Swedish Match

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Image 1: Swedish Match General snus

Swedish Match is a Swedish tobacco company that manufactures and sells snus (image 1), moist snuff, cigars, chewing tobacco and matches. Philip Morris International (PMI) bought the company in 2022.

The company used to sell cigarettes, but decided in 1999 to divest its cigarette business to Austria Tabak.1 Lennart Sundén, then President and CEO of Swedish Match, said at the time:

“Cigarette consumption, the industry’s most dominant source of revenue, is declining or has reached a plateau in most Western countries. For Swedish Match therefore, the divestment of our cigarette operations was a natural step. We were a strong player in local markets, but a very small player compared with our main competitors.”2

In September 2021, Swedish Match announced that it would be selling its US cigar business and focus on its oral products.34 Plans to sell were put on hold in March 2022.5

In May 2022 Philip Morris International made an offer of US$16 billion to buy the whole company.67 On 11 May the board of directors of Swedish Match recommended that its shareholders accept PMI’s offer.8

As of 10 November 2022, PMI had acquired 86% of the company, and Swedish Match Directors recommended that the remaining shareholders offer to sell their shares to PMI, via its Netherlands subsidiary Philip Morris Holland Holdings (PMHH).910 On 28 November 2022 PMI announced that it held over 90% of the company, meaning it could buy the remaining shares under compulsory purchase rules and take Swedish Match off the stock market.11

Market Share

Swedish Match’s markets for snus, its main product, are Sweden, Norway and the United States (US), although in 2010 the company aspired to become the “global smokefree leader”.12

In 2010 the company held around 80% of the market in Western Europe (mainly in Norway and Sweden) but it has gradually lost market share following the entry of transnational tobacco companies on the Scandinavian snus market.13 By 2019 Swedish Match held less than 60%. For details see Cigarette Companies Investing in Snus.

In the US, Swedish Match remains the third biggest manufacturer of snus and moist snuff with around 10% market share in 2019. Its main competitors are market leader Altria, and Reynolds American (since July 2017 wholly owned by British American Tobacco).1415

Key Brands

In 2021, the company’s key snus brands were listed on “Smokefree” web page:16

  • Sweden – General, Göteborgs Rapé, Kaliber, , Kronan, and Ettan .
  • Norway – General, General G.3, The Lab, Nick & Johnny
  • US – General

Similarly to cigarettes, snus brands are available in different price segments, in particular premium and value price categories.

Swedish Match also sells snus-style nicotine pouches which do not contain tobacco leaf and so are not regulated as tobacco products in most countries. Its leading brand in the global market is Zyn. The large transnational tobacco companies have more recently moved into this rapidly growing market. For details see Nicotine Pouches.

Employees/Board Members: Past and Present

In June 2008 Lars Dahlgren became the Chief Executive Officer (CEO) of Swedish Match. Thomas Hayes became President of the US division in 2020, having previously held other leadership roles at the company.

A full list of the current company’s Board of Directors can be accessed here and the current management team here.1718

Other people that are or have been associated with the tobacco company:
Markus Ersmark Johan Gabrielsson Tomas Hammargren Cecilia Kindstrand Lars Olof Lofman Lars-Erik Rutqvist

Partnerships and Affiliations

Lorillard

In 2006 Swedish Match entered into a joint venture with Lorillard (the third largest cigarette manufacturer in the US at the time) to develop Swedish-style snus for the US market,19 but this joint venture was terminated at the end of 2009 following unsatisfactory results.20

Philip Morris International

In February 2009 Swedish Match entered into a joint venture with Philip Morris International (PMI) to “commercialize Swedish snus and other tobacco products worldwide, outside of Scandinavia and the United States”.21 This joint venture was dissolved in 2015, allegedly because of lack of demand for snus in the test markets.22

American Lobbyists

In January 2018, the Louisville Courier Journal reported that records of the Kentucky Legislative Ethics Commission showed that some of the highest paid people working at the Kentucky Assembly, were lobbyists paid to influence the State government by large corporations, including tobacco companies.23 The records named two lobbyists that listed Swedish Match North America as a client:24

  • Katherine W. Hall
  • Patrick M. Jennings

European Smokeless Tobacco Council

In 1989, Swedish Match (then known as Svenska Tobaks), co-founded the lobby group European Smokeless Tobacco Council (ESTOC).25

Since 2017, ESTOC no longer appears to be active.

Eliminating Child Labour in Tobacco Growing Foundation

Swedish Match is a member of the Eliminating Child Labour in Tobacco Growing Foundation (ECLT).26 In addition to Swedish Match, ECLT Board members include the International Tobacco Growers Association, British American Tobacco (BAT), Imperial Tobacco, Japan Tobacco International (JTI), and PMI, amongst others. The ECLT has a partnership with the International Labour Organisation (ILO), a United Nations (UN) agency, focussed on issues related to labour such as international labour standards, social protection and unemployment.27

NordCham Philippines

The company is member of NordCham Philippines, reportedly the largest Nordic Chamber of Commerce in the Asian Region.28 Swedish Match has owned a factory that produces lighters in Manilla since 2007.29

Controversial Marketing Strategies

Targeting Youth in Russia

In June 2012, marketing firm Proximity Russia posted promotional materials online that they had produced for SMPM International, the joint venture of Swedish Match and PMI. The company had been asked to develop promotional materials to aid the launch of Parliament snus in Russia, with the promotional materials including so-called “youth engagement materials”.30 For details and images of this controversial campaign, go to TPD: Marketing to Youth.

Image 2: Swedish Match employees used online snus user forums to directly communicate with customers (screenshot www.snuscentral.org, accessed 24 February 2011)

Image 3: Swedish Match Vice President Scientific Affairs was a columnist for an online snus user community (screenshot www.snuscentral.org, accessed 3 April 2012)

Promoting Tobacco Use via Social Media and Online Forums

A 2010 peer-reviewed study demonstrated that, in light of increasing tobacco advertising restrictions, Swedish Match had turned to YouTube and other social media to market its products, with none of the company’s YouTube videos including adequate safeguards to prevent under-age viewing.31 A 2011 social network analysis further demonstrated that Swedish Match employees had been active on Facebook, with Swedish Match employee Markus Ersmark at the centre of an elaborate network of snus manufacturers, snus retailers, and pro-snus bloggers generating pro-snus content.32

Swedish Match also used to directly contribute to online consumer forums to promote the company, its products and pro-snus messages (see images 2 and 3). The company used to have a ‘Ask the Manufacturer’ column on the American snus consumer forum SnusCENTRAL.org. In 2009 and 2010, Ersmark and a colleague directly responded to consumer questions about Swedish Match products and snus use in general. Over a period of eight months, the duo responded to 31 consumer questions, started one thread themselves, and in total posted 56 messages.33

Relationship Building with Social Media Influencers: Hospitality for Pro-Snus Bloggers

In addition to being directly active on social media, Swedish Match have engaged in ‘influencer marketing’ in which the marketing occurs indirectly through key influencers online.34 The company actively nurtured relationships with key pro-snus bloggers (of which some labelled themselves ‘snus ambassadors’) through providing hospitality and free sample products.35 For example, in 2012 Swedish Match hosted a so-called “summit” for American snus bloggers in Washington DC.36 A year earlier, the company hosted a delegation of American and British snus bloggers in Stockholm, visiting Swedish Match headquarters and factories, as well as a Tobacco Museum.37 In May 2010 two American bloggers visited Sweden, courtesy of Swedish Match, as was the case in 2009.38

Some bloggers received regular free snus samples from Swedish Match and then reviewed the products online, including British blogger Tim Haigh. Haigh and Swedish Match later became involved in a controversy which saw researchers from the University of Bath receive verbal abuse over a peer-reviewed article which highlighted that snus was being sold illegally across the EU via the Internet, contravening three EU Directives and Swedish national legislation.39 For more information see our page on FOI: University of Bath.

Failed Legal Bid to Stop Plain Packaging in Norway

In December 2016, the Norwegian Parliament approved plain packaging legislation on cigarettes and snus. Swedish Match sought an injunction from the Oslo County Court to delay the legislation, arguing that the Norwegian government was in breach of the free European Economic Area (EEA) trade rules and that the intervention (plain packaging of snus boxes) was not in proportion to the health risks associated with snus.40

In November 2017 the court rejected the Swedish Match claims, ruling that plain packaging was “an evidence-based and internationally recommended measure” adding that it was “a legitimate measure in line with the EEA Agreement”.41 The court also ruled that snus is harmful to health, and that plain packaging will contribute to the protection of public health, particularly of children and young people.

Swedish Match was ordered to pay the legal costs of the Norwegian Government.

  • Litigation is a well-known tactic of tobacco companies to stop or delay tobacco legislation. For more information go to Challenging Legislation.

Tactics to Subvert the Europe-Wide Snus Sales Ban

In 1992, sales of snus were banned in Europe, following an aggressive attempt by the US Smokeless Tobacco Company to introduce smokeless tobacco to several European markets in the mid-1980s. From 2001 the EU snus sales ban has been included in the European Union (EU) Tobacco Products Directive (TPD), which was reviewed in 2014. The snus ban severely limits the growth potential of Swedish Match in Europe, and the company has been attempting to lift the snus ban in the last decade using multiple tactics. The two main platforms of the company’s opposition to the snus ban are free trade and harm reduction.

In a submission to the 2010 public consultation that was part of the TPD review, Swedish match claimed that banning snus “denies 106 million smokers in the EU access to a traditional and non-combustible tobacco alternative to their cigarette”. 42 The company further ‘reminded’ the Commission of the need for EU legislation to respect the principles of EU Better Regulation and that there should be a “non-competitive regulation or tobacco and nicotine products” which would not create internal market distortions.

Directly and Indirectly Lobbied Commission Officials

Swedish Match lobbied DG SANCO (Health Directorate-General), and to a larger extent, non-health elements of the Commission, in particular the Secretariat General (responsible for Better Regulation and impact assessments), the Cabinet of the Regional Policy Commissioner Hahn, and DG ENTR (Enterprise and Industry Directorate-General).

Some of the meetings were facilitated by PR firm Kreab Gavin Anderson. Twice the company was accompanied by Revolving Door case Karin Riis-Jørgensen, a Danish former MEP and senior advisor of Kreab Gavin Anderson.43

Murky Lobbying Practices Exposed: ‘Dalligate’ and Untrue Version of Events

On 16 October 2012, EU Health Commissioner John Dalli was forced to resign following an investigation by EU’s anti-fraud office, OLAF, into bribery claims made by Swedish Match. For more detail on this controversy, labelled by some as ‘Dalligate’ or Barrosogate’, visit the pages TPD: Dalligate and TPD: Dalligate Timeline.

The scandal, besides raising questions about the transparency around EU policy making, also exposed the murky lobbying practices of Swedish Match in its attempts to have the snus ban lifted. Evidence showed that the company had inappropriately sought access to Dalli in his private sphere in Malta via Gayle Kimberley, a Maltese lobbyist not registered at the EU Transparency Register. Swedish Match’s Director of EU Affairs, Johan Gabrielsson, one of the people at the centre of the scandal, confirmed in a statement to OLAF on 2 June 201244 that Swedish Match had paid the lobbyist €5,000 to gain access to Dalli and feed him information that would help shape the evidence base on snus in favour of the company’s interests.

The company intentionally hid its relationship with Kimberley who, following a meeting with Dalli in January 2012, reported to Gabrielsson that “the meeting was CONFIDENTIAL and I was in no way representing SM Match just giving the objective position of snus producers and users!”.45

In the aftermath of the scandal, Swedish Match publicly lied at several occasions suggesting that Kimberley had met Dalli TWICE, the first time in January 2012 and the second time in February 2012 when the alleged bribery attempt had supposedly been made. In an interview following Dalli’s shock resignation, Swedish Match Vice President of EU Affairs, Patrik Hildingsson, recalled:

“There was a first meeting with Dalli in early January and a second one in February to hand over WHO science on snus. After this meeting she lobbyist sounded very upset, saying the meeting was derailed and went in a very odd direction. She told us that during the meeting Dalli had explained that all arguments behind the snus ban were actually in favour of Swedish Match. Then he said that, however, as a health commissioner, his political career would be over if he lifted the ban on snus. He said, according to the feedback I got, that it would be a political suicide to lift the ban. Then he left the meeting and we were alone with a man, an entrepreneur. He was supposed to be a friend of Dalli and did not have any relationship with Swedish Match. He continued the meeting and asked why Dalli would take a suicidal political decision without gaining anything. The solution was simple: we had to pay.”

However, when Hildingsson shared this version of events with the media, Swedish Match had already been informed by OLAF that Kimberley had lied about her presence on this supposed second meeting.46 The second meeting between the lobbyist and Dalli had not taken place. Gabrielsson later accused OLAF of advising him to stick to an untrue story of events: “I never lied. I just said what I had been told by OLAF. That’s not a lie”.

OLAF has denied allegations that it asked Swedish Match to skew the evidence and the Commission has indicated that it will not pursue this any further.

Image 4: Online monthly diary page of Swedish MEP Christofer Fjellner, showing a listed meeting on 10 September 2010 titled (translated in English) “Speak with snus manufacturer Swedish Match” (screenshot taken 30 March 2012)

Lobbying Members of European Parliament

In January 2013, Swedish Match was a keynote speaker at a Parliamentary event organised by the Brussels Network. MEPs Christofer Fjellner, Syed Kamall and Alexander Graf Lambdorff organised a meeting with tobacco as the agenda item, with Swedish Match given their version of their involvement in ‘Dalligate’.47 On this occasion, Swedish Match also stuck to the untrue version of events regarding the number of times their lobbyist met Dalli.

Challenging the Snus Ban in Court

In 2016 Swedish Match requested a judicial review of the snus ban in the UK High Court, which was approved on 26 January 2017. The case was referred to the European Court of Justice. In its legal challenge, the tobacco company has been supported by the New Nicotine Alliance UK (NNA), who requested the Court to make its own submission to provide a “customer perspective on the ban and on the benefits that will follow if the ban is lifted”.48 Gerry Stimson, a vocal advocate of tobacco harm reduction, is a Board member of the NNA.

Lobbied for legalisation of snus in the UK

Swedish Match have worked with PR company Abzed to lobby for the legalisation of snus in the UK.495051 Abzed stated that it had organised the “placement of around 20 parliamentary questions on snus” and a letter to Matt Hancock, Minister for Health in 2018, co-signed by Adam Afriyie MP.5150 This campaign continued after the UK left the EU in 2020. In December 2021, Abzed posted messages on snus forums, offering to help members of the public to write to their MPs.5150 Abzed is not listed on UK or EU lobbying registers.

For more information on Afriyie see All-Party Parliamentary Group (APPG) for Vaping (E-Cigarettes).

Close relationship with Swedish Politicians

In the past, Swedish Match enjoyed a good relationship with Swedish politicians, including Swedish Member of European Parliament (MEP) Christofer Fjellner, who promoted a pro-snus agenda in the European Parliament and was a vocal advocate for removing the EU ban on snus sales.52 Shortly before Fjellner launched a petition in 2010 to mobilise opposition to the EU snus ban, Swedish Match had two meetings with the MEP (see image 4).53
Swedish Match also claims a “close relationship between industry and government” in Sweden.54 Indeed, the Swedish Government supported Swedish Match’s call for a removal of the EU snus ban, regarding it a violation of free trade principles rather than a public health issue555657, an argument first voiced by Swedish Match.58

Image 5: Screengrab Swedish Match Annual Report 2009

Corporate Social Responsibility (CSR): Boosting Corporate Reputation

A 2011 news article in Tobacco Control pointed to Swedish Match as an example of tobacco industry philanthropy, where positive publicity was generated with little upfront community investment.59 The tobacco company’s 2009 annual report revealed that “Australia had suffered the country’s worst wildfire disaster in a quarter of a century” and in response the tobacco company had contributed to “Emergency Relief’ by giving a “cash donation” to the Australian Salvation Army (image 5). The company stopped short of disclosing the amount of money donated.

When the authors contacted the Australian Salvation Army and asked about the size of the donation, a spokesperson for the Charity confirmed that Swedish Match had donated AU$500 (approximately £256). The donation had presented only one ten thousandth of a per cent of the company’s operating profit.

Funding Science and Scientists

Image 6: Screengrab of funding disclosure of the University Of Louisville’s Endowed Chair in Tobacco Harm Reduction Research, undated, March 2015

For several years, Swedish Match North America was a financial donor to the University of Louisville’s Kentucky Research Challenge Trust Fund (also known as ‘Bucks for Brains’).60

From 2005 to 2008, Swedish Match spent half a million US dollars to fund the University’s Endowed Chair in Tobacco Harm Reduction held by Brad Rodu (Image 6).61 Rodu has been a vocal supporter of lifting the EU ban on snus.62

The tobacco industry has historically used science to oppose tobacco regulation and bias public opinion in favour of the tobacco companies.

Marketing Snus as “Modified Risk Tobacco Product” in the US

In April 2015, the advisory panel of the US Food and Drug Administration (FDA) rejected Swedish Match’s application to alter the health warnings of 10 variants of its General snus and claim snus is less harmful than cigarettes.63

The panel concluded that the company had not provided enough evidence to support that The Swedish Experience could be replicated in the US, and had not sufficiently tested the proposed new health warning to ensure consumers would understand it and interpret it.

In December 2016, the FDA upheld the panel’s advice although it encouraged the company to amend their application and submit more evidence to support their claims.64

In 2019, the FDA stated that eight Swedish Match snus products could be marketed in the US under the “Modified Risk Tobacco Products” (MRTP) pathway, for an initial period of 5 years.65 The FDA emphasised that this did not mean that these products were “FDA approved” or indeed “safe”. It also specified restrictions on advertising to prevent them being targeted to youth.65Read more about the tobacco industry and Harm Reduction.

Relevant Link

Swedish Match website

TobaccoTactics Resources

TCRG Research

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References

  1. ↑Swedish Match, Swedish Match to sell the cigarette business to Austria Tabak for MSEK 4,800, Press Release 31 May 1999, accessed January 2018
  2. ↑Swedish Match, Swedish Match 1999 Annual Report, accessed January 2018
  3. ↑A. Ringstrom, Swedish Match plans to spin off and list cigar business, Reuters, 15 September 2021, accessed September 2021
  4. ↑D. Afanasieva, Cigar exit is next strike in Swedish Match revamp, 20 July 2021, accessed September 2021
  5. ↑A. Ringstrom and M. Mannes, Swedish Match strikes record high on Philip Morris $16 bln takeover move, Reuters, 10 May 2022, accessed May 2022
  6. ↑Philip Morris International, PMI Offer For Swedish Match AB, PMI Investor Relations web page, 11 May 2022, accessed May 2022
  7. ↑A. Massoudi. P. Nilsson and J. Fontanella-Khan, Philip Morris International nears $16bn deal for Swedish Match, The Financial Times, 9 May 2022, accessed May 2022
  8. ↑Swedish Match, Statement by the Board of Directors of Swedish Match AB in relation to the public cash offer by Philip Morris Holland Holdings B.V.,press release, 11 May 2022
  9. ↑Philip Morris International, PMHH acquires shares in Swedish Match outside the offer and becomes the owner of nearly 86% of the shares, BusinessWire, 10 November 2022, accessed November 2022
  10. ↑Swedish Match, Statement by the Board of Directors of Swedish Match AB in relation to the increased public cash offer by Philip Morris Holland Holdings B.V., website, 27 October 2022, accessed November 2022
  11. ↑M. Mannes, Philip Morris to de-list Swedish Match after raising stake to 93%, Reuters, 28 November 2022, accessed November 2022
  12. ↑Swedish Match, Company Presentation: Who we are, What we do. 21 July 2010, accessed November 2017
  13. ↑S. Peeters, A. Gilmore, Transnational Tobacco Company Interests in Smokeless Tobacco in Europe: Analysis of Internal Industry Documents and Contemporary Industry Materials, PLoS Med 10(9): e1001506, 2013
  14. ↑Swedish Match, Market Development, last updated 24 March 2017, accessed January 2018
  15. ↑Euromonitor International, Smokeless Tobacco: Company Share, 2009-2019 (behind paywall)
  16. ↑Swedish Match, Smokefree, website, undated, accessed 23 September 2021
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  18. ↑Swedish Match, Management, website, undated, archived 7 June 2021, accessed September 2021
  19. ↑Swedish Match, January-September 2006 Interim Statement, accessed January 2018
  20. ↑FD (Fair Disclosure) Wire, Conference Call Transcript with Lorillard Executives at the Morgan Stanley Consumer & Retail Conference 16 November 2010
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  22. ↑Swedish Match, Swedish Match and Philip Morris International to dissolve smokeless joint venture, Press Release 16 July 2015, accessed January 2018
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  28. ↑NordCham Philippines, Members, NordCham Philippines website, 2016, accessed January 2018
  29. ↑Swedish Match, Cricket gears up in the Philippines, 4 August 2008, accessed January 2018
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  34. ↑Influencer Marketing, Marketing-Schools.org, 2012, accessed January 2018
  35. ↑L. Waters, Swedish Match XRANGE Snuses Released and Why?, SnusCentral.org, 30 March 2015, accessed April 2015
  36. ↑M. Hellwig, The Swedish Match Snus Summit- My Reflections, SnusCentral.org, 1 October 2012, accessed March 2015
  37. ↑M. Hellwig, The most exclusive snus in the world, 2 June 2011, accessed November 2011
  38. ↑C. Jones, Full report on the trip to Sweden and visit with Swedish Match! 31 May 2010, 31 May 2010, accessed June 2012
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  40. ↑Swedish snus company sues Norwegian state over neutral packaging, thelocal.no, 25 September 2017, accessed January 2018
  41. ↑Norwegian Government, Full victory to Norway over snus producer Swedish match, Press release 6 November 2017, accessed January 2018
  42. ↑C. Kindstrand, Swedish Match Industry Submission to the public consultation on the possible revision of the Tobacco Products Directive 2001/37/EC, page 2462 of 3697, 2010, accessed November 2017
  43. ↑European Commission and OLAF European Anti-Fraud Office, Replies to the Questionnaire from the Committee on Budgetary Control of the European Parliament concerning the resignation of the former Commissioner John Dalli, 30 November 2012
  44. ↑European Anti-Fraud Office, Written Record of Interview with Mr Johan Lenmart Gabrielsson, conducted 2 June 2012. In: Transmission of information following a closure of investigation, Fax from Giovanni Kessler to Peter Grech, dated 17 October 2012
  45. ↑Gayle Kimberley, Re: Meeting Commissioner. Email dated 9 January 2012 addressed to Johan Gabrielsson. In: Transmission of information following a closure of investigation, Fax from Giovanni Kessler to Peter Grech, dated 17 October 2012
  46. ↑Transcription of the meeting between Jose Bove MEP, Jean-Marc Desfilhes MEP Assistant, Cecilia Kindstrand-Isaksson Swedish Match, Johan Gabrielsson Swedish Match. 2013.
  47. ↑C. Fjellner, Email to MEPs dated 17 December 2012, Subject: Brussels Network January 9: Inside Dalli-gate
  48. ↑New Nicotine Alliance, NNA goes to the High Court to challenge the ban on snus, 19 January 2017, accessed January 2018
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  51. ↑abcCampaign to legalise Snus in the UK – we need your help!, posted by [email protected], reddit.com, 14 December 2021, accessed March 2022
  52. ↑Ewa Björling och Christofer Fjellner: Hjälp oss att rädda svensk snuskultur, Espressen.se, 5 November 2010, accessed November 2017
  53. ↑C. Fjellner, Kalender. Fjellner’s website, accessed February 2011
  54. ↑L. Rutqvist, The Swedish Tobacco Harm Reduction Experience. FDA-TPSAC Meeting on Dissolvable Products 18-20 January 2012
  55. ↑Swedish Match, Swedish Match welcomes an important step to normalize trade in the EU, press release 28 November 2008, accessed January 2018
  56. ↑C. Danielsson, Sweden’s response to the public consultation on Directive 2001/37/EC of 5 June 2001 on the approximation of the laws, regulations and administrative provisions of the Member States concerning the manufacture, presentation and sale of tobacco products. 2010
  57. ↑K. Gustafsson, Sweden Urges EU To Lift Ban On Snus Exports, The Wall Street Journal , 30 May 2011
  58. ↑Swedish Match. Arbitrary, Unreasonable and Discriminatory, press release 3 June 2002, accessed January 2018
  59. ↑G. Fooks & S. Peeters, World: disasters are ‘brand aid’ opportunities for tobacco, Tobacco Control 2011, 20:4-7
  60. ↑University of Louisville, Bucks for Brains donors, undated, accessed April 2017
  61. ↑University of Louisville, Endowed Chair in Tobacco Harm Reduction Research, undated, accessed January 2012
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  63. ↑T. Clarke, FDA panel votes against label change to Swedish Match snus, Reuters, 10 April 2015, accessed January 2018
  64. ↑Food and Drug Administration, FDA Submission Tracking Numbers (STNs): Multiple STNs, see below, Letter to Swedish Match North America dated 14 December 2016, accessed November 2017
  65. ↑abUS Food and Drug Administration, FDA grants first-ever modified risk orders to eight smokeless tobacco products, press release, 22 October 2019, accessed March 2022

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