Background:
After the EU menthol ban, a substantial proportion of adolescents and young adults in Denmark still smoke menthol cigarettes. This may be due to tobacco industry tactics to circumvent the ban.

Objective:
We aim to: 1) give insights into the response of the tobacco industry to the implementation of the EU menthol ban in Denmark; 2) identify loopholes in the EU characterizing flavour ban; and 3) discuss how to make bans on menthol-flavored tobacco most effective.

Methods:
We employ screening of tobacco products using online tobacco stores. We analyze samples of cigarette packages, tobacco flavor accessories, and menthol-flavored cigarette-like products purchased between December 2019 and January 2022.

Results:
The products identified and analyzed in our study reveal that tobacco companies and retailers use a variety of strategies to undermine the EU menthol ban:

• Continued use of menthol as an ingredient in cigarettes (The EU TPD only bans menthol as a characterizing flavor).
• Cigarettes without menthol flavor but with menthol-like qualities (cooling effect and fresh feeling).
• Tobacco flavor accessories that enable users to customize their cigarettes with menthol and sweet flavors.
• Recessed cigarette filters with a hollow section that allows inserting smaller menthol filter tips.
• Menthol flavored cigarette-like products (cigarillos, heated tobacco etc.).
• Cigarette pack design and brand descriptors insinuating menthol-like qualities.

Conclusions:
To be efficient, bans on flavored tobacco products should prohibit menthol and other additives with flavor properties, as ingredients. Ingredients that produce a cooling effect should also be banned. Legislation should prohibit flavored tobacco accessories and filter modifications which may enable tobacco companies to circumvent the flavor ban. Legislation should encompass all tobacco products to avoid the substitution of one product with another. Attention should be given to plain packaging of tobacco products as a tool to support a menthol ban.