Brownstone Institute
The WHO’s Proposed Pandemic Agreements Worsen Public Health
From the Brownstone Institute
The WHO decided that the response for a Toronto aged care resident and a young mother in a Malawian village should be essentially the same – stop them from meeting family and working, then inject them with the same patented chemicals.
Much has been written on the current proposals putting the World Health Organization (WHO) front and center of future pandemic responses. With billions of dollars in careers, salaries, and research funding on the table, it is difficult for many to be objective. However, there are fundamentals here that everyone with public health training should agree upon. Most others, if they take time to consider, would also agree. Including, when divorced from party politicking and soundbites, most politicians.
So here, from an orthodox public health standpoint, are some problems with the proposals on pandemics to be voted on at the World Health Assembly at the end of this month.
Unfounded Messaging on Urgency
The Pandemic Agreement (treaty) and IHR amendments have been promoted based on claims of a rapidly increasing risk of pandemics. In fact, they pose an ‘existential threat’ (i.e. one that may end our existence) according to the G20’s High Level Independent Panel in 2022. However, the increase in reported natural outbreaks on which the WHO, the World Bank, G20, and others based these claims is shown to be unfounded in a recent analysis from the UK’s University of Leeds. The main database on which most outbreak analyses rely, the GIDEON database, shows a reduction in natural outbreaks and resultant mortality over the past 10 to 15 years, with the prior increase between 1960 and 2000 fully consistent with the development of the technologies necessary to detect and record such outbreaks; PCR, antigen and serology tests, and genetic sequencing.
The WHO does not refute this but simply ignores it. Nipah viruses, for example, only ‘emerged’ in the late 1990s when we found ways to actually detect them. Now we can readily distinguish new variants of coronavirus to promote uptake of pharmaceuticals. The risk does not change by detecting them; we just change the ability to notice them. We also have the ability to modify viruses to make them worse – this is a relatively new problem. But do we really want an organization influenced by China, with North Korea on its executive board (insert your favorite geopolitical rivals), to manage a future bioweapons emergency?
Irrespective of growing evidence that Covid-19 was not a natural phenomenon, modelling that the World Bank quotes as suggesting a 3x increase in outbreaks over the next decade actually predicts that a Covid-like event will recur less than once per century. Diseases that the WHO uses to suggest an increase in outbreaks over the past 20 years, including cholera, plague, yellow fever, and influenza variants were orders of magnitude worse in past centuries.
This all makes it doubly confusing that the WHO is breaking its own legal requirements in order to push through a vote without Member States having time to properly review implications of the proposals. The urgency must be for reasons other than public health need. Others can speculate why, but we are all human and all have egos to protect, even when preparing legally binding international agreements.
Low Relative Burden
The burden (e.g. death rate or life years lost) of acute outbreaks is a fraction of the overall disease burden, far lower than many endemic infectious diseases such as malaria, HIV, and tuberculosis, and a rising burden of non-communicable disease. Few natural outbreaks over the past 20 years have resulted in more than 1,000 deaths – or 8 hours of tuberculosis mortality. Higher-burden diseases should dominate public health priorities, however dull or unprofitable they may seem.
With the development of modern antibiotics, major outbreaks from the big scourges of the past like Plague and typhus ceased to occur. Though influenza is caused by a virus, most deaths are also due to secondary bacterial infections. Hence, we have not seen a repeat of the Spanish flu in over a century. We are better at healthcare than we used to be and have improved nutrition (generally) and sanitation. Widespread travel has eliminated the risks of large immunologically naive populations, making our species more immunologically resilient. Cancer and heart disease may be increasing, but infectious diseases overall are declining. So where should we focus?
Lack of Evidence Base
Investment in public health requires both evidence (or high likelihood) that the investment will improve outcomes and an absence of significant harm. The WHO has demonstrated neither with their proposed interventions. Neither has anyone else. The lockdown and mass vaccination strategy promoted for Covid-19 resulted in a disease that predominantly affects elderly sick people leading to 15 million excess deaths, even increasing mortality in young adults. In past acute respiratory outbreaks, things got better after one or perhaps two seasons, but with Covid-19 excess mortality persisted.
Within public health, this would normally mean we check whether the response caused the problem. Especially if it’s a new type of response, and if past understanding of disease management predicted that it would. This is more reliable than pretending that past knowledge did not exist. So again, the WHO (and other public-private partnerships) are not following orthodox public health, but something quite different.
Centralization for a Highly Heterogeneous Problem
Twenty-five years ago, before private investors became so interested in public health, it was accepted that decentralization was sensible. Providing local control to communities that could then prioritize and tailor health interventions themselves can provide better outcomes. Covid-19 underlined the importance of this, showing how uneven the impact of an outbreak is, determined by population age, density, health status, and many other factors. To paraphrase the WHO, ‘Most people are safe, even when some are not.’
However, for reasons that remain unclear to many, the WHO decided that the response for a Toronto aged care resident and a young mother in a Malawian village should be essentially the same – stop them from meeting family and working, then inject them with the same patented chemicals. The WHO’s private sponsors, and even the two largest donor countries with their strong pharmaceutical sectors, agreed with this approach. So too did the people paid to implement it. It was really only history, common sense, and public health ethics that stood in the way, and they proved much more malleable.
Absence of Prevention Strategies Through Host Resilience
The WHO IHR amendments and Pandemic Agreement are all about detection, lockdowns, and mass vaccination. This would be good if we had nothing else. Fortunately, we do. Sanitation, better nutrition, antibiotics, and better housing halted the great scourges of the past. An article in the journal Nature in 2023 suggested that just getting vitamin D at the right level may have cut Covid-19 mortality by a third. We already knew this and can speculate on why it became controversial. It’s really basic immunology.
Nonetheless, nowhere within the proposed US$30+ billion annual budget is any genuine community and individual resilience supported. Imagine putting a few billion more into nutrition and sanitation. Not only would you dramatically reduce mortality from occasional outbreaks, but more common infectious diseases, and metabolic diseases such as diabetes and obesity, would also go down. This would actually reduce the need for pharmaceuticals. Imagine a pharmaceutical company, or investor, promoting that. It would be great for public health, but a suicidal business approach.
Conflicts of Interest
All of which brings us, obviously, to conflicts of interest. The WHO, when formed, was essentially funded by countries through a core budget, to address high-burden diseases on country request. Now, with 80% of its use of funds specified directly by the funder, its approach is different. If that Malawian village could stump up tens of millions for a program, they would get what they ask for. But they don’t have that money; Western countries, Pharma, and software moguls do.
Most people on earth would grasp that concept far better than a public health workforce heavily incentivized to think otherwise. This is why the World Health Assembly exists and has the ability to steer the WHO in directions that don’t harm their populations. In its former incarnation, the WHO considered conflict of interest to be a bad thing. Now, it works with its private and corporate sponsors, within the limits set by its Member States, to mold the world to their liking.
The Question Before Member States
To summarize, while it’s sensible to prepare for outbreaks and pandemics, it’s even more sensible to improve health. This involves directing resources to where the problems are and using them in a way that does more good than harm. When people’s salaries and careers become dependent on changing reality, reality gets warped. The new pandemic proposals are very warped. They are a business strategy, not a public health strategy. It is the business of wealth concentration and colonialism – as old as humanity itself.
The only real question is whether the majority of the Member States of the World Health Assembly, in their voting later this month, wish to promote a lucrative but rather amoral business strategy, or the interests of their people.
Author
From the Brownstone Institute
A walk through a dozen convenience stores in Montgomery County, Pennsylvania, says a lot about how US nicotine policy actually works. Only about one in eight nicotine-pouch products for sale is legal. The rest are unauthorized—but they’re not all the same. Some are brightly branded, with uncertain ingredients, not approved by any Western regulator, and clearly aimed at impulse buyers. Others—like Sweden’s NOAT—are the opposite: muted, well-made, adult-oriented, and already approved for sale in Europe.
Yet in the United States, NOAT has been told to stop selling. In September 2025, the Food and Drug Administration (FDA) issued the company a warning letter for offering nicotine pouches without marketing authorization. That might make sense if the products were dangerous, but they appear to be among the safest on the market: mild flavors, low nicotine levels, and recyclable paper packaging. In Europe, regulators consider them acceptable. In America, they’re banned. The decision looks, at best, strange—and possibly arbitrary.
What the Market Shows
My October 2025 audit was straightforward. I visited twelve stores and recorded every distinct pouch product visible for sale at the counter. If the item matched one of the twenty ZYN products that the FDA authorized in January, it was counted as legal. Everything else was counted as illegal.
Two of the stores told me they had recently received FDA letters and had already removed most illegal stock. The other ten stores were still dominated by unauthorized products—more than 93 percent of what was on display. Across all twelve locations, about 12 percent of products were legal ZYN, and about 88 percent were not.
The illegal share wasn’t uniform. Many of the unauthorized products were clearly high-nicotine imports with flashy names like Loop, Velo, and Zimo. These products may be fine, but some are probably high in contaminants, and a few often with very high nicotine levels. Others were subdued, plainly meant for adult users. NOAT was a good example of that second group: simple packaging, oat-based filler, restrained flavoring, and branding that makes no effort to look “cool.” It’s the kind of product any regulator serious about harm reduction would welcome.
Enforcement Works
To the FDA’s credit, enforcement does make a difference. The two stores that received official letters quickly pulled their illegal stock. That mirrors the agency’s broader efforts this year: new import alerts to detain unauthorized tobacco products at the border (see also Import Alert 98-06), and hundreds of warning letters to retailers, importers, and distributors.
But effective enforcement can’t solve a supply problem. The list of legal nicotine-pouch products is still extremely short—only a narrow range of ZYN items. Adults who want more variety, or stores that want to meet that demand, inevitably turn to gray-market suppliers. The more limited the legal catalog, the more the illegal market thrives.
Why the NOAT Decision Appears Bizarre
The FDA’s own actions make the situation hard to explain. In January 2025, it authorized twenty ZYN products after finding that they contained far fewer harmful chemicals than cigarettes and could help adult smokers switch. That was progress. But nine months later, the FDA has approved nothing else—while sending a warning letter to NOAT, arguably the least youth-oriented pouch line in the world.
The outcome is bad for legal sellers and public health. ZYN is legal; a handful of clearly risky, high-nicotine imports continue to circulate; and a mild, adult-market brand that meets European safety and labeling rules is banned. Officially, NOAT’s problem is procedural—it lacks a marketing order. But in practical terms, the FDA is punishing the very design choices it claims to value: simplicity, low appeal to minors, and clean ingredients.
This approach also ignores the differences in actual risk. Studies consistently show that nicotine pouches have far fewer toxins than cigarettes and far less variability than many vapes. The biggest pouch concerns are uneven nicotine levels and occasional traces of tobacco-specific nitrosamines, depending on manufacturing quality. The serious contamination issues—heavy metals and inconsistent dosage—belong mostly to disposable vapes, particularly the flood of unregulated imports from China. Treating all “unauthorized” products as equally bad blurs those distinctions and undermines proportional enforcement.
A Better Balance: Enforce Upstream, Widen the Legal Path
My small Montgomery County survey suggests a simple formula for improvement.
First, keep enforcement targeted and focused on suppliers, not just clerks. Warning letters clearly change behavior at the store level, but the biggest impact will come from auditing distributors and importers, and stopping bad shipments before they reach retail shelves.
Second, make compliance easy. A single-page list of authorized nicotine-pouch products—currently the twenty approved ZYN items—should be posted in every store and attached to distributor invoices. Point-of-sale systems can block barcodes for anything not on the list, and retailers could affirm, once a year, that they stock only approved items.
Third, widen the legal lane. The FDA launched a pilot program in September 2025 to speed review of new pouch applications. That program should spell out exactly what evidence is needed—chemical data, toxicology, nicotine release rates, and behavioral studies—and make timely decisions. If products like NOAT meet those standards, they should be authorized quickly. Legal competition among adult-oriented brands will crowd out the sketchy imports far faster than enforcement alone.
The Bottom Line
Enforcement matters, and the data show it works—where it happens. But the legal market is too narrow to protect consumers or encourage innovation. The current regime leaves a few ZYN products as lonely legal islands in a sea of gray-market pouches that range from sensible to reckless.
The FDA’s treatment of NOAT stands out as a case study in inconsistency: a quiet, adult-focused brand approved in Europe yet effectively banned in the US, while flashier and riskier options continue to slip through. That’s not a public-health victory; it’s a missed opportunity.
If the goal is to help adult smokers move to lower-risk products while keeping youth use low, the path forward is clear: enforce smartly, make compliance easy, and give good products a fair shot. Right now, we’re doing the first part well—but failing at the second and third. It’s time to fix that.
Author
From the Brownstone Institute
Cigarettes kill nearly half a million Americans each year. Everyone knows it, including the Food and Drug Administration. Yet while the most lethal nicotine product remains on sale in every gas station, the FDA continues to block or delay far safer alternatives.
Nicotine pouches—small, smokeless packets tucked under the lip—deliver nicotine without burning tobacco. They eliminate the tar, carbon monoxide, and carcinogens that make cigarettes so deadly. The logic of harm reduction couldn’t be clearer: if smokers can get nicotine without smoke, millions of lives could be saved.
Sweden has already proven the point. Through widespread use of snus and nicotine pouches, the country has cut daily smoking to about 5 percent, the lowest rate in Europe. Lung-cancer deaths are less than half the continental average. This “Swedish Experience” shows that when adults are given safer options, they switch voluntarily—no prohibition required.
In the United States, however, the FDA’s tobacco division has turned this logic on its head. Since Congress gave it sweeping authority in 2009, the agency has demanded that every new product undergo a Premarket Tobacco Product Application, or PMTA, proving it is “appropriate for the protection of public health.” That sounds reasonable until you see how the process works.
Manufacturers must spend millions on speculative modeling about how their products might affect every segment of society—smokers, nonsmokers, youth, and future generations—before they can even reach the market. Unsurprisingly, almost all PMTAs have been denied or shelved. Reduced-risk products sit in limbo while Marlboros and Newports remain untouched.
Only this January did the agency relent slightly, authorizing 20 ZYN nicotine-pouch products made by Swedish Match, now owned by Philip Morris. The FDA admitted the obvious: “The data show that these specific products are appropriate for the protection of public health.” The toxic-chemical levels were far lower than in cigarettes, and adult smokers were more likely to switch than teens were to start.
The decision should have been a turning point. Instead, it exposed the double standard. Other pouch makers—especially smaller firms from Sweden and the US, such as NOAT—remain locked out of the legal market even when their products meet the same technical standards.
The FDA’s inaction has created a black market dominated by unregulated imports, many from China. According to my own research, roughly 85 percent of pouches now sold in convenience stores are technically illegal.
The agency claims that this heavy-handed approach protects kids. But youth pouch use in the US remains very low—about 1.5 percent of high-school students according to the latest National Youth Tobacco Survey—while nearly 30 million American adults still smoke. Denying safer products to millions of addicted adults because a tiny fraction of teens might experiment is the opposite of public-health logic.
There’s a better path. The FDA should base its decisions on science, not fear. If a product dramatically reduces exposure to harmful chemicals, meets strict packaging and marketing standards, and enforces Tobacco 21 age verification, it should be allowed on the market. Population-level effects can be monitored afterward through real-world data on switching and youth use. That’s how drug and vaccine regulation already works.
Sweden’s evidence shows the results of a pragmatic approach: a near-smoke-free society achieved through consumer choice, not coercion. The FDA’s own approval of ZYN proves that such products can meet its legal standard for protecting public health. The next step is consistency—apply the same rules to everyone.
Combustion, not nicotine, is the killer. Until the FDA acts on that simple truth, it will keep protecting the cigarette industry it was supposed to regulate.
Author
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