Textual analysis of 38 Chinese subnational tobacco control regulations against FCTC Article 8

China ratified the WHO Framework Convention on Tobacco Control (FCTC) in 2005; it entered into force domestically on 9 January 2006. Absent of comprehensive national smoke-free legislation, subnational jurisdictions have enacted dedicated tobacco control regulations heterogeneously. The textual architecture distinguishing FCTC Article 8-compliant from non-compliant drafting has not been systematically characterized at corpus scale.

This study compiled 38 Chinese subnational dedicated tobacco control regulations enacted or materially amended after FCTC entry into force (9 January 2006 through 31 December 2024) (100635 substantive Chinese characters). Each was independently evaluated against the four core requirements of the FCTC Article 8 Implementation Guidelines [FCTC/COP2(7), 2007] and triangulated against an authoritative expert database. A five-layer framework examined corpus scale, compliance, e-cigarette prohibitions, enforcement features, and other FCTC complementary measures. Mann-Whitney U tests with Cliff's delta and Fisher's exact tests were used (two-sided, α = 0.05).

Of 38 regulations, 10 (26.3%) met FCTC Article 8 compliance criteria; 28 (73.7%) did not. Compliant regulations had higher median character counts (3249 vs 2572; δ=0.40, p=0.066) and clause counts (28.0 vs 23.0; δ=0.46, p=0.034). E-cigarette prohibitions (60.0% vs 25.0%, p=0.062) and cessation service requirements (90.0% vs 50.0%, p=0.056) were more frequent in compliant regulations. The 10 compliant jurisdictions cover an estimated 121.6 million residents (8.6% of mainland China's 2020 population).

Greater corpus elaboration, more complete enforcement specification, and inclusion of FCTC-aligned complementary measures are textual features systematically associated with - though not shown to cause - FCTC Article 8 compliance in Chinese subnational law. These findings characterize legal text rather than implementation outcomes and inform drafting guidance for Chinese cities and other jurisdictions pursuing Article 8 implementation.