Table 3.

Code list for content analysis of industry submissions arguments.

Argument	Definition	Key words or expression used to identify arguments for coding*
Illicit trade	Illicit trade used as argument to opposed proposed regulation, mentioned as a threat	“Illicit trade”, “counterfeit”, “black market”, “smuggling”, “criminal”, “illegal”
Freedom	Arguments based on freedom to choose, freedom of commerce, freedom of speech or expression	“Freedom”, “free”
Employment & economic growth	Arguments for renouncing regulation due to economic reasons	“Employment”, “jobs”, “economy”, “competitiveness”
Smokeless tobacco products cited as being less harmful	Arguments claiming that smokeless tobacco products are less harmful than combustible products	“Hazard”, “less hazardous”, “less harmful”, “dangerous”
Avoid EU level regulation of tobacco products	Arguments for keeping tobacco regulation as prerogative of Member States	“Prerogative”, “responsibility”, “domain”, (state's) “duty”, (state's) “powers”, “EU-level”
Denormalization of tobacco products	Denormalization mentioned in relation to regulation	“Denormalization”, “denormalization”
Informing consumers on health risks	Arguments to provide customers with information on the different risk levels of different tobacco products	“Education”, “information”, “advice”, “risk”
Preferential treatment of smokeless tobacco products	Arguments for giving smokeless tobacco products preferential treatment over combustible tobacco products in regulation	“Tax”, “beneficial”, “preference”, “preferential”

^*Corresponding words were used for German, Swedish and Finnish.