OBJECTIVE: The tobacco manufacturers state that they want to see laws that prohibit the sale of tobacco to minors enacted and enforced. Our purpose was to compare these public statements with the US tobacco industry's legislative agenda at the federal and state levels. DESIGN: A review of the industry's comments to the US Department of Health and Human Services (DHHS) regarding proposed federal regulations, and an analysis of pro-tobacco state legislation concerning tobacco sales to minors. RESULTS: The industry is strongly opposed to federal regulations requiring states to effectively enforce their laws prohibiting the sale of tobacco to minors. A food industry newsletter reports that the Tobacco Institute has circulated a model state bill concerning underage tobacco sales. Striking similarities between bills from several states would seem to confirm this report. These bills strip communities of enforcement authority while making effective enforcement by state officials virtually impossible. CONCLUSION: The evidence strongly suggests an industry strategy to undermine efforts to enforce laws prohibiting the sale of tobacco to minors. As has been the case in the past, the tobacco industry is publicly endorsing a socially responsible goal while apparently taking action behind the scenes to ensure that the goal is not achieved.