Plain Packaging Opposition in the UK: 2012 Consultation

From TobaccoTactics
Share/Save/Bookmark
Jump to: navigation, search

Background

In the UK, tobacco companies Imperial Tobacco, Japan Tobacco International (JTI), British American Tobacco (BAT) and Philip Morris International (PMI) have publicised their arguments against plain packaging using:

  • their corporate websites;
  • political advertising campaigns;
  • submissions to the two UK Consultations on plain packaging;
  • third-party voices.

The plain packaging of tobacco products was first suggested in Canada, New Zealand, the UK and Australia in the mid-1980s and early 1990s. Tobacco companies and their associates have been working on a defence strategy against the threat of plain packaging since this time. See the History of Plain Packaging: Developing the Intellectual Property Argument for detailed information on the development of this strategy. Nearly two decades later in 2010, industry analyst Citigroup noted that plain packaging was the “biggest regulatory threat to the industry, as packaging is the most important way tobacco companies have to communicate with the consumer and differentiate their products.” [1]

Tobacco companies are aware of how important packaging is to marketing, especially in countries that do not permit any other forms of advertising. For example, a Philip Morris marketing executive stated in 1994:

"In the absence of any other Marketing messages, our packaging -- comprised of the trademark, our design, color and information -- is the sole communicator of our brand essence. Put another way -- when you don't have anything else -- our packaging is our Marketing." [2]

Taking each tobacco company in turn, this page highlights some key examples of the aforementioned activities particularly during the UK government’s first public consultation on the plain packaging of tobacco products which took place between 16 April 2012 and 10 August 2012. It is not exhaustive.

Imperial Tobacco

In 2011, when the UK government first announced that it would hold a public consultation on plain packaging , Imperial Tobacco held the largest share of the UK cigarette market with 43.1%.[3] During the first consultation in 2012, the company engaged in corporate political advertisingin an attempt to influence the views of the general public and most importantly politicians.

Attempts to Influence the General Public

Imperial produced a YouTube advert called Britain - 2020 Vision?, which misleadingly suggested that by 2020 all perceptibly unhealthy products would be sold in plain packaging. [4] The 2020 Vision advert was promoted on leaflets distributed to the public, with the message "Say NO to plain packs". The leaflets were not openly attributable to Imperial Tobacco or the Hands Off Our Packs campaign, which uploaded the advert to YouTube (see images 1 and 2).

Speaking in May 2012, Imperial CEO, Alison Cooper, stated that plain packaging would be a gift to criminal gangs and terrorists. Cooper said: "Do we really want to hand business like this to gangs in Eastern Europe funding crime and even, in some cases, terrorists?” Reporting on Cooper's remarks, The Sun newspaper ran a sensationalist headline (Image 3). It argued that "groups who benefit from such trade include al-Qaeda and Hezbollah." [5] There is no independent evidence that plain packaging will increase illicit trade, increase crime or terrorism.[6][7][8]

Attempts to Influence MPs

Imperial also attempted to influence UK MP’s views on plain packaging. The company funded an advert in The House magazine (a weekly political magazine delivered directly to MPs, Peers, and civil servants), whereby the normal cover pages of the magazine were covered with dark brown/gold plain packaging, with a warning message, mimicking those found on tobacco packets, which read, “WARNING Plain Packaging: Bad for business Good for Criminals” (Image 4). [9] The double spread cover page did not disclose it was an Imperial Tobacco advertising campaign.

It was only on page 19 of the magazine that a second gold coloured full-page advert explained, in a smaller font than the rest of the text at the bottom of the page and with no explicit link to the cover advert, “This advert has been produced and placed by Imperial Tobacco in association with Asian Trader magazine.”[9]

More information on this advertisement, and the debate that followed, can be found on Imperial Tobacco Promotes Opposition to Plain Packaging.

Imperial Tobacco’s UK 2012 Consultation Response

In Imperial Tobacco’s Submission to the 2012 UK Consultation on standardised packaging, the company put forward the following arguments against the introduction of plain packaging legislation in the UK.

  • No credible evidence or research that plain packaging would reduce smoking prevalence

AND, plain packaging will:

  • Increase the trade in illicit tobacco;
  • Put the government in breach of national, European and international law.

Furthermore it argued that:

  • The consultation process was fundamentally flawed;
  • Plain packaging goes against the government’s principles and objectives.

Click on thumbnails to enlarge images.

Japan Tobacco International

In 2011, JTI owned the second largest proportion of the UK cigarette market (37.1%).[3] Approximately 24-hours after the British government announced a 4-week extension to the first consultation on plain packaging on 10 July 2012, JTI launched an anti-plain packaging campaign costing £2 million to “share its views”.[10][11][10]

According to JTI, this spending was to ensure a wide reach of its messages to JTI’s target audience, “both government and decision makers”. [10] Adverts were included in a number of daily newspapers including The Financial Times and The Guardian (see Image 5 and Image 6).[12] The adverts specifically claimed that the UK government had considered plain packaging previously and had ‘rejected’ the idea ‘when it was found to have no credible evidence’ for success.[12] The adverts appeared online as well as in print (Image 7).

In September and October 2012, a second wave of the JTI campaign promoted the potential detrimental impacts of plain packaging on the illicit tobacco trade with a knock on effect for small businesses. This wave of advertising consisted of full page adverts in The Financial Times, The Times, The Telegraph, The Guardian and the Evening Standard and ran over a two week period. Martin Southgate, then Managing Director of JTI said that this wave of the campaign “was timed to coincide with the party political conference season”, in order to reach an unprecedented number of MPs and opinion formers.[13] This can be seen as an example of indirect lobbying.

Action for Smoking and Health (ASH) London, ASH Scotland and Cancer Research UK complained to the Advertising Standards Agency (ASA) that the claims made by JTI in both adverts were misleading.[14]

On 13 March 2013, the ASA upheld the complaint pertaining to the first wave of advertising.

“We acknowledged the numerous statements regarding the issue of plain packaging which had been provided by JTI, and which they considered demonstrated both that the government had rejected the policy in 2008 and that it had done so because it lacked the evidence to support it. However, although the government had decided not to take forward the proposal for plain packaging in the same way as it did with other measures considered in the consultation, we understood that they had nevertheless intended to keep the measure under review and planned to re-assess it at a later date. We therefore considered that the claims in the adverts that the policy had been ‘rejected’ in 2008 because of a lack of credible evidence gave a misleading impression of the position and action taken at that time by the government and concluded that the adverts breached the [advertising] code.” [15]

A month later, in April 2013, the ASA ruled that the second set of adverts (September and October 2012) were also misleading. The ASA ruled that JTI could not claim that “the black market in tobacco is booming”. Nor could they claim that the UK had suffered “£3 billion lost in unpaid duty last year”. The ASA noted that this figure was the very upper limit of an estimate of revenue loss by Her Majesty’s Revenue and Customs (HMRC) – in reality the figure was likely to be far lower.[16]

HMRC figures show that the illicit market for cigarettes in the UK has more than halved in a decade. The ruling noted that JTI had themselves acknowledged that the illicit trade in tobacco products has reportedly been a declining trend in the last ten years.

Despite the rulings of the ASA against JTI’s first two waves of advertising, later in April 2013, in response to political speculation that plain packaging would be incorporated into the government’s legislative programme and announced in the Queen’s Speech in May 2013, JTI launched a third wave of print advertising (Image 8). This time the advert featured a full page 2011 letter from the UK Department of Health to the Australian government. The letter asked what evidence the Australian government had to support plain packaging legislation. JTI’s Managing Director in the UK Jorge da Motta told Packaging News: “We are using this media campaign to demonstrate that in 2011 even the Department of Health accepted that these proposals are not supported by any hard evidence.” However, JTI did not mention that since the time this letter was penned a considerable amount of plain packaging research was conducted both in the UK and elsewhere.

A 2012 systematic review by the Public Health Research Consortium of 37 studies of the potential impacts of plain tobacco packaging found that when branding is removed from tobacco packaging, health warnings are more salient, packs appear less attractive and of a lower quality and there is less confusion about the relative harm from different brands.[17] In March 2015, a series of studies evaluating the impact of plain packaging in Australia were published in the peer-review journal Tobacco Control. For more a summary of these studies please visit Countering Industry Arguments Against Plain Packaging: No Evidence Plain Packaging Will Work.

JTI UK 2012 Consultation Response

In Japan Tobacco International’s Submission to the UK 2012 Consultation on standardised packaging the company argued that:

  • there is no evidence that plain packaging will work;
  • the consultation process of the Department of Health is flawed;
  • plain packaging will have serious unintended consequences.

To support its arguments JTI attached 12 research reports from “independent experts” along with their submission.

“JTI’s views are based on our experience of how competition between branded consumer goods works, our careful review of the documents forming part of the current consultation, as well as the independent opinions of leading experts, whose reports are being submitted with this response.”(p2)[18]

Each of the 12 reports cited in the JTI submission, written by “leading experts” with “independent opinions”, was financially supported by JTI and therefore arguably not independent.[19] This is an example of a well-worn industry tactic of Hiring Independent Experts.

British American Tobacco

In 2011, BAT owned 8.1% of the UK cigarette market.[3] BAT did not take out adverts in its own name in the UK, like it did in New Zealand where it owned over 80% of the market share in cigarettes, nevertheless the company has actively lobbied against plain packaging in the UK.

Firstly, BAT created two emotive You Tube adverts to suggest that plain packaging would increase illicit trade and consequently increase organised crime, including sex trafficking and terrorism.[20][21]

BAT’s UK Consultation Response

British American Tobacco’s Submission to the UK 2012 Consultation on standardised packaging argued that plain packaging would:

  • Not be effective in reducing smoking prevalence as tobacco packaging is not a relevant factors in people’s decision to smoke or quit;
  • Exacerbate the significant illicit trade problem in the UK;
  • Lower cigarette prices, thereby increasing smoking, reducing government revenue and harming small businesses;
  • Breach UK, EU and international laws and agreements and “constitute a wholesale expropriation of BAT’s valuable intellectual property” costing the government significant compensation.

BAT also criticised the Department of Health for not considering the “relevant research”, claiming instead that it relied on insufficient and unreliable evidence and that it has failed to demonstrate that the benefits would outweigh the adverse consequences.

See BAT Funded Lobbying Against Plain Packaging for BAT’s lobbying activities in the UK, Australia and New Zealand, including the its funding of third-party campaigns against plain packaging.

Philip Morris International

PMI, the largest transnational tobacco company in the world, owned approximately 8% of the UK market share in cigarettes in 2011.[3] Nevertheless, PMI engaged in extensive lobbying activity in the UK – most notably pushing the so-called “illicit trade” argument.

In 2013, PMI published their annual “Project Star” report (produced by KPMG) several months earlier than it had done in previous years. Given that the results suggested that illicit trade increased by a quarter of the legal market compared to the fourth quarter of 2012, the early publication could be seen as a deliberate attempt to influence the outcome of the consultation. Project Star’s findings were in direct contradiction to official figures suggesting that illicit trade in the UK was decreasing. [22]

Furthermore, the Project Star report was “traditionally agreed with OLAF (EU anti-fraud office) and member states in advance of publication but this year’s [2013] had not been.” [23]

PMI also employed the public relations firm Luther Pendragon to try and create a grassroots rebellion amongst UK MPs, but the PR firm severed its ties with the company following criticism from leading health organisations. PMI replaced Luther Pendragon with a deal with the Crosby Textor Group and lobbyist Lynton Crosby in November 2012. This was an extremely controversial appointment as Crosby had also been appointed as a political advisor to the Conservative Party that very same month.[24]

Furthermore, leaked Philip Morris International (PMI) corporate presentations from 2012 revealed that the company had meticulously planned an extensive multifaceted public relations campaign against Plain Packaging in the UK, including a highly detailed media campaign, a strategy to mobilise opposition from retailers, and scaremonger about illicit trade and detailed political analysis of the best ways to prevent the implementation of the policy. See below for links to other pages on the leaked PM documents:

PMI UK 2012 Consultation Response

Philip Morris’ Submission to the UK’s 2012 Consultation on standardised packaging argued that:

  • The evidence does not meet the standards set by the Department of Health and that PMI only supports regulation proven to be effective in reducing youth smoking.

It, like the other three companies insisted that plain packaging will:

  • …not reduce youth smoking and may actually encourage it;
  • …not make it easier to quit smoking;
  • …increase the level of illicit tobacco in the UK;
  • …require the government to compensate tobacco companies, costing taxpayers billions.

Use of Third-Parties in Consultation Responses

Each of the big four tobacco companies presented evidence to support their arguments in their submissions to the plain packaging consultation. This evidence took a number of forms, from peer-reviewed journal articles, to tobacco industry funded reports, to the opinions of trade organisations, MPs and police officers. A significant proportion of the people and organisations cited as independent from the industry had significant conflicts of interest; being either entirely industry-funded front groups or industry-linked through membership fees, research funding or vested interests (e.g. retailers and packaging companies who believe that their business is going to be damaged by plain packaging).[25]

Use of Third-Party Evidence to Support ‘Unintended Consequences’ Argument

Tobacco companies cited evidence from financially linked third parties to support its arguments that plain packaging would lead to an increase in illicit tobacco trade in the UK with an associated increase in crime and a detrimental impact on small businesses.[25] Some organisations cited were industry front groups, others were commissioned to write reports at the request of individual tobacco companies and some were lobby groups that listed tobacco companies as fee paying members. In the majority of cases the tobacco companies, in their submissions, did not disclose any links between authors of the evidence and themselves. It should be noted however, that the actual pieces of evidence, for the most part, did disclose the link.

This is a problem when policymakers reviewing each tobacco company’s consultation submission do not know that these individuals and organisations are associated with the industry without further investigation, i.e. looking at each piece of evidence referred to by the tobacco companies. Given the volume of detailed responses to the consultation received by the Department of Health, checking the independence of each piece of evidence would be an extremely time consuming exercise.

The following tables provide details of organisations and people cited in the industry’s 2012 submissions in order of proximity with the tobacco industry. Listed first in alphabetical order are front groups, followed by a list of those paid by tobacco companies to write reports or give opinions, followed thereafter by those with vested interests, for example, packaging companies, trade organisations and lobby groups with tobacco industry members.

The majority of the individuals or organisations listed include a hyperlink to a more detailed page explaining their relationship with the tobacco industry.

Front Groups

Some front groups are likely to be known to policy makers, for example, the Tobacco Manufacturers' Association, however in many cases affiliations are less intuitive.

Organisation Funded by Argument Cited by
Alliance of Australian Retailers[26] PM Limited, BAT and IT[27] The Alliance which was entirely conceptualised and funded by tobacco companies in Australia commissioned a report by Deloitte. See Deloitte in the next table. PMI, JTI, IT
Tobacco Manufacturers' Association[28][29] BAT, JTI, IT[30] Counterfeit cigarettes account for 13% if the illicit market compared to 1% in 2004. Plain packaging will have detrimental economic impacts as an estimated 66,000 jobs among suppliers wholesalers, distributors and retailers are dependent on the UK tobacco industry. BAT, JTI
Tobacco Retailers Alliance [31] TMA [32] Small retailers will suffer as increased transaction times send customers to the larger retailers. BAT

Commissioned Opinions and Reports

Organisation Commissioned by Argument Cited by
Deloitte[26][33] PMI Visits to small stores will decrease due to an increased demand for illicit tobacco and as well as increased transaction times sending customers to larger supermarkets. PMI, JTI, IT
Dr Andrew Lilico from Europe Economics[34][35] JTI Plain packaging will lead to an increase in price competition and a downward trend in prices, which in turn will lead to an increase in demand. BAT, JTI
Lord Hoffman PMI The UK government may have to pay tobacco companies compensation for “depriving someone of his proprietary interest in a trade mark for a tobacco product...” PMI
KPMG PMI Illicit tobacco is a big problem in the UK costing the treasury £3.1 billion per year. PMI
Professor Ernesto Savona and Dr Francesco Calderoni at Transcrime[36] PMI Plain packs will increase illicit trade because, 1) plain packs will be easier and cheaper to counterfeit, 2) Consumers may prefer illicit branded packs over unbranded legal products, 3) tax increases in response to price competition may drive consumers to the illicit trade. PMI, BAT
Professor Alan Zimmerman and Professor Peggy Chaudhry[37] JTI Plain packaging will create opportunities for illicit traders and make it more difficult for law enforcement and consumers to differentiate been legitimate and illicit products. JTI

Vested Interests

Organisation Connection with Industry Argument Cited by
Anti-Counterfeiting Group (ACG)[38][39] Tobacco industry are fee paying members of the ACG.[40] Plain packs will ‘open the floodgates’ to branded illicit packs and at the same time plain packs will be easier to counterfeit and more difficult to detect. BAT, PMI
Association of Convenience Stores (ACS)[41] Tobacco companies are members of the ACS.[42] Plain packaging will lead consumers to buy illicit branded packs. “The result would be more consumers placed at the mercy of unscrupulous criminals that run the black market…” BAT, JTI
Business Action to Stop Counterfeiting and Piracy (BASCAP)[43] BAT disclosed on the EU Transparency register 2013 that it is a member of BASCAP.[44] See also International Chamber of Commerce. Plain packaging will make counterfeiting easier and it will “increase the burden on already overstretched public agencies as they try to keep illicit products away from consumers.” BAT, JTI
British Brands Group[45][39][38][46] Big four are fee-paying members of the British Brands Group.[47] PP would set a precedent and put off companies looking to invest in the UK this would have an adverse impact on the economy. Furthermore, the impact on the illicit market will be huge. BAT, PMI, JTI, IT
Confederation of British Industry (CBI) Industry are members,[48] BAT’s ex-CEO Martin Broughton had close ties with the group and became its president between 2007 and 2009.[49] Plain packaging would set a precedent and put off companies looking to invest in the UK this would have an adverse impact on the economy. Furthermore, the impact on the illicit market will be significant. IT
European Carton Makers Association (ECMA)[50][51] Receive tobacco industry business.[44] Plain packaging will make counterfeiting easier. Pictorial health warnings pose no problem for counterfeiters – these can be reproduced using low cost printing. Current packaging uses design features such as embossing, debossing, hotfoil stamping and UV varnish and typically use 8-10 unique colours from state of the art printing equipment. “It is therefore, the branding on a cigarette pack that counterfeiters find difficult to replicate and that allows retailers and the public to differentiate between real and counterfeit products.” BAT, PMI
International Chamber of Commerce (ICC) UK[52] BAT is a member of the ICC.[44] Philip Morris International is listed as a member of the ICC’s American affiliate the US Council for International Business.[53] PP would set a precedent and put off companies looking to invest in the UK this would have an adverse impact on the economy. Furthermore, the impact on the illicit market will be huge. BAT, JTI, IT
International Tax and Investment Center (ITIC)[54] Tobacco industry are fee paying members of the ITIC.[55] Illicit cigarettes are smuggled by criminal gangs who operate in our local communities. These gangs also bring smuggled alcohol, guns, drugs and violence. “The man on the corner selling cigarettes to kids from the boot of his car is not acting alone – his sales fund serious organised crime and terrorism. PMI
National Federation of Retail Newsagents (NFRN)[56][57] Received industry funding for an anti-point of sale display ban campaign.[58] Price competition resulting from plain packaging will disproportionately affect small retailers who rely more on the profit. BAT, IT
Nude Brands Consulting Limited[59] JTI is a client. JTI does disclose this in its submission to the consultation. JTI accounts for approximately 75% of Nude Brands’ business. JTI
Parkside, Chesapeake, Weidenhammer Packaging Group, Amcor, API Group[60] Receive tobacco industry business. Plain packaging will undermine the legitimate economic interests of packaging companies. BAT,JTI, IT
Roy Ramm,[61] Former Commander of Specialist Operations for New Scotland Yard, Founding Member of The Common Sense Alliance. BAT provides financial support to The Common Sense Alliance.[62] Plain packaging will increase organised crime and children will be buying branded packets from criminals. PMI
Scottish Grocers' Federation[56] Imperial Tobacco, British American Tobacco and Japan Tobacco International supply 9.7% of the money they receive from supplier memberships.[63] Given that we already have a Point of Sale Display ban plain packaging is “an absurd example of over regulation”. BAT
Peter Sheridan, Former Assistant Chief Constable of Northern Ireland,[64] Founding Member of The Common Sense Alliance. BAT provides financial support to The Common Sense Alliance.[62] Plain packaging will open the floodgates to illicit whites and make life easier for criminals. PMI

TobaccoTactics Resources

See Countering Industry Arguments against Plain Packaging for the public health counter arguments to the company arguments above.

TCRG Research

Notes

  1. P. Smith, P. Kwan Yuk, Australia plans cigarette packet branding ban, The Financial Times, 29 April 2010, accessed March 2012
  2. M. Hulit, Marketing Issues Corporate Affairs Conference, Philip Morris, Manila, 27 May 1994
  3. 3.0 3.1 3.2 3.3 Euromonitor International, Company shares by Global Brand Owner Historic UK 2011, accessed August 2012
  4. Imperial Tobacco, Britain 2020 Vision uploaded to You Tube by HandsOffOurPacks 1 May 2012, accessed July 2012
  5. Steve Hawkes, "Fag packet ban 'boosts terror' - Move is ‘gift to black market’ says boss”, The Sun, 25 May 2012
  6. Luk Joossens, Smuggling, the Tobacco Industry and Plain Packs, Cancer Research UK, November 2012
  7. M.Scollo, M. Bayly, M. Wakefield. Availability of illicit tobacco in small retail outlets before and after the implementation of Australian plain packaging legislation. Tobacco Control doi:10.1136/tobaccocontrol-2013-051353, [published online first 10 April 2014], accessed May 2014
  8. M. Scollo, M. Zacher, K. Coomber, M. Wakefield. Use of illicit tobacco following introduction of standardised packaging of tobacco products in Australia: results from a national cross-sectional survey. Tobacco Control, 2015:24:ii76-81 DOI:1036/tobaccocontrol-2014-052072
  9. 9.0 9.1 “The House”, Parliament’s Magazine, Dods, No.1419, Vol 36, 14 June 2012
  10. 10.0 10.1 10.2 Japan Tobacco International Challenging UK ‘plain’ cigarette packs, accessed July 2012
  11. The Grocer, JTI takes aim at "flawed" dialogue on plain packaging, 6 July 2012, accessed July 2012
  12. 12.0 12.1 ”The Financial Times”, It’s not worth the paper it’s written on, 10th July 2012, p5
  13. Asian Trader, Full page adverts in national warn of dangers of plain packaging, 22 October 2012, accessed October 2012
  14. M. Sweney, ASH and Cancer Research win ban on adverts attacking plain cigarette packs, 13 March 2012, Accessed March 2013
  15. Advertising Standards Agency, ASA adjudication on Gallaher Ltd, 13 March 2013, Accessed March 2013
  16. Cancer Research UK, Further adverts from Japan Tobacco International ruled misleading, Press release, 17 April 2013, accessed May 2013
  17. Public Health Research Consortium, Plain Packaging: a systematic review, November 2012, accessed May 2013
  18. Japan Tobacco International, Response to the Department of Health’s Consultation on the Standardised Packaging of Tobacco Products, 3 July 2012
  19. JTI,Japan Tobacco International’s Submission to the UK Consultation on standardised packaging, August 2012, accessed June 2013
  20. BAT, This is the man, accessed June 2012
  21. BAT, Who’s in Control?, accessed June 2012
  22. HMRC, Measuring Tax Gaps 2012, Tax gap estimates for 2010-11, 18 October 2012, accessed June 2013
  23. A. Ralph, Anti-fraud office fuming over British American Tobacco’s survey claim, The Times, 27 May 2013
  24. j. Doward, David Cameron urged to probe claim that aide had £6m tobacco deal, The Observer, 20 July 2013, accessed May 2016
  25. 25.0 25.1 K. A. Evans-Reeves, J. L. Hatchard, A. Gilmore, ‘It will harm business and increase illicit trade’: an evaluation of the relevance, quality and transparency of evidence submitted by transnational tobacco companies to the UK consultation on standardised packaging 2012, Tobacco Control, 2015,24(e2):e168-e177
  26. 26.0 26.1 Deloitte Australia, Alliance of Australian Retailers: Plain packaging and channel shift, June 2011, accessed August 2013
  27. Ballyhoo, Alliance of Australian Retailers media investment reconciliation to The Civic Group, 30 August 2010, Bates No: PLAIN00016, accessed August 2013
  28. B. Fenton, Security Liaison Officer,Sizing the non-duty paid market, Tobacco Manufacturers’ Association, 2011, accessed August 2013
  29. TMA, The UK Tobacco Sector, May 2012, accessed August 2013
  30. TMA, About us, 2010, accessed August 2013
  31. Tobacco Retailers Alliance, Newsletter, November 2011, accessed June 2013
  32. TMA, Statement to Accompany Account Submitted to TMA Board of Directors, 20 February 2001, accessed August 2013
  33. Deloitte Australia, Alliance of Australian Retailers: Potential impact on retailers from the introduction of plain tobacco packaging, February 2011, accessed August 2013
  34. Europe Economics, Economic analysis of a display ban and/or a plain packs requirement in the UK, A report for Japan Tobacco International, 2 September 2008
  35. Europe Economics, Economic analysis of a plain packs requirement in the UK, A report for Japan Tobacco International, 29 June 2012
  36. E. Savona & F. Calderoni, Transcrime, Plain packaging and illicit trade in the UK, May 2012, accessed August 2013
  37. A. Zimmerman & P. Chaudhry, The impact of plain packaging on the illicit trade in tobacco products, 29 June 2012, accessed August 2013
  38. 38.0 38.1 PR Newswire, Plain packaging – A leap in the dark, 16 April 2012, accessed August 2013
  39. 39.0 39.1 ACG & BBG, Plain packaging: Unforeseen consequences, a briefing for the All Party Groups on Health Disease and Smoking & Health, 13 January 2012, accessed August 2013
  40. ACG, Members, accessed September 2013
  41. Talking Retail, Independent newsagents fear boost to illicit trade from plain tobacco packaging, 16 April 2012, accessed August 2013
  42. ACS, Premier Club, accessed April 2013
  43. ICC, BASCAP comments denounce proposed Australian plain packaging regulation, 20 October 2011, accessed August 2013
  44. 44.0 44.1 44.2 EU Transparency Register, British American Tobacco, 20 January 2013, accessed September 2013
  45. Hands Off Our Packs, John Noble: Beware ‘full implication of plain packs, 16 May 2012, accessed August 2013
  46. P. Dobson, A. Yadav, Packaging in a market economy: The economic and commercial role of packaging communication, Commissioned by the British Brands Group, 28 June 2012, accessed August 2013
  47. ASH, The smoke filled room: How big tobacco influences health policy in the UK, 2010, accessed September 2013
  48. K. E. Smith, G. Fooks, J. Collin, H. Weishaar, S. Mandal, A. Gilmore, "'Working the system' British American Tobacco's influence on the European Union Treaty and its implications for policy: an analysis of internal tobacco industry documents", PLoS Medicine, 2010, 7(1), e1000202
  49. NNDB, Martin Broughton, profile, accessed March 2013
  50. European Carton Makers Association, Submission to the Consultation on the revision of the European Tobacco Products Directive, date unknown. The Carton Makers should not be confused with the European Cigars Manufacturers Association, going by the same acronym and lobbying against plain packaging too.
  51. A. Blaschke, President of the ECMA, Plain packaging for cigarettes will ease counterfeiting. 10 May 2012
  52. PR Newswire, ICC stresses need for wider perspective on plain packaging, 13 April 2012, accessed August 2013
  53. US Council for International Business, List of USCIB members, USCIB website, Accessed June 2013
  54. International Tax and Investment Center, The illicit trade in tobacco products and how to tackle it, 19 April 2011, accessed August 2013
  55. ITIC, Sponsors, accessed June 2012
  56. 56.0 56.1 Talking Retail, Independent newsagents fear boost to illicit trade from plain tobacco packaging, 16 April 2012, accessed August 2013
  57. NFRN, Response to the UK Future of Tobacco Control Consultation. 2008
  58. The Guardian, BAT admits bankrolling newsagents' tobacco campaign, 28 April 2011, accessed 15 July 2011
  59. Nude Brands Consulting Ltd, Letter to Emily Thornberry MP, 25 April 2012
  60. API Group plc, Weidenhammer Packaging Group, Chesapeake Branded Packaging, Parkside Flexibles, Amcor Tobacco Packaging, Letter to Mark Prisk MP, Minister for Business, Innovations and Skills, 2 May 2012
  61. R. Ramm, Government plans for plain packaging will boost illicit trade, The Huffington Post, 2 July 2012, accessed August 2013
  62. 62.0 62.1 Simon Millson of BAT, Letter to Deborah Arnott CEO of ASH, 20 May 2013
  63. Scottish Grocers’ Federation, Standardised packaging of tobacco products: Consultation response from the Scottish Grocers’ Federation, undated, accessed September 2013
  64. P. Sheridan, Plans for plain packaging of cigarettes are a charter for organised crime and a danger to our children, The Daily Mail , 22 June 2012, accessed August 2013