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Marketing Responsibility

Management Approach

Information required by procedures for product and service labelling


marketing responsibility

RAI’s operating companies are responsible marketers of age-restricted tobacco products. The operating companies comply with the marketing restrictions in the Family Smoking Prevention and Tobacco Control Act, enacted by Congress in June 2009.

RAI'S largest operating company, R.J. Reynolds Tobacco Company (R.J. Reynolds), has long abided by voluntary advertising restrictions set forth in the Voluntary Cigarette Advertising and Promotion Code, including:

  • No one depicted in cigarette advertising shall be or appear to be under 25 years of age;
  • Cigarette advertising shall not suggest that smoking is essential to social prominence, distinction, success or sexual attraction, nor shall it picture a person smoking in an exaggerated manner;
  • Cigarette advertising may picture attractive, healthy looking persons, provided there is no suggestion that their attractiveness and good health are due to cigarette smoking;
  • Cigarette advertising shall not depict as a smoker anyone who is or has been well known as an athlete, nor shall it show any smoker participating in, or obviously just having participated in, a physical activity requiring stamina or athletic conditioning beyond that of normal recreation; and
  • No sports or celebrity testimonials shall be used or those of others who would have special appeal to persons under 21 years of age.

In 1998, R.J. Reynolds and other major cigarette manufacturers agreed to comply with the marketing restrictions set forth in the Master Settlement Agreement (MSA). Among those restrictions are:

  • Bans on the use of cartoon images in advertising, promotion, packaging or labeling of tobacco products;
  • Bans on the use of billboards, stadium signs, transit signs and certain other outdoor advertising of tobacco products;
  • Bans on the use of tobacco-branded merchandise (such as caps and T-shirts);
  • Bans on the use of payments for the placement or use of tobacco products or brands in movies, TV programs, live recorded performances, videos or video games;
  • Bans on the use of non-tobacco brand names on tobacco products; and
  • Bans on licensing third parties to use or advertise any tobacco brand name in a manner that would constitute a violation of the MSA if done by the participating manufacturer itself.


RAI's operating companies maintain a database of adult tobacco consumers to facilitate marketing communications directly with adult tobacco consumers who have expressed an interest in receiving communications from the companies. To be added to this database, the adult tobacco consumer must certify that they are an existing consumer of tobacco products, are at least 21 years of age and wish to receive mailings and offers. The age of consumers who sign up through a brand website or the consumer relations center is verified using independent third-party sources that access and utilize a broad range of private, public and government data. For in-person consumer engagements, such as in retail outlets, bars and nightclubs, adult tobacco consumers are required to show a valid, government-issued photo identification showing proof of age in order to be added to the marketing database.

Every marketing mailing sent out contains information identifying ways for consumers to opt out of future communications. In addition, consumers are removed from the active mailing list after a period of inactivity if they do not redeem promotional offers or otherwise interact with our tobacco operating companies and brands.


RAI’s operating companies’ policies for placing print advertising are designed to limit youth exposure while exercising our constitutional right to communicate with adult tobacco consumers. The companies’ policies exceed the U.S. Federal Trade Commission’s guidance for advertising other age-restricted products, such as alcohol. As part of their policies, the operating companies:

  • Review audience-measurement data regarding the age of a publication’s readership,
    • Where data are available on a publication's readership aged 12 or older, the companies only advertise in magazines with readership of at least 85 percent aged 18 or older,
    • For publications where audience measurement data are available only for readership 18 and older, the companies advertise only if the median age of the audience is 23 or older;
  • Analyze the editorial content of the publications over time to assess whether the topics covered by such publications have adult appeal and focus;
  • Evaluate third-party advertisements that appear in those publications to assess whether such advertisements are for products that have adult appeal and focus; and
  • Assess such factors as the publication’s business stability, circulation dynamics and method of distribution.

Vapor products are subject to a different regulatory regime than cigarettes and smokeless tobacco. Nevertheless, R.J. Reynolds Vapor Company works to ensure its brand advertising placement is consistent with RAI and its operating companies’ commitment to limiting youth exposure to tobacco-related messages. All consumer advertising for vapor products indicates that the product contains nicotine, which is addictive. Any VUSE brand television advertising is placed only during programming viewed primarily by adults, according to Nielsen data or other reliable third-party sources. 


Every employee who interacts with adult tobacco consumers is trained to ensure that marketing safeguards and standards are adhered to in every interaction. Through comprehensive computer-based training, they learn how to follow policies, rules and procedures, as well as what constitutes an appropriate, successful engagement. Consumer-facing employees must successfully complete this training, as well as classroom training and role-playing exercises with a third-party assessor. Finally, these employees receive in-market observation and coaching from their managers in order to demonstrate mastery of the required skills and behavior.