Brownstone Institute
The WHO Is a Real and Present Danger
From the Brownstone Institute
Our governments intend to transfer decisions over our health, families, and societal freedoms to the Director General of the World Health Organization (WHO), whenever he or she declares it necessary. The success of this transfer of power depends on public ignorance of its implications, and of the nature of the WHO itself and its recent pandemic policy reversals. When the public understands, then its leaders are more likely to act in their interests rather than against them.
In late 2019, the WHO issued new recommendations for pandemic influenza. Influenza spreads by the same mechanism as Covid-19 (aerosols), with a similar mortality in most people. The WHO stated that it is “not recommended in any circumstances” to undertake contact tracing, quarantine of exposed individuals, entry and exit screening, and border closures. They envisioned that in a severe pandemic it may be necessary to close businesses for up to seven to ten days.
The WHO cautioned against strict measures because they would have minimal impact on the spread of an aerosolized respiratory virus while inevitably increasing poverty, especially harming low-income people. Poverty makes people die younger and is a major killer of babies in low-income countries.
A few months later, the WHO advocated for everything they had previously advised against, to combat Covid-19. This reversal in their recommendations had the effect they had predicted; increasing poverty and shortening life expectancy, particularly amongst the world’s poorest and most vulnerable, while having minimal overall impact on virus spread.
While the WHO’s 2019 recommendations were based on the assessment of decades of knowledge by an expert panel, its Covid-19 lockdown recommendations were based solely on reported experience from one city in China. Their new source of knowledge had, a few weeks earlier, stated that the new virus had no human-to-human transmission. This was followed by apparent propaganda taken up by the world’s media of people dropping dead in the streets.
It is vital to understand what drove this reversal of WHO policy, and to detail its harm. International public health priorities are currently being upended with the specific aim of allowing the WHO to do this again, harder and more frequently. In May 2024 our countries will vote to allow a single person to dictate border closures and quarantine, and require medical examinations and vaccination of their citizens. They will agree to censor those who protest. Our governments will undertake to make this individual’s recommendations regarding our rights to family life, work, and school effectively binding.
In promoting lockdowns, the WHO was not only following China, but a group of powerful Pharma-related interests who have been pushing these approaches for over a decade. They have established public-private partnerships such as the Swiss-based CEPI, channeling taxpayer funding to promote their authoritarian approach to public health. In October 2019, a meeting called Event-201 was convened by the Bill & Melinda Gates Foundation, World Economic Forum and Johns Hopkins School of Public Health, including the WHO, China CDC and others, to run simulations of such approaches for a hypothetical coronavirus outbreak. At this time, Covid-19 virus must already have been circulating well beyond China.
Whilst establishing this influence over public health policy, Pharma and their private investors increasingly funded the WHO itself, now providing about 25 percent of its budget. This funding is ‘specified,’ meaning the funder decides how and where it is spent. Certain governments now also ‘specify’ most of their funding, leading to over 75 percent of the WHO’s activities being determined by the donor. Germany stands out as the second highest national donor after the USA, also being a major investor in BioNTech, Pfizer’s Covid-19 mRNA vaccine developer.
Discarding basic immunology, the WHO then claimed in late 2020 that only vaccination could lead to high community immunity (‘herd immunity’) and became a major proponent of mass vaccination within an epidemic, aligning fully with its private sponsors. Under pressure for obviously lying, they then changed to a preference for vaccination – equally foolish as a general statement since many everyday viruses are obviously mild. While not based on evidence or expertise, this clearly serves a purpose.
Despite there being a clearly identified subset of people at high Covid risk, vaccination-for-all was promoted by Pharma investors as a ‘way out’ of the lockdowns these same people had advocated for. The WHO’s incoherent Covid vax mantra – “No one is safe until all are safe” – is supposed to support this but logically implies that vaccination does not even protect the vaccinated.
In Western countries the results of these policies are increasingly stark; rising inequality, closed businesses and rising young adult all-cause mortality. In low-income countries across Africa and Asia that the WHO once prioritized, its actions have been even more devastating. As predicted in early 2020, malaria, tuberculosis and HIV/AIDS are increasing, killing more people and at a far younger age than Covid-19. Over 100 million additional people face malnutrition, up to 10 million additional girls will endure child marriage and nightly rape, and millions more mothers will lose their infants due to the impacts of deeper poverty. UNICEF estimated nearly a quarter million added child deaths from lockdowns in South Asia in 2020 alone. The WHO did this – they stated that it would happen, then encouraged its implementation.
Few gained from the Covid response, but those who did gained; particularly private and corporate funders of the WHO with large Pharma and software assets, gained massively. WHO employees and others working in global health also thrived, and are now securing lucrative careers as the agenda expands. As the old evidence-based public health is pushed aside, it is in the new public health of the software entrepreneurs and Pharma moguls that careers will be made.
So, we have a problem. The WHO, ostensibly leading the show, is deeply conflicted through its private investors, whilst governed by an Assembly including powerful States hostile to human rights and democracy. Its staffing policies, based on country quotas and rules that promote retention rather than targeted recruitment, are not even designed to assure technical expertise.
The recent behavior of these staff – blind, dutiful compliance with the organization’s multiple nonsensical claims – must raise questions regarding their integrity and competency. The expanding pandemic industry has a massive financial war chest aimed at media and political sponsorship, and our politicians fear political oblivion should they oppose it.
Pandemics are rare. In the past century, including Covid, the WHO estimates about one per generation. These cost fewer life-years during their time of spread than tuberculosis or cancer cost every year. No one can rationally claim we face an existential crisis, or that forfeiting human freedom to Pharma and private entrepreneurs is a legitimate public health response should we face one. Our democracies are being eroded through a massive amoral business deal, a structure designed to concentrate the wealth of the many in the hands of the few. Covid-19 proved the model works.
The only real question is whether, and how, this society-wrecking pandemic train can be stopped. The public health professions want careers and salaries, and will not intervene. They have proven that in previous manifestations of fascism. The public must educate themselves, and then refuse to comply. We can just hope some of our supposed leaders will step forward to help them.
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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