Re: Docket No. FDA-2026-D-1817 (91 Fed. Reg. 11980, Mar. 11, 2026) – “Flavored Electronic Nicotine Delivery Systems (ENDS) Premarket Applications—Considerations Related to Youth Risk”

RAI Services Company (“Reynolds”) submits this response to the Center for Tobacco Products’ (“CTP”) draft guidance named “Flavored Electronic Nicotine Delivery Systems (ENDS) Premarket Applications—Considerations Related to Youth Risk,” 91 Fed. Reg. 11980 (Mar. 11, 2026) (“Draft Guidance”).¹

The draft guidance doubles down on a flavor-prohibitionist playbook that harms Americans by handing over the marketplace to unregulated Chinese manufacturers whose illicit products evade FDA review and endanger youth. Today, these illicit Chinese products constitute about 86% of the market—and worse, they explicitly target youth by, among other things, incorporating popular cartoon characters and built-in video games. This bears repeating: 86% of the American vape market is comprised of illicit Chinese vapes. The guidance does nothing to correct this. Instead, it entrenches the exact failures it purports to address.

The guidance is a gut punch to American companies committed to playing by the rules. Responsible American manufacturers languish in a regulatory purgatory, whereas foreign companies that evade FDA and flood the market with illicit products have thrived. The path to protecting youth is enforcement against illicit products—not severely restricting American products. The draft guidance gets this exactly backwards.

In addition, FDA has a historic opportunity to help adults quit smoking. FDA can help move adult smokers away from combustible cigarettes to less risky ENDS products—and it should make this transition easier, not harder. But the guidance gets this backwards as well. Studies show that adult smokers who use flavored ENDS products like vapes and e-cigarettes are significantly more likely to quit smoking than those who use tobacco-flavored ENDS or no ENDS at all. Flavors drive the switch, and steer adult smokers away from smoking combustible cigarettes. But FDA and its guidance get in the way of that switch. The guidance doubles down on a so-called “comparative efficiency standard,” which is an unscientific bureaucratic fiat that requires companies creating flavored vapes to meet a heightened standard: They must prove that their non-tobacco flavored ENDS products statistically outperform tobacco-flavored products in head-to-head switching studies. This is the wrong comparison, and it leaves the vast majority of the public health benefit on the table. Millions of smokers who would switch for a fruit flavor will never switch for tobacco, and the comparative-efficacy standard writes them off as if they do not exist. FDA should make it simpler—not harder—to get these products to adult smokers who want to stop smoking cigarettes. Unfortunately, the draft guidance endorses an approach that makes it harder. In fact, it makes it virtually impossible, as demonstrated by the near-universal denials for non-tobacco flavored ENDS products. If Congress had wanted to ban such products, it would have said so. But Congress did not, and it is not for a regulatory agency to substitute its own judgment and policy preference for that of Congress.

Reynolds is committed to ensuring that no youth ever uses a tobacco or nicotine product, but the draft guidance does nothing to achieve that goal. Reynolds offers these comments to make the case for a regulatory framework that protects youth through aggressive enforcement, while giving adult smokers access to the flavored products that maximize their chances of quitting combustible cigarettes for good.

Read the full comment

¹ RAIS submits this comment on its own behalf and on behalf of its affiliated tobacco companies. RAIS coordinates regulatory compliance for the subsidiary companies of �������� Inc. (RAI), including R.J. Reynolds Tobacco Company; American Snuff Company, LLC; Santa Fe Natural Tobacco Company, Inc.; R.J. Reynolds Vapor Company; and Modoral Brands Inc. References to “RAIS” or “Reynolds” in this letter may refer to RAIS itself and/or its affiliated RAI subsidiaries, as applicable.

WINSTON-SALEM, N.C., (March 5, 2026) — The �������� companies (��������) announced a forward-looking commitment to invest more than $3.2 billion across its U.S. operations by 2030, reinforcing its long-term focus on value creation and American manufacturing. The investment began in 2024 and is expected to support more than 2,000 direct and indirect jobs across ��������’s operations and U.S. supply network, including roles tied to recent manufacturing expansion and innovation initiatives.

The announcement marks the launch of Growing Tomorrow; ��������’s campaign focused on driving business performance and delivering sustainable returns. The campaign reinforces ��������’s position as a leading organization with the largest multicategory nicotine product portfolio in the U.S.

“Growing Tomorrow reflects the investments we’re making today in American manufacturing and jobs,” said David Waterfield, President and CEO of �������� Inc. “By expanding manufacturing capabilities and strengthening our workforce, we’re building on more than 150 years of investment in the U.S. economy to ensure our competitiveness for the future.”

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Growing Performance

��������’s investment supports the organization’s continued evolution toward a predominantly smokeless future, building on momentum in high-growth categories. The organization continues to expand its innovative smokeless portfolio with a multiyear investment focused on:

• Modernizing and expanding U.S. manufacturing
• Scaling innovation and production
• Strengthening domestic supply chains
• Advancing workforce capabilities and operational excellence

More than $200 million has already been invested in U.S. manufacturing over the past two years as part of this commitment.

Growing Innovation

��������’s research and manufacturing hubs in Winston-Salem, North Carolina, and operations in Clarksville, Tennessee play a central role in the organization’s transformation, supporting a broad, science-led portfolio designed to meet the evolving preferences of adult nicotine consumers. Planned investments will further modernize facilities, expand production capabilities, and reinforce ��������’s competitive position for sustained performance.

Innovation remains foundational to that future. �������� employs hundreds of scientists in Winston-Salem, supported by approximately $100 million in annual research and development investment, with the majority focused on innovative smokeless categories.

Growing Careers & Community

Today, �������� employs more than 4,300 people across the U.S., with roles spanning advanced manufacturing, engineering, science, skilled operations, and corporate functions. Continued investment in technology, training, and workforce readiness extends the organization’s economic impact beyond its direct operations through a broad U.S. supply network.

“Investing in growth means investing in people,” said Borgia Walker, Senior Vice President and Chief People Officer at �������� Inc. “We’re focused on building capabilities, expanding opportunity, and helping our employees grow meaningful careers as we grow business performance.”

��������’s impact extends beyond its direct business operations to agriculture and local economies nationwide. North Carolina, the nation’s leading tobacco producing state, anchors this ecosystem, with farmers and agricultural partners remaining integral to the organization’s success and domestic supply chain. In 2025, �������� was the largest purchaser of U.S. tobacco leaf from American farmers.

Together, these investments reinforce ��������’s long-term strategy focused on disciplined growth, sustained returns, and shared value creation. This approach strengthens U.S. manufacturing, supports good-paying jobs, and helps build resilient communities.

Growing Tomorrow is how �������� delivers on that commitment today and for decades to come.

About �������� Inc.���������� Inc. is a wholly owned subsidiary of the global BAT Group and the U.S. parent company of R.J. Reynolds Tobacco Company, Santa Fe Natural Tobacco Company, Inc., American Snuff Company, LLC, R.J. Reynolds Vapor Company, and Modoral Brands Inc. References to “��������,” “the group,” “the company,” “the organization,” “we,” “us,” and “our” are simply for convenience and are not intended to imply or suggest that the subsidiaries’ businesses are operated other than as separate, distinct businesses. To learn more about �������� Inc. and its operating companies, please visit��www.reynoldsamerican.com.

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Media Contact:

mediaoffice@rjrt.com

The article explores how Reynolds is navigating a rapidly evolving industry landscape while remaining focused on long-term growth and environmental responsibility. It also emphasizes the company’s commitment to investing in advanced technologies and building a culture of continuous improvement.

This feature is a testament to the work being done across the organization to drive progress and lead with purpose. It offers a behind-the-scenes look at how Reynolds is shaping the future of its industry.

Employees and stakeholders are invited to read the full article and learn more about Reynolds’ vision and impact.

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Custom Content from WSJ is a unit of The Wall Street Journal Advertising Department. The Wall Street Journal news organization was not involved in the creation of this content.��

In a recent episode of podcast, Kara Calderon, Head of Underage Access Prevention at Reynolds, and Stephanie Sikorski, CEO of TruAge, spoke about the collaborative efforts to prevent underage access to tobacco and nicotine products.

The conversation highlighted how partnerships between manufacturers, retailers, and technology providers are contributing to lower rates of underage tobacco use. Reynolds enforces strict marketing protocols and maintains contractual obligations with nearly 183,000 retail outlets, requiring age verification at point-of-sale to ensure products are sold only to legal-age consumers. TruAge, a nonprofit, mission-driven organization, offers a universal age verification solution that supports responsible retailing across the convenience industry.

“We are now at record lows of underage vapor usage,” Kara shared, citing 2024 data from the National Youth Tobacco Survey. “Middle school usage is down to 3.5%, high school usage to 7.8%, and underage cigarette use has dropped to an all-time low of 1.4%.”

Stephanie added context from the retail environment, noting that convenience stores process over 54 million age-restricted transactions daily, with more than 40% of those involving age-restricted products. TruAge’s technology helps retailers verify age securely while providing actionable insights into carding rates and ID validation.

Despite the progress, both leaders acknowledged a growing challenge: the rise of illicit disposable vapor products, often flavored and marketed in ways that appeal to youth. Kara cited a 2,200% increase in youth use of these unregulated products, calling it the biggest hurdle facing underage access prevention today.

Stephanie emphasized the importance of proactive solutions like TruAge, which not only verify age but also help shift the narrative around convenience retailing. “TruAge was built to show proof points,” she said. “We want convenience to be in the headlines for the right reasons, showing how to do responsible retailing right.”

Listen to the full episode to learn more about how Reynolds and TruAge are working together to protect youth and support responsible retailing:

To learn more about Reynolds’ Underage Access Prevention efforts, click here.

Through THR, we aim to create A Better Tomorrow by Building a Smokeless World—one where adult nicotine consumers have access to smokeless product alternatives that are potentially less risky than combustible cigarettes.

Our latest clinical research on oral nicotine products is a key milestone in that journey. The study, published in , analyzed how adult nicotine consumers engage with nicotine pouches and examined patterns such as consistency of use and nicotine uptake. The findings build on a growing body of evidence showing that smokeless products can serve as potentially less risky alternatives for adult smokers.

This study evaluates how adult nicotine consumers interact with nicotine pouches—across different nicotine strengths and flavors—and finds consistent patterns in how they are used. The findings reinforce why nicotine pouches are increasingly considered viable as potentially less risky product alternatives for adult smokers. They contain no tobacco leaf, involve no combustion, and produce no emissions. The data, now peer-reviewed and under FDA scientific review, strengthens the growing evidence base supporting the role of smokeless product alternatives in potentially reducing the public health impact of smoking.

RELATED: Fostering Transparent Collaboration to Reduce Tobacco Harm

This isn’t just about publishing science. It’s about putting our principles into practice.

We believe the success of THR depends on three things: expanding product choices, advancing scientific understanding and acceptance, and building solutions grounded in real-world behavior. This study supports all three. It adds to the growing body of evidence regulators rely on, reinforces the importance of science-based decision-making, and demonstrates that adult nicotine consumers benefit from access to a wider range of potentially less risky product alternatives that better suit their preferences. Most importantly, it reflects the kind of rigorous, transparent engagement we see as essential to driving the THR conversation forward.

While smoking rates are at historic lows, at least 30 million Americans still choose to use combustible cigarettes. Expanding the range of high-quality, science-backed, non-combustible product alternatives is essential to potentially reducing the public health impact of smoking.

What makes this research especially meaningful is not just what it shows about the use of nicotine pouches—but what it reflects about our approach: a commitment to clinical science, behavioral research, and proactive engagement with public health stakeholders. This study is one of many efforts to build understanding around THR. Through research like this, we aim to demystify smokeless product categories, address their misperceptions, and support informed choices for adult nicotine consumers concerning these products.

Our commitment is clear: we’ll continue to publish, share, and engage—because helping adult nicotine consumers make informed choices about alternative products is how we move toward A Better Tomorrow.

To learn more about our approach to Tobacco Harm Reduction, visit the Reducing Harm��page on��ReynoldsAmerican.com.

RELATED: The Path to Tobacco Harm Reduction

The global BAT organization has a mission to create A Better Tomorrow by Building a Smokeless World and aims to reach 50 million adult consumers of its smokeless products globally by 2030.

In the video above, Susie Gharib, senior special correspondent at Fortune Brand Studio, interviews BAT’s chief financial officer Soraya Benchikh about BAT’s role in advancing Tobacco Harm Reduction.

for the original interview with Benchikh in the Fortune Brand Studio.

The WaterHub® is an advanced water recycling facility and product of H2O Innovation projected to reclaim more than 60 million gallons of water a year—equivalent to the annual water supply of approximately —reducing Reynolds’ environmental impact and advancing the global BAT Group’s sustainability ambitions. Utilizing the latest technology, it captures a combined wastewater stream from the plant, treats it to North Carolina reclaim water standards, and then reintroduces it as intake water for the factory utilities—reducing the intake of fresh, valuable drinking water at the facility.

“Today marks a significant milestone in Reynolds’ sustainability journey and demonstrates our long-term commitment to environmental stewardship,” said Bernd Meyer, executive vice president of operations at the Reynolds organization. “With the WaterHub now operational, we expect to reduce water withdrawn at the Reynolds Operations Center by more than 40%, which in turn is anticipated to reduce water withdrawn across the global BAT Group by approximately 6%.”

The WaterHub is a lighthouse project in the global BAT Group, significantly advancing the the global Group’s sustainability agenda through its scale and impact. Through the WaterHub, Reynolds is contributing to the global BAT Group’s goal of reducing water withdrawn by 35% across global operations.

One of the few projects of its size in the United States using advanced water reclamation technologies, the WaterHub enables Reynolds’ operating facilities to reduce dependence on potable water for factory utility operations, conserving water in Forsyth County’s Yadkin-Pee Dee River Basin.

“The WaterHub is a prime example of how innovation can advance both sustainability and resilience,” said Guillaume Clairet, chief operations officer at H2O Innovation. “By supporting partners like Reynolds in conserving water and achieving their environmental goals, we’re proud to play a role in their journey toward water positivity.”

The surrounding WaterHub site will serve as a sustainability showcase for the organization and include a 1300 square foot native garden with over 400 plants of 24 different species to promote biodiversity and multiple sustainable technology installations.

Reynolds received a SEAL Business Sustainability Award in the Environmental Initiatives category for the WaterHub project and was recently recognized with an Award of Excellence by Winston-Salem/Forsyth County Utilities for its Industrial Waste Pretreatment Program for 2024. The Reynolds Operations Center also maintains Alliance for Water Stewardship certification, a globally applicable framework for sustainable water management to better understand water use and impacts.

For additional information on Reynolds’ water stewardship efforts and commitment to sustainability, read the 2024 �������� Sustainability Summary. To learn more about the WaterHub, visit .

Photos and video footage are available for download in our media gallery. Photos are linked and videography , using the password: WATERHUB (case sensitive).

THR is an approach to improve public health outcomes by focusing on what we believe is one of the most important movements for America’s health agenda – reducing the harm associated with smoking combustible cigarettes.

Our commitment to our mission of creating A Better Tomorrow^TM by Building a Smokeless World necessitates an even stronger commitment to pragmatic solutions that help advance paths to reduce the health impact of our operating businesses.

There are over one billion smokers worldwide and 30 million of them live right here in the U.S. In any group that large, there will be a wide spectrum of opinions and priorities. Some adult smokers are uninterested in quitting tobacco altogether. Those adults deserve access to science-backed information about potentially reduced risk options available today.

RELATED: Fostering Transparent Collaboration to Reduce Tobacco Harm

So, what exactly is THR? It’s a public health strategy that creates opportunities to improve health outcomes in America. By empowering adult smokers with knowledge about potentially reduced risk alternatives, they can make informed decisions regarding their consumption of alternative nicotine products.

Public misperceptions surrounding potentially reduced risk products pose a challenge in reducing the health burden of cigarette smoking. Our focus is to address these misperceptions by educating and engaging with key stakeholders on the scientific evidence supporting the potential benefits of potentially reduced risk products as compared to combustible cigarettes. THR accounts for where the tobacco and nicotine markets are today, where the market is heading, and for the innovative technology that has become more commonplace in the last few years. From modern oral products, like nicotine pouches, to tobacco heating products and e-cigarettes, there are more options than ever for those adults who want to continue to use tobacco and nicotine products while exploring alternatives that have potentially reduced risk compared to combustible cigarettes.

Why now? Smoking is at a near historic low. Adult smokers are embracing these potentially reduced risk alternatives, and they deserve the information about potentially reduced risk products that allows them to make the best choices for themselves. In fact, since 1970, the rate of adult smoking has fallen more than 70%, but of adults that still smoke tobacco products, including non-combustible products, more than 79% use combustible cigarettes. This number will likely remain higher than it could be if there is a lack of access to alternatives with potentially less risk for adult smokers who are uninterested in quitting tobacco altogether.

Nothing happens in a vacuum, which is why our approach to Tobacco Harm Reduction has four key pillars, all of which are crucial to having a positive impact on America’s public health:

1. Better Regulation: Using guidance grounded in science to foster sensible regulation that keeps pace with innovation.
2. Better Alternative Choices: Continued innovation allows the industry to bring new, potentially reduced risk alternatives to adult smokers who are uninterested in quitting tobacco products altogether something other than traditional combustible cigarettes.
3. Better Solutions: By working together with anyone who shares the common goal of improving public health in the US, we can find new solutions only made possible through collaboration.
4. Better Understanding: An unwavering commitment to THR requires leveraging sound science to inform adult smokers on potentially reduced risk alternatives.

These four pillars enable us to pursue our most important goal – finding a Better Way to A Better Tomorrow^TM.

In the coming weeks, we’ll dive more deeply into each of these important pillars and work to provide you with a better understanding of Tobacco Harm Reduction and why it is so important.

To learn more about Tobacco Harm Reduction, and Reynolds’ commitment to creating A Better Tomorrow by Building a Smokeless World, visit the Reducing Harm page on ReynoldsAmerican.com.

At ��������, underage access prevention (UAP) is more than a policy; it is a core principle that drives every facet of our business. We are resolute in our commitment to ensuring that our products are not accessible to individuals under 21. This steadfast dedication influences our practices, technology, and collaborations with stakeholders across the board.

Our aim is unambiguous: We do not want our products in the hands of underage individuals. Period. This conviction propels us to operate with the highest level of responsibility, forging strong partnerships with regulators, policymakers, and retail partners. Our aim extends beyond simply complying with industry standards—we strive to set them.

In our pursuit of excellence, we leverage cutting-edge technology, trusted data, and robust marketing controls to enhance our underage protection measures. By integrating the latest scientific advancements and technological innovations, we are able to address emerging challenges and continually refine our strategies to safeguard youth.

Our vision for “A Better Tomorrow” is not just about transitioning adult smokers to potentially reduced-risk alternatives; it’s also about establishing the highest industry standards for preventing underage access. We are heartened by the significant decline in underage smoking and vaping rates, which is a testament to the collective effectiveness of our initiatives to keep these products out of the hands of youth.

A cornerstone of our strategy involves stringent contractual agreements with retailers. We require them to enforce strict age restrictions on the sale of tobacco and nicotine products, including rigorous age verification at the point of sale. This approach has achieved an impressive 99.9% compliance rate, reflecting our commitment to preventing the sale and distribution of tobacco products to minors.

Our dedication to underage access prevention is further reinforced through ongoing training and responsible marketing practices. We take a proactive approach to restrict our advertising to media where at least 85% of the audience is over 21, as verified by independent third parties. Employees of the �������� organization are continually engaged in training programs focused on Retailer Compliance, Responsible Marketing, and Underage Access Prevention. Additionally, we support TruAge, a digital solution that enhances the security and reliability of age verification processes for adult tobacco consumers. We have also been an active supporter of the We Card program since its inception in 1995. This program provides retailers with essential materials and training to help prevent the sale of tobacco and nicotine products to minors.

We are vigilant in ensuring that our marketing and advertising content does not portray underage activities or imply that using our products is crucial for social status or success, and our advertising practices strictly avoid the use of celebrities or individuals who might appeal to youth.

At ��������, our commitment to underage access prevention is always ongoing. We are dedicated to continually working with regulators, policymakers, and retail partners to enhance our strategies and maintain the highest standards of integrity and responsibility. For more information about our unwavering dedication to underage access prevention, visit our dedicated page at ReynoldsAmerican.com. Together, we are committed upholding the highest standards of responsibility and protect the well-being of our youth.

In the recent Packaging Digest article, Wesley Jones, Senior Director, Packaging & Materials; Laya Horton, Director, Packaging Development; and Michael Davis, Master Scientist, Materials Development, speak to the initiatives we have underway to make our packaging more sustainable.

Read the original article on Packaging Digest by visiting .

Keep reading to find a copy of the full article below.

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��������’s Sustainable Packaging Swap

Swapping packaging materials and design components increases portfolio packaging recyclability and decreases virgin resource use.

By Wesley Jones, Senior Director, packaging & materials at ��������

At a Glance

• A packaging change by R.J. Reynolds Tobacco Co. was key to parent �������� topping 90% recycle-ready packaging.
• ��������’s plan to ‘Build a Smokeless World’ with new product entries will bring new circular economy challenges.
• The company is collaborating with key suppliers to find packaging solutions and inspire future innovation.

�������� is championing circular economy principles by swapping and reducing product packaging materials to increase recyclability and reduce use of virgin materials. The packaging trades have resulted in over 90% of the packaging in the �������� organization’s portfolio being recycle-ready and the use of fewer finite resources.

One fundamental substitute has been critical to achieving this milestone: swapping the foil inner bundle in most R.J. Reynolds Tobacco Company (RJRT) cigarette packs.

In the previous packaging used by RJRT, foil-lined paper was incorporated inside a paper box. The recent switch substitutes the inner bundle with paper, instead of a foil-paper lamination, thereby making both the liner and box paper-based and increasing recyclability. All packs are enclosed in a polypropylene wrap for benefits such as product freshness to maintain a consistent product experience. This wrap must be removed by the adult consumer prior to recycling.

“This is a significant packaging advancement for �������� given that R.J Reynolds Tobacco Company is the organization’s largest operating company. Not only was the conversion to a paper liner the right thing to do for the planet, but it also makes sound business sense,” said Laya Horton, director, packaging development, with the �������� organization.

The new RJRT packs continue to be made from paperboard certified by the Programme for the Endorsement of Forest Certification, advancing sustainable forest management. Furthermore, 95% of cigarette packs across the portfolio are labeled to educate adult consumers on proper waste disposal and recycling.

The paper-based packs have begun appearing on retail backbars across the country and will continue rolling out through the year.

A ‘Smokeless World’ brings challenges & solutions.

New category products that support our vision to create “A Better Tomorrow” by “Building a Smokeless World” rely on different resources, presenting unique challenges in sourcing materials, production, and responsible disposal. Our operating companies are consistently working to improve circularity and to create less overall waste.

For example, previously, R.J. Reynolds Vapor Company reduced the use of virgin plastics by removing the polypropylene outer wrap on Vuse Alto Pod and Power Unit vape products, helping to keep approximately 165,000 pounds of plastic out of landfills. But the company didn’t stop at removing the plastic wrap, as Alto’s packaging is also made of 100% recycle-ready cardboard. While we are proud of this progress, we recognize that there is still work to be done to fully integrate sustainable practices and improve circularity.

The polypropylene wrap removal for Vuse Alto Pod and Power Unit has been completed, and the updated packaging is available nationwide.

“We are continuously researching and developing innovative ways to simplify our packaging to lessen our material use. Where able, removing packaging materials that do not affect the product’s quality or adult consumer experience, is a great stride forward in minimizing ��������’s environmental impact,” said Michael Davis, Master Scientist, Materials Development with the �������� organization.

These packaging swaps support ��������’s circular economy strategy, which encompasses the organization’s commitment to simplifying packaging to improve recyclability, and to reduce the use of virgin materials and finite resources. RJRT’s foil-to-paper improvement additionally supports the organization’s goal of having 100% recycle-ready packaging by 2025.

Circular economy efforts continue.

Despite design advancements aimed at increasing the recyclability of packaging, infrastructure to recycle many technically recyclable materials remains largely unavailable. Addressing this gap is essential to fostering a circular economy with a self-sustaining ecosystem of materials.

Like many other consumer goods organizations, �������� faces ongoing challenges in sourcing and identifying food-grade alternative materials to achieve 100% recycle-ready packaging. In response, the organization recently hosted its inaugural Supplier Sustainability Summit at its largest manufacturing facility, the Reynolds Operations Center outside Winston-Salem, North Carolina. The two-day event brought together senior leaders and sustainability experts from top key suppliers, underscoring their essential role in �������� achieving its sustainability ambitions. By collaborating early and closely with suppliers, the �������� organization aims to leverage its expertise and capabilities in the development of additional innovative packaging solutions.

“�������� was really successful in bringing multiple suppliers from different areas together and the discussions were really fruitful,” said Diogo de Almeida, regional sales director at Amcor, a key packaging supplier to ��������. “We all have things that we can learn from �������� and hopefully collaborate towards achieving fantastic results in the future for the planet and for all of us.”

�������� portfolio products and packaging are subject to extensive regulation, which substantially limits product and packaging changes. All product and packaging changes are implemented in compliance with all applicable regulations.

Learn more about our packaging environmental sustainability initiatives by visiting our website at www.reynoldsamerican.com/product-stewardship/.