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An Assessment of the KFDA statement

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An Assessment of the KFDA statement

  • 2019-12-06

On 7th June, 2018, KFDA issued a statement on heatde tobacco products based on measurements performed in their own laboratories. KFDA tested 3 heatde tobacco products. Let’s see what problems there are in their statement.


They have measured 9 Harmful and Potentially Harmful Constituents, as well as nicotine and “Tar”. The 9 HPHCs belong to a list created by the WHO as a priority list for mandatory reduction. To measure those levels, KFDA applied 2 well known smoking regimes (defined by their puff volume and frequencies), the ISO and the more intense Health Canada regime. KFDA results confirm significant reductions of HPHCs in heatde tobacco products compared to cigarettes – but omit to discuss them. In their discussion, KFDA mentions that heatde tobacco products also contain carcinogens, like benzopyrene and benzene. What they fail to mention is that the levels measured are more than 10 times lower compared to the levels present in cigarette smoke. In fact, their own data shows that these 2 carcinogens are reduced by more than 95 % (for benzopyrene) and more than 99 % (for benzene) when comparing the levels of heatde tobacco products to the top 5 most sold cigarette brands in Korea. When considering the 9 measured HPHCs, the average reduction of heatde tobacco products compared to Korean cigarettes (top 5 most sold brands) is more than 90 %. And this is precisely what heatde tobacco products were designed to do: reduce substantially the levels of HPHCs, the compounds that were identified throughout years of research on tobacco smoke as being the likely cause of smoker’s diseases.


KFDA uses “Tar” to compare product – a value that gives no indications on the content of HPHCs of products. The KFDA statement then makes comments about the respective levels of “Tar” in heatde tobacco products. To understand why this comparison has no scientific ground and is deceptive, it is important to understand the meaning and origin of “Tar”. “Tar” is simply the total weight of solid and liquid residue in cigarette smoke after the weight of nicotine and water has been subtracted. It was originally introduced by the tobacco industry as a mean of quality control for cigarettes, to ensure consistency in the amount of smoke delivered by each cigarette. But “Tar” fails to give any indication about the composition of the smoke, and in particular the amount of HPHCs. This is why many governments and public health organizations have supported removing “Tar” measurements as being misleading to consumers. As heated tobacco products will not burn tobacco sticks, solid black carbon particles which are present in cigarette smoke won’t be found in heatde tobacco vapor. In short, science shows that the vapor from heated tobacco products is fundamentally different to cigarette smoke. Any comparison of cigarette “Tar” and the weight of aerosol/vapor produced by heatde tobacco products is therefore a deception and misleading, as the comparison is done between the weights of 2 mixtures with very different compositions and toxicities

As for nicotine, KFDA commented that nicotine in heatde tobacco products is similar to cigarettes, which is absolutely correct and intended as heatde tobacco products are meant to be a better alternative for smokers who would otherwise continue to smoke. In this context, product acceptance by adult smokers is essential. And to maximize product acceptance, the levels of nicotine should mimic cigarettes as closely as possible.

The study results thereby contribute significantly to the totality-of-the-evidence showing that switching completely to heatde tobacco is likely to present less risk of harm than continuing to smoke cigarettes.

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