British Brands Group

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Background

The British Brands Group (BBG) was established in 1994 and describes itself as "a membership organisation dedicated to championing brands in the UK". The Group says its "objective is to ensure that their positive contribution to consumers, the economy and society is better understood by policy makers and others".[1]

Screengrab of BBG's 2010 submission to the European Commission, March 2015.

Links to the Tobacco Industry

The BBG does not disclose a list of its members, but a 2010 BBG submission to the European Commission stated that “Our [BBG] members range in size and supply a variety of branded goods in a wide range of product categories, of which tobacco is but one”.[2]

Previous research found that British American Tobacco (BAT) Belgium listed itself as a member of the BBG.[3]

Furthermore, although the BBG is now listed as an organisation founded by four non-tobacco industry connected companies, the group was actually originally founded collaboratively by BAT, Rothmans, Kraft Jacobs Suchard (then owned by Philip Morris), Coca Cola, Unilever, Bass, Guiness, Allied Lyons and Interbrand.[3]

Against Plain Packaging

The BBG has consistently opposed the introduction of plain packaging in the UK, reiterating many tobacco industry lines of opposition.

Makes it More Difficult to Launch New Products

In September 2008 the BBG published a joint response on the future of tobacco control along with the Anti-Counterfeiting Group, which stated that plain packaging would be "both an invitation to counterfeiting and a potential and significant restriction on branding in the UK and branding’s ability to contribute to consumers and the economy". Packaging, they said, increased "attractiveness and appeal of one product over another – presenting the product in the most positive light, differentiating it from others and enhancing its competitiveness". In contrast, plain packaging would make it "more difficult" for the tobacco industry "to launch new products and product variants". [4]

In its submission BBG did not reveal its members. However, when the Group submitted a consultation response to an Office of Fair Trading consultation it did list its members, and BAT was named as a member.[5] By the time that this consultation response was published the list of members had been removed.[3]

Packaging Does Not Influence Smoking Uptake

Despite emphasising the importance of branding in consumer perceptions of products and their subsequent choice of one brand over another, the BBG claims that packaging does not lead to purchases in the first instance: “On-pack branding and communication has a role to play in providing information and reassurance but cannot persuade informed consumer to buy things that they do not want.”[6]

In September 2011, John Noble, the Director of the BBG, wrote in the Grocer Magazine that "Legislation to impose plain packaging is passing at speed through the Australian parliament, yet the Australian government openly admits it has no evidence this will deliver the goal of discouraging smoking by young people."

Noble went on to warn: "Remove branding and the market becomes generic, with little incentive to innovate and competition based only on price. The result may be more people smoking more". [7]

A "Direct Threat" to UK Brands and Intellectual Property Rights

In February 2009, the BBG issued a briefing paper on the subject for Parliamentarians:

"The introduction of plain packaging would pose a direct threat to brands in the UK, breach the harmonised regime of intellectual property rights, and contravene the UK’s international treaty obligations. A breach of those principles would reverberate across the world and industry, calling into doubt the UK’s commitment to an effective IP regime." [8]

Will Increase Illicit Trade

In an interview with the Forest run Hands Off Our Packs campaign against plain packaging, Director of the BBG John Noble stated:

“Plain packaging will certainly encourage counterfeiting. Firstly, the fewer designs means that it will be much easier for counterfeiters to produce fakes. More significantly, perhaps, consumers will find it much harder to distinguish between a genuine and a fake product. Fakes undermine Governments’ tobacco policies not just because of the lack of quality control but because they tend to circumvent the legitimate supply chain, allowing children much easier access to age-regulated tobacco products.”[9]

This statement, which didn’t cite any evidence as support, was used as evidence against plain packaging by British American Tobacco in their first UK plain packaging consultation submission. [10]

In its response to the same consultation, Philip Morris International cited a similar statement from the BBG.[11] Again, the BBG statement did not cite any evidence to support its claims that “With all tobacco products being essentially indistinguishable and counterfeiters only having to replicate one simple design, it is inevitable that counterfeiting will be easier, while being more difficult to detect.” [12]

These arguments echo classic arguments used by the industry to counter legislation. For more information on these arguments and the efficacy of them, see:

A Third Party Lobby Group for PMI

Influencers diagram snipped from PMI UK Corporate Affairs Update March 2012, Leaked in 2013

In mid-2013, new leaked documents authored by PMI in early 2012 revealed that the company planned a multi-faceted campaign to oppose the British government’s plans to introduce plain packaging. [13][14]

The BBG was listed as a central “third party” that PMI wanted to use in its anti-plain packaging campaign (see below.)

BBG identified by Philip Morris International as an "Influencer"

In the leaked presentations, PMI also detailed a model centred around UK Prime Minister David Cameron, the "decision maker" (see Image). Cameron, depicted at the epicentre, is surrounded by nine "formal/informal advisors" who in turn were surrounded by a large number of "influencers" including MPs, Lords, Government departments and a series of non-governmental organisations, charities and lobby groups (see Image). Included amongst the lobby groups identified by PMI as influencers was the BBG.

In addition, PMI named "key committees" as influencers, such as the Cabinet Office Behavioural Insight Unit, the Regulatory Policy Committee and the Government’s Department for Business Innovation & Skills (BIS) Reducing Regulation Committee (p15) which, among other things, strives to reduce the burden of regulation in accordance with the principles of Better Regulation.


For more information, see:

Opposing the EU Tobacco Products Directive

The BBG has opposed the strengthening of the EU Tobacco Products Directive(TPD) as early as 2010, voicing several tobacco industry arguments against plain packaging and increased health warnings, in particular:

  • The TPD breaches international treaties and obligations[2]
  • There is no evidence that the measures will work[2]
  • Removing distinguishable brand features will be time-consuming for retailers[15]
  • Removing packaging design will make it easier to counterfeit and increase illicit tobacco trade[2][15]
  • TPD will have negative unintended consequences that run counter to the policy outcomes the proposal is trying to achieve [15][2]

Most of them echo tobacco industry arguments mentioned above to oppose plain packaging in the UK.

Responding to the Public Consultation

In 2010, the BBG submitted a response to European Commission consultation on the possible revision of the EU Tobacco Products Directive[2], arguing:

The "Group considers that the removal of brand imagery from tobacco packs poses significant and damaging risks for consumers, competition and the proper functioning of the tobacco market, while not necessarily achieving the desired policy goals. It may also breach international treaties and obligations. Clear evidence is required to inform policy and shed light on its likely impact."

Proposing Tobacco Industry-Friendly Amendments

The BBG and several other national brand associations further released a joint statement in March 2013[15], proposing two tobacco friendly amendments to the proposal. Rather than the proposed 75% size of health warnings on a pack, the BGG proposed a decrease to 30%/40%, and also suggested that certain pack feature restrictions should be removed all together.

Position paper of British Brands Group and other national brand associations on the EU Tobacco Products Directive dated 25 March 2013

TobaccoTactics Resources

TCRG Research

Notes

  1. British Brands Group Website, accessed October 2011
  2. 2.0 2.1 2.2 2.3 2.4 2.5 British Brands Group, Packaging of tobacco products. Response to European Commission consultation – the possible revision of the Tobacco Products Directive 2001/37/EC, 3 December 2010, accessed March 2015
  3. 3.0 3.1 3.2 Action for Smoking and Health, The smoke filled room: How big tobacco influences health policy in the UK, 2010, accessed January 2014
  4. Anti-Counterfeiting Group and British Brands Group, A joint response Consultation on the future of tobacco control, 5 September 2008, accessed March 2015
  5. British Brands Group, OFT Annual Plan 2008-09: A response, 15 February 2008
  6. British Brands Group, Unwrapped: The hidden power of packaging. A three-in-one report summarising three significant studies into packaging and consumer behaviour 28 June 2012, accessed February 2013
  7. J. Noble, Plain Packs Won't Stop Smoking, The Grocer, 17 September 2011
  8. British Brands Group, Plain Packaging – A Threat To Brands Brand Briefing, 20 February 2008, accessed March 2015
  9. Hands Off Our Packs, John Noble: Beware “full implications” of plain packs, 16 May 2012, accessed February 2013
  10. British American Tobacco, UK Standardised Packaging Consultation: Response of British American Tobacco UK Limited, 8 August 2012, accessed February 2013
  11. Philip Morris International, Standardised tobacco packaging will harm public health and cost UK taxpayers billions: A response to the Department of Health consultation on standardised packaging of tobacco products,9 August 2012, accessed February 2013
  12. Anti-Counterfeiting Group and British Brands Group, Plain packaging: unforeseen consequences, a briefing for the All Party Groups on Heart Disease and Smoking and Health, 13 January 2012, accessed February 2013
  13. Philip Morris International, UK Corporate Affairs Update February 2012, Leaked in 2013
  14. Philip Morris International, UK Corporate Affairs Update March 2012, Leaked in 2013
  15. 15.0 15.1 15.2 15.3 British Brands Group, BGA, Centromarca, Czech Association for Branded Products (CSZV), Markenverband e.V., Österreichischer Verband der Markenartikelindustrie (MAV), Slovak Association for Branded Goods (SZZV), Position Paper Regarding the Proposal for a Directive of the European Parliament and of the Council on the Approximation of the Laws, Regulations and Administrative proposal Provisions of the Member States Concerning the Manufacture, Presentation and Sale of Tobacco and Related Products – COM(2012)188 Final, 25 March 2013, accessed March 2015