The World Health Organization (WHO) points out that the tobacco industry creates or uses front groups to manufacture support for its agenda, as one of its main strategies to interfere in public policies. These groups present themselves as independent organizations—business associations, technical institutes, community entities, or civil society movements—but act to defend the commercial interests of the tobacco sector, often concealing their connections to the industry.1
Article 5.3 of the Framework Convention on Tobacco Control (WHO FCTC)[2 requires Parties to protect their tobacco control policies from industry interference. The guidelines for implementing this Article recommend that Parties identify links and record interactions between the industry and groups that support its interests, adopting safeguards to prevent these entities from influencing policymaking processes.3
In Brazil, at least two groups active in debates on electronic smoking devices (ESDs) present themselves as independent organizations but have points of contact with the tobacco industry. The first is the Directory of Information for Tobacco Harm Reduction (Direta), which organized a series of pro-vape demonstrations and was received several times by the Brazilian Health Regulatory Agency (Anvisa) during the process of reviewing the regulation of these devices.4 Currently, nothing on Direta’s website indicates an explicit connection with the industry,5 and its representatives claim to be independent consumers. However, according to a member of the association’s board, the creation of the entity was a “direct result” of two seminars held in 2019 and 2020 with sponsorship from Philip Morris Brasil.6 In addition, at least until 2024 the group’s website indicated a partnership with the World Vapers Alliance (WVA), created by the Consumers Choice Center (CCC), a group focused on promoting ESDs. The CCC, in turn, has received funding from companies such as BAT, Philip Morris, and Japan Tobacco International (JTI).7
The second is Tobacco Harm Reduction Brasil (THR Brasil), an organization that claims to be “dedicated to defending the rights of vapers”8 and that submitted a request to Anvisa calling for changes in the regulation on the issue.9 THR Brasil appears on the list of partners on the WVA website,10 which, notably, carried out a series of visits to the offices of Brazilian lawmakers in 2024 to advocate for the legalization of ESDs.4
In the context of tobacco farming, the Brazilian Tobacco Growers’ Association (Afubra) is, in theory, tasked with supporting its members—family tobacco producers in the southern region of the country. In practice, however, Afubra has historically defended industry interests alongside the Tobacco Industry Union (SindiTabaco),11 even when this may be detrimental to farmers. This is the case of the association’s position on the regulation of ESDs: it supports the possibility of producing and marketing these devices,12 even though the production of vapes requires significantly fewer tobacco leaves than the manufacture of combustible products.13 As a rule, Afubra’s actions tend to favor tobacco companies. For this reason, the organization is legitimized by the companies themselves as a representative of the sector’s interests, which facilitates its influence and recognition in society.11
These cases illustrate, in the Brazilian context, a global strategy of the tobacco industry, which consists of creating or supporting different types of organizations—such as “smokers’ rights” groups, producers’ associations, and service-sector entities—to advocate for positions aligned with its interests. In doing so, the industry seeks to influence public and political debate, often under the appearance of independent technical, economic, or social action. This reinforces the need for transparency in interactions between the industry and public authorities, in line with the guidelines of Article 5.3 of the WHO FCTC.3
- 1. World Health Organization. Tobacco Industry Interference - A Global Brief [Internet]. 2012. Available from: https://iris.who.int/server/api/core/bitstreams/4bae7c52-79c3-473c-b846-...
- 2. World Health Organization. WHO Framework Convention on Tobacco Control [Internet]. [cited September 11, 2025]. Available from: https://wkc.who.int/resources/publications/i/item/9241591013
- 3. a. b. World Health Organization. Guidelines for implementation of Article 5.3 [Internet]. Geneva: WHO; 2013 [cited March 25, 2026]. Available from: https://fctc.who.int/resources/publications/m/item/guidelines-for-implem...
- 4. a. b. ACT Health Promotion, Oswaldo Cruz Foundation, Global Center for Good Governance in Tobacco Control. Tobacco Industry Interference Index – Brazil | 2025 [Internet]. ACT Health Promotion; 2025. Available from: https://actbr.org.br/wp-content/uploads/2025/10/2025_TII-Index-Questiona...
- 5. DIRETA [Internet]. 2026 [cited March 26, 2026]. Home. Available from: https://www.direta.org/
- 6. Mathias M. Lobbying runs free in the final stretch of the decision on electronic cigarettes. O Joio e O Trigo [Internet]. December 22, 2021 [cited March 26, 2026]. Available from: https://ojoioeotrigo.com.br/2021/12/muito-lobby-na-reta-final-da-decisao...
- 7. Feifel LS Rafael Oliveira, Bianca. Tobacco caucus becomes a defender of “vapes” in Congress. Agência Pública [Internet]. January 16, 2024 [cited March 26, 2026]. Available from: https://apublica.org/2024/01/como-a-bancada-do-fumo-virou-defensora-dos-...
- 8. Tobacco Harm Reduction Brasil - Instagram page [Internet]. [cited March 26, 2026]. Available from: https://www.instagram.com/thrbrasil_org/
- 9. Brazilian Health Regulatory Agency. Partial Report of Regulatory Impact Analysis – Electronic Smoking Devices [Internet]. 2022 [cited March 26, 2026]. Available from: https://www.gov.br/anvisa/pt-br/assuntos/regulamentacao/participacao-soc...
- 10. Home - World Vapers Alliance [Internet]. [cited March 26, 2026]. Available from: https://worldvapersalliance.com/pt/
- 11. a. b. Mengel AA, Aquino SL de. The tobacco production chain as a field of disputes [Internet]. 2017 [cited March 26, 2026]. Available from: https://lume.ufrgs.br/handle/10183/177569
- 12. Interativa B. Afubra participates in a tobacco forum at Expointer. Afubra [Internet]. August 27, 2024 [cited March 26, 2026]. Available from: https://afubra.com.br/afubra-participa-de-forum-sobre-tabaco-na-expointer/
- 13. Vapor Curtain | Less tobacco and more nicotine: how the cigarette industry is planning crops for vapes in Brazil [Internet]. [cited March 26, 2026]. Available from: https://cortinadevapor.ojoioeotrigo.com.br/reportagem/menos-tabaco-e-mai...
