Background: Tobacco-related promotional content on social media often features young-looking influencers, models, or brand ambassadors who are appealing to youth; their posts often have inconsistent disclosures of partnerships with tobacco brands and lack age-restrictions prohibiting access to users under 18 or 21 years of age. These examples demonstrate violations of the U.S. Federal Food and Drug Administration (FDA) marketing restrictions. Methods: Marketing granted orders issued by the FDA to RJ Reynolds, Logic Technology, NJOY and Phillip Morris as part of the Premarket Tobacco Product Applications (PMTA) review process were qualitatively analyzed. Marketing practices that the tobacco companies intended to adhere to (e.g., refrain from using young-looking influencers in marketing materials) were documented. Perceived age of 55 micro-influencers who promote e-cigarette products on Instagram were assessed by 15 undergraduate student raters. Results: Despite the existing regulations of tobacco-related online marketing, the use of models or influencers and overall social media marketing is not prohibited, which leaves room for potential use of loopholes. The tobacco companies that were issued marketing granted orders set different age limits for the models to be considered young-looking and not to be used in marketing materials. The perceived age of the 55 influencers assessed by the raters was between 21-30, which is below the age limit proposed in several PMTA applications. Conclusion: Tobacco product online marketing, especially on social media, is underregulated. Strengthening tobacco marketing regulations, along with partnering of policymakers with social media platforms on establishing and maintaining effective tobacco-restriction policies, could help reduce proliferation of youth-appealing marketing of tobacco products.
Keywords: Tobacco products; influencers; marketing; promotions; social media.
Despite the existing regulations of tobacco-related online marketing, the use of models or influencers is not prohibited leaving room for potential violations of marketing restrictions and use of loopholes.Several tobacco companies that were granted marketing orders by the FDA stated in their PMTA applications that they would not use young models in their marketing; however, it is unclear what the implications are for deviating from this marketing practice since it is supported by the FDA but is not required.Cross-border advertising of tobacco products, especially on social media, is underregulated. This is concerning considering presence of international net of influencers, brand ambassadors and models on social media who expose their followers to tobacco promotional content inside and outside of their country’s border.