As negotiators prepare to meet in Geneva, 5-14 August in yet another attempt to finalize the United Nations Global Plastics Treaty addressing a pollution crisis affecting oceans and ecosystems worldwide – a critical linkage between health and environment governance seems to be largely missing from the draft text.

After nearly three years of negotiations, the world may be on the verge of finalizing its first legally-binding global instrument to tackle plastic pollution – providing that treaty negotiators overcome massive pressures from the fossil fuel industry to further stall an agreement or weaken provisions aiming to limit plastics production.  

But as negotiators prepare for the resumed fifth session (INC-5.2),  another fundamental flaw threatens the future treaty’s health objectives: the failure to integrate environmental and health governance. 

This is particularly apparent with regards to cigarette filters – the world’s most littered plastic item – although it extends to cross-sector cooperation on other issues regarding the health harms of other plastics as well.

The current draft text makes with only one reference to ‘plastic’ cigarette filters (in draft Annex X) and makes no reference at all to the WHO Framework Convention on Tobacco Control – which could, in fact, be an important nexus for health-environment cooperation on the treaty – once it is approved.

The treatment of cigarette filters – largely made of a plastic called cellulose acetate – sends smoke signals about more systematic problems with the treaty text in terms of its approach to environment and health.

Health rhetoric vs reality gap

The Chair’s text, the working document guiding final negotiations, acknowledges health extensively in its rhetoric, although much of it remains in brackets, indicating areas where countries have not yet reached agreement.

The preamble recognizes plastic pollution as “a serious environmental and human health problem,” while the treaty’s stated objective is “to protect human health and the environment from plastic pollution.”

But while the preamble recognizes mutual support with “other international agreements in the field of the environment,” it limits that framework to environmental treaties. 

Any reference to health instruments, including the WHO Framework Convention on Tobacco Control (FCTC), which has been ratified by 183 countries, are absent from this structure. 

The Chair’s preambular text affirms that the plastics treaty will “not affect… existing treaty obligations,” but this is a non-binding statement that merely avoids direct legal contradictions without promoting substantive policy coherence. 

In practice, it enables siloed implementation, weakens the ability of health ministries to regulate tobacco product components, and gives the tobacco industry new opportunities to exploit regulatory gaps through the environment ministries.

Most tellingly, a standalone health article remains uncertain, reduced to scattered references or a placeholder “pending informal drafting work.” Despite the draft’s stated health objectives, the institutional bridge to health governance is still missing. 

The ‘safe alternatives’ problem 

This gap matters because “safe substitutes,” “safe alternatives,” or “safe recycling” are at the heart of solutions throughout the draft treaty. But how can environmental authorities evaluate safety and health impacts without connecting to international or national health standards?

The tobacco industry is already exploiting this governance gap by promoting “eco-filters” and “biodegradable” alternatives to plastic cigarette filters. While these products may appear to address plastic pollution, they remain harmful to both health and the environment. 

Worse, they risk misleading consumers and this kind of product feature substitution is typically assessed by health authorities, not environmental ministries, which may lack the mandate or expertise to evaluate such claims.

The cigarette filter test case

Used cigarette filters represent the world’s most littered plastic item, with trillions discarded annually. Each cigarette butt contains toxic lead, cadmium, phthalates, and polycyclic aromatic hydrocarbons that leach into waterways. A single cigarette butt can contaminate 1,000 liters of water, causing $26 billion in annual marine ecosystem damage.

The FCTC provides clear guidance on these filters: Parties should prohibit ingredients in tobacco products that may create the impression that they have a health benefit. 

The WHO study group’s recommendations early this year included that filters should be banned to reduce the palatability and appeal of cigarettes. This would remove consumer misconceptions that filters reduce health harms, and it would also reduce a major source of toxic tobacco waste, including the microplastics deposited by cellulose acetate in filters. 

Yet the draft plastics treaty only lists “cigarette filters made with plastic” in a priority list for mandatory or voluntary restriction or banning (Annex X), rather than on the ban or phaseout list (Annex Y).  The “made with plastic” language for cigarette filters also creates a dangerous loophole that permits biofilters/ eco-filters, contradicting established health guidance.

In contrast, Annex Y, the ban/ phase out list, itemizes toys and food containers containing lead, cadmium, and phthalates – the same toxicants found in cigarette filters. 

Broader governance architecture problem

The cigarette filter case reveals systemic weaknesses in the treaty draft’s language around health. Article 2.2 of the FCTC requires Parties to ensure that subsequent international agreements should be compatible with FCTC obligations. However, the negotiating states have yet to provide a mechanism for ensuring this compatibility. When environmental ministries approve product redesigns without health authority input, both agendas suffer. When industries exploit policy gaps to rehabilitate their image while maintaining harmful products, both environmental integrity and health objectives are compromised.

Extended Producer Responsibility schemes promoted throughout the draft treaty could also legitimize tobacco industry participation in environmental policy and its greenwashing, directly contradicting FCTC Article 5.3’s requirement to “protect tobacco-related environment policies” from industry interference.

The problem extends far beyond tobacco. Plastic substitution decisions made in isolation from health expertise risk creating new health hazards while solving environmental concerns—essentially trading one set of risks for another. Environmental authorities may inadvertently approve alternatives that address plastic pollution while creating health risks.

Infrastructure already exists

The solution isn’t to build new health systems from scratch, as many countries already have relevant capacity, and global infrastructure exists, including for chemical safety, food standards, and medical devices. 

For tobacco, global networks like TobLabNet and TobReg provide evidence-based guidance. 

The real challenge is not global coordination, but national-level inter-agency cooperation. The future plastics treaty can help by explicitly obligating this, ensuring health and environment agencies work together. 

Without giving due regard to existing health treaties, such coordination will inevitably run up against the different standards these agencies follow on industry engagement. No credible health authority engages with the tobacco industry, which is prohibited globally under the WHO’s Framework of Engagement with Non-State Actors (FENSA) and nationally through Article 5.3 of the FCTC, which covers over 90% of the world’s population.

The commitment to binding norms on conflict of interest in the FCTC is essential. It creates space for the broader safeguards called for by civil society, scientists, and the Office of the High Commissioner for Human Rights (OHCHR). 

Failing to respect existing obligations—especially in the clearest and extreme case of tobacco— effectively precludes any meaningful prevention of conflicts of interest.

Integration not isolation

The solution lies in strengthening the draft’s health foundation by explicitly recognizing existing health agreements, including the WHO’s FCTC, which was already referenced in previous drafts to promote “cooperation, coordination, and complementarity.”

A global coalition focusing on this issue recommends a simple safeguard clause – “Measures taken under this instrument shall be without prejudice to, and aligned with, existing international public health treaties and obligations, (including the WHO FCTC)” – would help prevent regulatory conflicts while provide supportive infrastructures to bolster the authority of environmental ministries to implement the future treaty.  

For cigarette filters, the recommendation is to eliminate material qualifiers “made of plastic” and move filters to a list for immediate bans. 

More broadly, the future instrument needs formal mechanisms for health expertise integration—not transferring authority from the environment to health ministries, but creating coordination mechanisms ensuring both objectives are met.

The Geneva opportunity

The Global Plastics Treaty could model integrated governance for 21st-century planetary health challenges, or represent another missed opportunity for coherent global health governance.

Tobacco control shows how weak coordination between health and environmental sectors can backfire. 

When environmental agencies promote so-called “eco-filters” without health input, they risk legitimizing harmful products. 

But the reverse is also true. During COVID-19, health-led responses drove a surge in plastic consumption, worsening pollution. Both cases expose the same flaw: without coordination, one sector’s solution can become another’s crisis.

The Plastics Treaty offers a rare chance to correct this. The infrastructure exists. The evidence is clear. 

What’s missing is the political will to connect them through binding legal frameworks. Geneva may be the last, best opportunity, not only to curb plastic pollution, but to safeguard the future of global health governance. 

Integrating international health agreements into the treaty does more than align with existing obligations. It helps define the treaty’s direction and lays the foundation for a strong, legally binding instrument with robust regulatory measures and comprehensive protections for people and the planet.

Deborah Sy is head of Strategy and Global Public Policy at the Global Center for Good Governance in Tobacco Control (GGTC) at Thammasat University in Thailand, the convener of Global Youth Voices and the Stop Tobacco Pollution Alliance (STPA). She is the founder and senior advisor of Health Justice Philippines, an observer to the UN Plastics Treaty negotiations.

Image Credits: Dennis Skley, University of Bath , UNEP , Chairs Text, draft UN Plastics Treaty, December 2024, Chairs Text, UN Plastics Treaty, Draft 2024, Ciel.org.