PROJECT SUMMARY The Family Smoking Prevention and Tobacco Control Act granted the FDA the authority to regulate and restrict tobacco advertising tactics that inaccurately convey reduced product risk, yet there is a dearth of up-to-date regulatory science to inform such regulations. Although FDA has restricted use of descriptors such as “natural” and “additive-free,” our research shows that the tobacco industry quickly pivoted to increase use of alternative, unregulated tactics. Greenwashing is one increasingly common tobacco marketing strategy in which products are portrayed as eco-friendly and/or natural. Our preliminary research indicates that greenwashing tactics may inaccurately convey modified product risk to consumers. To address this problem, we have developed a comprehensive and dynamic approach involving multi-modal cognitive and behavioral assessments. The overarching objective is to describe how cigarette companies use greenwashing to market their products, and test the effect of these tactics on both risk perceptions in an online sample and actual smoking behavior in a controlled laboratory study. Our proposed research focuses on young adults (age 18-29), because this is a key age for smoking initiation and escalation, and research has found that young adults may be more susceptible than older adults to greenwashing in cigarette ads. We aim to: (1) Identify specific greenwashing tactics used in cigarette ads, determine their prevalence across brands and sub-brands, and determine changes in these tactics over time; (2) Test the extent to which the greenwashing tactics identified in Aim 1 contribute to inaccurate modified risk perception in a large sample (N=1,500) using an online survey; and (3) Test the effect of greenwashing on behavioral economic demand and smoking topography in a laboratory-controlled cigarette self-administration study. Per the RFA, this application is unrelated to health warnings and focuses exclusively on advertising tactics that inaccurately convey modified product risk. This work connects to the Marketing Influences interest area, specifically, the priorities of “understanding why people become susceptible to using tobacco products...and transitions between experimentation, initiation to regular use and dual use” and “methods, measures, and study designs to best assess the impact of tobacco product advertising, and promotion restrictions on users and non-users of tobacco”. The data from the online cognitive assessment and laboratory- based behavioral study proposed in this research will clearly connect tobacco advertising features to product risk perceptions and actual smoking behavior. This work will provide FDA with an integrated set of evidence that identifies misleading greenwashing tactics that inaccurately convey modified product risk which can be used to inform regulatory action regarding restrictions of this type of advertising.

PROJECT SUMMARY The proposed research conducts multi-modal cognitive and behavioral experiments to document the effect of misleading advertising tactics on consumer risk perceptions and use behavior. This work informs FDA regulatory action by identifying misleading cigarette advertising tactics that inaccurately convey modified product risk.