On December 17, 2010, WLF filed formal comments with the European Union’s (EU) Health and Consumers Directorate, urging it not to adopt new restrictions on the packaging of tobacco products. The EU is proposing to require all tobacco products to be sold in “plain packaging” – meaning nothing more than the name of the product in black and white, along with a large health warning covering the top half of each package. WLF urged the EU not to adopt the proposal. WLF argued that the proposal would raise serious issues regarding free speech and intellectual property rights. By prohibiting the use of trademarks and logos, the proposal would run afoul of international treaty obligations, WLF said. It also argued that the proposal would likely lead to increased tobacco sales and counterfeiting – the precise opposite effect from the one that regulators are hoping to achieve.