Association of Convenience Stores

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The Association of Convenience Stores (ACS) is an organisation representing 33,500 local shops in the United Kingdom (UK).
In their own words:

“ACS’ core purpose is to lobby Government on the issues that make a difference to local shops. We represent the interests of retailers on a range of issues, including business rates, energy, regulation, planning, alcohol and many more.”1

Relationship with the Tobacco Industry

Tobacco Companies are ACS Members

British American Tobacco (BAT), Imperial Tobacco, Japan Tobacco International (JTI) and Philip Morris Limited UK are “premier club” members of the ACS.2
Premier club members “join ACS as a signal of their support for the industry and a number of exclusive events. Premier Club brings extensive benefits including, premium networking opportunities and insight into the convenience sector at all levels”.2
In a January 2013 letter to the UK Department of Health, ACS’ CEO James Lowman declared that the tobacco companies each paid £23,550 for ACS premier club membership that year.3
In 2012 the tobacco companies had paid £22,860 each in membership fees.4

Japan Tobacco International Sponsored ACS Events

In addition to membership fees, Lowman’s letter revealed that JTI spent at least £10,000 on sponsoring the annual ACS Forecourt Seminar event, and had also sponsored the 2013 ACS Annual Conference.3

Lobbying Against Public Health Measures

The ACS has lobbied against several public health measures including, tobacco track and trace to combat tobacco smuggling567, tobacco plain packaging8, a UK Soft Drinks Industry Levy and increase in cigarette excise910, and measures imposed in the 2001 and 2014 European Union Tobacco Products Directive.1112
Below are details of ACS opposition against the introduction of plain packaging in the UK.

Opposed UK Plain Packaging

Image 1. ACS Plain Packaging Operational Implications, accessed October 201313

In April 2012 the UK Department of Health launched a consultation on the plain packaging of tobacco products. ACS’ CEO Lowman released a press release in which he said: “We welcome the opportunity of this consultation to set out the reasons why plain packs will be a major burden to local shops across the UK.”14
In August the ACS submitted a response to the consultation.8 The submission argued that plain packaging would have a negative operational impact on retailers; that it would lengthen service times, would lead to a loss of retail margin, and had the potential to drive consumers away from the legitimate tobacco market into the illicit trade market (see image 1).13
Its arguments echoed tobacco industry arguments against plain packaging.
The ACS made no fewer than nine recommendations to the UK Government and the Department of Health, stating that it:

1. should adhere to the principles of better regulation when deciding on regulation so that unnecessary burden is not placed upon businesses;

2. should wait for an evaluation of plain packaging in Australia, the first country in the world to introduce this legislation;

3. should conduct a “detailed and reliable analysis of smokers’ response” to plain packaging;

4. should conduct a “consumer study on the likely impact of this policy on counterfeit tobacco products and cross-border sales”;

5. should give careful consideration to the impact plain packaging could have on making illicit trade more attractive, especially to young people and those in deprived communities;

6. should allow time to assess the efficacy of recently introduced tobacco control interventions before introducing further burdens on business;

7. should conduct a full study of the efficacy of all existing tobacco control measures before introducing others;

8. should publish findings of on-going research in a timely manner to allow further consultation with stakeholders;

9. should commission research into the business impact of plain packaging.

British American Tobacco quotes ACS in its Submission

BAT’s submission to the 2012 consultation cited ACS’ concerns, but did not disclose that the tobacco company paid membership fees to the ACS.
On page 51 of BAT’s submission, the company quoted the ACS:
“We also fear that consumers that are used to buying certain brands will react against plain packs and seek them out from the illegal trade. The result would be more consumers placed at the mercy of unscrupulous criminals that run the black market and further loss of trade for legitimate retailers.”15

PMI identified the ACS as an ‘Influencer’

Image 2. PMI’s model of ‘influencers’ on the UK legislative decision-making process

Documents authored by PMI, leaked in mid-2013, revealed that the tobacco company had planned a multi-faceted campaign to oppose the UK government’s plans to introduce plain packaging.1617
In the leaked presentations, PMI identified all those whom it considered to be major players in the UK legislative decision-making process.
PMI named “key committees” 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.
PMI also detailed a model centred around UK Prime Minister David Cameron, the “decision maker” (see Image 2). 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. Included amongst the lobby groups identified by PMI as influencers was the ACS.
For more information, see pages on PMI’s Anti-Plain Packaging Lobbying Campaign and PMI’s Anti-PP Media Campaign.

ACS Vocal Against Plain Packaging in Second UK Consultation

On 26 June 2014 the UK Government published its second consultation on plain packaging.
Later that day, Lowman (CEO of ACS) stated “Ministers have consistently failed to accept the evidence about how disruptive and burdensome recent tobacco control measures have been for the tens of thousands of retailers that have to actually implement them”.18
This serves as another example of the ACS representing themselves as an independent organisation communicating on behalf of the UK’s retailers without disclosing their links to the tobacco industry.

Opposed tobacco endgame 

The ACS has lobbied against proposed tobacco endgame policies in the UK.19 For details see Tobacco Industry Interference with Endgame Policies. 


The ACS provides the Secretariat for the All Party Parliamentary Small Shops Group.2021

TobaccoTactics Resources

TCRG Research

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  1. Association of Convenience Stores, About us, accessed December 2017
  2. abAssociation of Convenience Stores, Premier Club, accessed December 2017
  3. abJ. Lowman, ACS’ Commercial Relationship with Tobacco Manufacturing Organisations. Letter dated 31 January 2013, addressed to the Deputy Director, Tobacco and Responsibility Deal, UK Department of Health, ACS website, accessed December 2017
  4. ACS, Consultation on Standardised Packaging of Tobacco Products: Response of the Association of Convenience Stores, 2012
  5. ACS Calls On Treasury Minister To Consider Retail Impact of Track and Trace Regulations,, 1 December 2017, accessed December 2017
  6. Association of Convenience Stores, ACS Submission: Implementing act under Article 15(11)of the Tobacco products Directive 2014/40/EU, ACS website, undated, accessed December 2017
  7. Association of Convenience Stores, Home Affairs Select Committee Inquiry into Tobacco Smuggling Submission from ACS, ACS website, undated, accessed December 2017
  8. abAssociation for Convenience Stores, Consultation on Standardised Packaging of Tobacco products Response of the Association of Convenience Stores, ACS website, undated, accessed December 2017
  9. Association of Convenience Stores, ACS Submission to HMRC Consultation on the Draft Finance Bill 2017, ACS website, undated, accessed December 2017
  10. Association of Convenience Stores, ACS Submission: Minimum Excise Tax, ACS website, undated, accessed December 2017
  11. Association of Convenience Stores, ACS Response to the Consultation on Revising the Tobacco Products Directive 2001/13/EC, ACS website, undated, accessed December 2017
  12. Association of Convenience Stores, ACS Briefing to ENVI Committee Members, Draft Tobacco Products Directive, ACS website, 2 May 2013, accessed December 2017
  13. abAssociation for Convenience Stores, for wholesalers and retailers under the proposed unbranded, or plain, tobacco packaging regulations, ACS website, undated, accessed December 2017
  14. Association of Convenience Stores, Department of Health Launches Plain Packaging Consultation, 16 April 2012
  15. British American Tobacco, UK standardised packaging consultation: Response of British American Tobacco UK Limited, 8 August 2012
  16. Philip Morris International, UK Corporate Affairs Update February 2012. Leaked in 2013
  17. Philip Morris International, UK Corporate Affairs Update March 2012, Leaked in 2013
  18. Retail Gazette, Plain Cigarette Packaging Will Hurt Convenience Stores, Claims ACS, 26 June 2014, accessed June 2014
  19. Association of Convenience Stores, ACS Calls for Better Regulation of Vaping Market and Explains Practical Challenges of Generational Tobacco Ban, website, 5 December 2023, accessed December 2023
  20. Register of All-Party Parliamentary Groups (as at 30 July 2015), All-Party Parliamentary Small Shops Group, 30 July 2015, accessed December 2017
  21. Register of All-Party Parliamentary Groups (as at 15 February 2017), All-Party Parliamentary Small Shops Group, 15 February 2017, accessed December 2017