by the federal cabinet in December last year (Business Recorder, 2022). However, the legalization of HTPs shall also benefit the large tobacco companies in Pakistan. There are only three dominant companies in the tobacco industry as listed in Table:1, of these the two that make the most of market share (Sabir et al., 2022) are subsidiaries of multinational companies that have heavily invested in HTPs. The Company A holds second most market share and has been planning to bring HTPs in Pakistan (Abbas, 2020). Although it has not brought HTPs officially, the product is being sold both online and at stores. Being unregulated there is even no custom duty being collected for HTPs as observable from Table: 2.
Table: 1. HTP Industry linkage with Pakistan’s Tobbaco Industry
Heated Tobacco Products Industry
International and Domestic Scenario
Market Share in Pakistan
(Sabir et al., 2022)
Heated Tobacco Product
Company C (Pak – based)
Table: 2. Custom Duty on Import of Tobacco Commodities
Ministry of Finance and Revenue (Customs Duty on Imports)
S.R.O. 966(l)/2022 – 30th June, 2022
Category of Tobacco Commodity
Custom Duty (Regulatory)
Tobacco, partly or wholly stemmed/ stripped
Cigars, cheroots, cigarillos and cigarettes, of tobacco or of tobacco substitutes
Manufactured tobacco and manufactured tobacco substitute
The existing Tobacco taxation in Pakistan also needs further improvement. The FED on cigarettes in Pakistan is less than WHO recommended at least 70% of retail price. This is one of the reason why Pakistan scored only 1.13 on Cigarette Tax Scorecard (Tobbaconomics, 2022). Increasing taxation and price of tobacco products is proven to increase spending on household necessities, reduce consumption and eventually disease burden (Ghaus et al., 2019). The recent increase in excise duty on cigarettes (See Table: 3) shall not only increase revenue but reduce consumption as well.
Table: 3. Increase in Excise Duty on Cigarette
Federal Board of Revenue
S.R.O. 178(1)/2023 – 14th February, 2023
Type of Cigarette
Price Increase (PKR)
From – to
Increase in Excise Duty
41 – 101
130 – 330
As Pakistan proceeds to regulate HTPs, the WHO recommendations regarding it need to be incorporated in the system effectively. WHO recommends to “tax HTPs at the same level as cigarettes on a per-unit basis, regardless of tobacco content” (World Health Organization, 2021). Countries that have adopted this approach include Azerbaijan, Colombia, Georgia, Israel, Japan, Ukraine and West Bank and Gaza Strip.
Once brought under regulatory oversight for all RRP retailers (online or store based and including HTPs) should be required to acquire license for selling such products and custom duty should be introduced on acquiring them.
As per SPDC estimates based on GATS – Pakistan 2014 survey, adult tobacco users make up 19.7% of the population i.e. 31 million (15 years above) (SPDC, 2022). As no recent survey is available and no accounts of RRP usage are available either, prevalence of tobacco usage by age groups needs to be monitored for devising better regulations and taxation policies.
Note: SPRC has also conducted a webinar on Tobacco Taxation and Social Policy which can be viewed here.
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Business Recorder. (2022, December 10). Unregulated spread of vaping products: Govt urged to introduce ‘smart regulation’ to insulate children. Business Recorder. https://www.brecorder.com/news/40213643/unregulated-spread-of-vaping-products-govt-urged-to-introduce-smart-regulation-to-insulate-children
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World Health Organization. (2021). WHO technical manual on tobacco tax policy and administration.