Tobacco Industry Attempts to Undermine the FCTC Illicit Trade Protocol (ITP)

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A 2015 article in The Lancet outlined how the tobacco industry, despite its long history of involvement in the illicit tobacco trade, has over the last 15 years used its vast resources in its efforts to control every aspect of the debate over the illicit tobacco trade [1] The tobacco industry has been manipulating the problem of tobacco smuggling for policy gain, using multiple tactics including extensive use of Third Party Techniques.

Industry Tactics and Influence

Tobacco industry attempts to influence the World Health Organisation’s (WHO) Framework Convention on Tobacco Control (FCTC) began as early as 1997, when PMI commissioned the consultancy group Mongoven, Biscoe & Duchin Inc. (MBD) to write two white papers for them.[2][3] Aiming to derail the FCTC was deemed to be unrealistic, however, it was suggested that PMI could have an influence on the final texts.[4] PMI were advised to try and influence the drafting of the FCTC through collusion with Governments that have tobacco-related interests and by working with other international agencies [5]

These recommendations led to multiple moves by PMI to attempt to influence the FCTC, including attempts to secure WHO accreditation for industry-aligned NGOs so that industry positions could be represented at FCTC negotiations.[6] PMI and other tobacco manufacturers also “cultivated relationships with tobacco-friendly governments” [4] such as Japan and Malawi[7] in attempts to weaken the FCTC.

Internal documents from 2000-2001 include examples of PMI attempting to influence the FCTC in relation to smuggling specifically. In 2000, for example, PMI argued to the US Departments of Commerce and Health and Human Services that Government involvement with the tobacco industry would be a more-effective way of combating illicit trade than the measures put forward in the FCTC [8] MBD also suggested that future protocols following on from the FCTC would have a bigger impact on the tobacco industry than the FCTC itself and so should be considered PMI’s main focus. [4]

TobaccoTactics Resources


  1. A. Gilmore, G. Fooks, J. Drops et. al. Exposing and addressing tobacco industry conduct in low-income and middle-income countries, The Lancet, 2015,385(9972): 1029-1043, accessed October 2016
  2. Mongoven, Biscoe & Duchin Inc. An Analysis of the International Framework Convention Process, 1997, accessed September 2016
  3. Mongoven, Biscoe & Duchin Inc. An Analysis of Non-Governmental Organizations from a United Nations Perspective, 1997, accessed September 2016
  4. 4.0 4.1 4.2 M. Gonzalez, L. Green, S. Glantz Through tobacco industry eyes: civil society and the FCTC process from Philip Morris and British American Tobacco’s perspectives, Tobacco Control, 2011,21(4)e1-9, accessed October 2016
  5. H. Mamudu, R. Hammond, S. Glantz Tobacco industry attempts to counter the World Bank report Curbing the Epidemic and obstruct the WHO framework convention on tobacco control Social Science & Medicine, 2008,67(11):1690-1699, accessed October 2016
  6. D. Bushong Email to Wendy Burrell, Mark Berlind, Anne Kush, Matt Winokur Wednesday April 08 1998 5:14 pm. Philip Morris, accessed September 2016
  7. M. Assunta, E. Dorotheo, SEATCA Tobacco Industry Interference Index: a tool for measuring implementation of WHO Framework Convention on Tobacco Control Article 5.3, Tobacco Control, 2015,25(3):313-318, accessed October 2016
  8. PMI Response to Request for Public Comment on the Framework Convention on Tobacco Control Requested by the United States Departments of Commerce and Health and Human Services 15 March 2000, 2000, accessed September 2016