Countering Industry Arguments Against Plain Packaging: No Evidence Plain Packaging Will Work

This page was last edited on at

Plain tobacco packaging was extended to the UK and Ireland in May 2016,12 three and a half years after it was first introduced in Australia in December 2012.3 France is due to follow suit in January 20174 and Bulgaria, Canada, Finland, Hungary, New Zealand, Norway, Singapore, South Africa, Sweden and Turkey are also formally considering the measure.5
As with other tobacco control measures, the tobacco industry have consistently argued that there is no evidence to show that plain packaging works; have sought to raise the required standard of evidence to include ‘real-world’ evidence pre-implementation; and have used public consultations as an opportunity to present their own commissioned evidence to governments.6
This page recounts the tobacco industry’s historical tactic of using evidence to oppose tobacco control policy and the importance they place on branding and packaging as marketing tools. It then describes the shortcomings of tobacco industry evidence on plain packaging and describes the growing body of public health evidence prior to and following the policy’s implementation in Australia.

Tobacco Industry Use of Evidence to Oppose Policy

The tobacco industry’s attempts to deny the evidence, even when evidence exists, is a tactic aimed at influencing public opinion. Placing this argument in the public domain creates a level of doubt which permeates even when credible evidence is presented to the contrary. This tactic has been used to oppose earlier policies (such as advertising bans and smoke-free legislation) which were strongly associated with positive health outcomes and reductions in health inequalities.7891011121314 1516
Insisting on real world evidence before regulating, as the tobacco industry has argued in the case of plain packaging,6 would effectively place a block on all new laws likely to promote public health and welfare, irrespective of advances in scientific knowledge.
In opposing plain packaging, the tobacco industry has used the principles and processes (public consultations and impact assessments) of Better Regulation to support its argument that there is insufficient evidence to support the implementation of the policy.17 Better Regulation was lobbied for by the industry and requires risks, costs and benefits to be weighed against one another before new regulatory burdens are placed on businesses. 181920

Flawed Tobacco Industry Evidence

Australia – Critique of Tobacco Industry Graphic Health Warnings Research

A report by Deloitte (2011), commissioned by BAT, suggested that health warnings on cigarette packets had not been successful in reducing cigarette consumption and therefore plain packaging was unlikely to be effective.21 However, Cancer Council Victoria (Australia) reviewed the analyses forming the basis of this conclusion and found the methodology weak in several respects.22 For instance, Deloitte made an error in their analysis by starting it in 1990, whereas health warnings were introduced in 1987. In addition to this error, the data used were not actually consumption data but rather duty paid shipment volumes. It has been reported that duty paid does not necessarily amount to consumption because in some years cigarettes are over-produced and surplus is often kept in storage until needed.23 Looking only at BAT brands, Deloitte concluded that volumes did not decline any more steeply than normal. However, when data on all duty paid tobacco products was assessed, Cancer Council Victoria reported that excise and customs duty declined more than would be predicted following the introduction of health warnings.22

UK – Critiques of Industry Evidence that Plain Packaging Will Not Work

Peer-reviewed research has shown how global tobacco companies commissioned, cited and critiqued evidence as part of a campaign to prevent the introduction of plain packaging for their products in the UK.6242526
Tobacco companies used this strategy to argue that plain packaging “won’t work”. Evidence to support this claim was promoted through the media and in submissions to government.
This strategy was examined in a series of peer-reviewed research papers, which highlighted the misleading nature of tobacco companies’ evidence on plain packaging, emphasising that:

  • Tobacco companies cited evidence that did not directly consider plain packaging to argue that regulation “won’t work”;6
  • Evidential critiques commissioned by tobacco companies used misleading techniques to discredit public health research on plain packaging;24
  • Quoted statistics on illicit tobacco were over-estimated to exaggerate the risks of the policy.2526

The Importance of Branding and Packaging to the Tobacco Industry

Despite the tobacco industry’s claims that plain packaging will not work because packaging is not important to marketing, internal industry documents show how important tobacco branding is, with innovations (packaging and product) leading to a 10% increase in market share for BAT in 2011.27 Internal industry documents reveal a long held understanding by the tobacco industry that cigarette packets and tobacco pouches represent mobile advertisements. One Rothmans document from 1982, for example, stated that the company was:

“very aware that every customer carries the Rothmans logo, on the package, with him or her all the time. That package comes out many times a day, and every time it is seen makes a personal comment about the person who carries and shows it.”28

In 1994, Philip Morris said:

“In the absence of any other marketing messages, our packaging — comprised of the trademark, our design, color sic 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.”29

The tobacco industry claims that cigarette packaging has no bearing on people’s smoking behaviour, however advertising works for every other industry. The tobacco industry has long argued that tobacco advertising is aimed at building brand loyalty, not trying to persuade young people to smoke or smokers to continue and not quit. However, others within the advertising industry have disputed this categorically.
Advertising executive Emerson Foote, former Chairman of the Board of McCann-Erickson, which handled $20 million in tobacco account sales, argued that:

“The cigarette industry has been artfully maintaining that cigarette advertising has nothing to do with total sales. This is complete and utter nonsense. I am always amused by the suggestion that advertising, a function that has been shown to increase consumption of virtually every other product, somehow miraculously fails to work for tobacco products.”30

In 2004, BAT acknowledged packaging innovations as the reason for the increased success of their Dunhill brand: “In Australia and Taiwan, the continued success of the new packaging led to increased volumes of 7 per cent and 20 per cent respectively”.31

Global – Pre-Implementation Evidence For Plain Packaging

Prior to the implementation of plain packaging in Australia a large volume of peer-reviewed research supported the measure. The research showed that when branding is removed from tobacco packaging, health warnings are more salient3233 packs appear less attractive and of a lower quality, and there is less confusion about the relative harm from different brands, e.g. Marlboro gold packs are viewed as less harmful than Marlboro red packs.2232 Furthermore, a number of studies evaluated in a systematic review for the UK Department of Health found that cigarette packaging influences children and is an important consideration in children’s smoking behaviour.32 A few examples of studies included in the systematic review are:

  • A study of school children in Canada and the US found that the majority of children, when asked, would prefer to take home a branded rather than a plain cigarette pack as the plain pack was “ugly” and “boring”.343536
  • A Scottish study found that amongst 10-17 year olds, plain cigarette packs were seen by the majority as “unattractive”, “uncool” and “a pack you would not like to be seen with”.37

Prior to the implementation of the policy in the UK and Ireland, two plain packaging evidence reviews by both the UK (the Chantler Review), and Irish Governments (the Hammond Review) concluded that that this population-scale measure is likely to be effective in reducing youth uptake of smoking. For example, in the UK, Sir Cyril Chantler’s review concluded that:

“Having reviewed the evidence it is in my view highly likely that standardised packaging would serve to reduce the rate of children taking up smoking and implausible that it would increase the consumption of tobacco. I am persuaded that branded packaging plays an important role in encouraging young people to smoke and in consolidating the habit irrespective of the intentions of the industry. Although I have not seen evidence that allows me to quantify the size of the likely impact of standardised packaging, I am satisfied that the body of evidence shows that standardised packaging, in conjunction with the current tobacco control regime, is very likely to lead to a modest but important reduction over time on the uptake and prevalence of smoking and thus have a positive impact on public health.”38

While the Hammond Review, commissioned by the Irish Government, concluded:

“The evidence indicates that tobacco packaging is a critically important form of tobacco promotion, particularly in jurisdictions with comprehensive advertising and marketing restrictions, such as Ireland. The evidence indicates that plain packaging reduces false beliefs about the risks of smoking, increases the efficacy of health warnings, reduces consumer appeal among youth and young adults, and may promote smoking cessation among established smokers.
Overall, there is very strong evidence that plain packaging would be effective in regards to four of Ireland’s specific policy objectives:

  • Prevent non-smokers including children and young people from starting to smoke;
  • Encourage, motivate and support current smokers to quit;
  • Reduce recidivism rates among those who have quit;
  • Limit the societal impacts of smoking and protect society, especially those under 18 years, from the marketing practices of the tobacco industry.”39

Australia – Early Evidence that Plain Packaging Works

Following the introduction of plain packaging in Australia in December 2012, calls to Quitline increased,40 individual pack display decreased,41 cigarette sales fell 3.4%,42 there was no increase in transaction times, no defection to larger stores to make tobacco purchases, and no impact on the illicit trade.434445
These early policy outcomes contradicted the claims made by tobacco companies in the UK, and complement the Tobacco Control Research Group’s research, which has raised serious questions about the trustworthiness and scientific value of tobacco companies’ arguments that plain packaging “won’t work”.

Australia – Evidence from the Post-Implementation Tobacco Plain Packaging Evaluation

In order to monitor the outcomes of the 2011 Tobacco Plain Packaging Act, in 2012 the Australian Department of Health commissioned a National Monthly Tobacco Plain Packaging Tracking Survey of the early effects of plain packaging on adolescents. Findings were reported in several studies published in a special issue of Tobacco Control. A Post-Implementation Review of Tobacco Plain Packaging was also published in 2016.

Results of Australia’s National Monthly Tobacco Plain Packaging Tracking Survey

Four hundred smokers and recent quitters were surveyed every four weeks between April 2012 and March 2014, with a follow up survey in May 2014. Post-implementation plain packaging legislation:

  • Reduced appeal of packs46;
  • Increased health warning effectiveness;
  • Corrected some misperceptions of harms;
  • Increased rates of quitting cognitions and quit attempts.47

Evaluation of the Effects of Plain Packaging on Australian Adolescents

A 2013 evaluation survey examined the impact of plain tobacco packaging and enhanced graphic health warnings on adolescents’ perceptions of pack images, brand differences and on their cognitive processing. Comparisons of results from 2011 and 2013 showed that:

  • The appeal of cigarette packs and brands to Australian adolescents decreased significantly;48;
  • Acknowledgement of negative health effects of smoking among Australian adolescents remained high; but, apart from bladder cancer, new requirements for packaging and health warnings did not increase adolescents cognitive processing of warning information;49.

Post-Implementation Review of Tobacco Plain Packaging in Australia

In 2016, in the Post-Implementation Review of Tobacco Plain Packaging, the Australian Department of Health linked the introduction of tobacco plain packaging with a reduction in daily smoking prevalence:

“The 2013 NDSHS collected data from nearly 24,000 people across Australia from 31 July to 1 December 2013, (notably, after the introduction of the tobacco plain packaging measure and mostly before the first of a series of four 12.5% tobacco excise increases on 1 December 2013). The results of the 2013 NDSHS show that daily smoking prevalence among Australians aged 14 years and over has fallen significantly from 15.1% in 2010 to 12.8% in 2013, a drop of 15%. This included declines in all Australian states and territories (except Tasmania).”50

Tobacco Industry Response to the Australian Post-Implementation Review (PIR)

Philip Morris Limited (PMI) made a submission to the PIR consultation50 which raised concerns about the PIR process.51 The submission sought to widen the scope of the Review beyond the impacts on smoking prevalence and the denormalising effects of plain packaging. It asserted that a ‘compliant’ PIR would need to include a ‘cost-benefit analysis’ of the policy which includes consideration of any impact on the illicit tobacco trade and on the structure of the tobacco market. The PMI submission cited a KPMG report on illicit tobacco in Australia.52 Earlier reports from this source has previously been rejected by the Australian Borders and Customs Agency and peer-reviewed research, which maintains there has been no impact on the illicit trade.444553
Similarly replicating previous tactics, Japan Tobacco International (JTI)’s press release following the release of Australia’s PIR54 questioned the credibility of the analysis.55

Countering Industry Arguments Against Plain Packaging

TobaccoTactics Resources

TCRG Research

Print Friendly, PDF & Email


  1. UK Government,The Standardised Packaging of Tobacco Products Regulations 2015, 2015, accessed March 2016
  2. H. McDonald,Ireland passes plain packaging bill for cigarettes, The Guardian, 3 March 2015, accessed March 2016
  3. Australian Department of Health,2011 Tobacco Plain Packaging Act, 2011, accessed March 2016
  4. Agence France Presse, Gauloises cigarette-maker to appeal against plain packaging rules, The Guardian, 10 May 2016, accessed May 2016
  5. Canadian Cancer Society,Plain packaging – International overview, Canada, 16 November 2015, accessed March 2016
  6. abcdJ. Hatchard, G.J. Fooks, K.A. Evans-Reeves et al, A critical evaluation of the volume, relevance and quality of evidence submitted by the tobacco industry to oppose standardised packaging of tobacco products, BMJ Open 2014, accessed July 2014
  7. J. Stauber, S. Rapton, Toxic sludge is good for you: Lies, damn lies and the public relations industry. Maine Common Courage Press, 1995
  8. D. Michaels, C. Monforton, Manufacturing uncertainty: Contested science and the protection of the public’s health and environment. American Journal of Public Health, 2005; 95, S39-48
  9. D. Apollonio, L.A Bero, The creation of industry front groups: The tobacco industry and ‘get government off our back.’ American Journal of Public Health, 2007; 97, 419-27
  10. M.Sims, S. Tomkins, K. Judge et al, Trends in and predictors of second-hand smoke exposure as indexed by cotinine in children in England from 1996 to 2006. Addiction, 2010; 105(3), 543-53
  11. M. Jarvis, M. Sims, A. Gilmore et al, Impact of Smoke-free Legislation on children’s exposure to second-hand smoke: Cotinine data from the Health Survey for England. Tobacco Control, 2011; 21(1), 18-23
  12. M. Jarvis, J. Mindell, C. Feyerabend et al, Smoke-free homes in England: Prevalence, trends and validation by cotinine in children. Tobacco Control, 2009; 18, 491-5
  13. M. Thun, R. Peto, J. Boreham et al, The tobacco epidemic today: Stages of the cigarette epidemic on entering its second century. Tobacco Control, 2012, 21, 96-101
  14. D.T.Levy, F. Chaloupka, G. Joseph, The effects of tobacco control policies on smoking rates: A tobacco control scorecard. Journal of Public Health Management and Practice,2004;10(4),338-53
  15. M. Sims, J. Mindell, M. Jarvis et al, Did Smoke-free Legislation in England reduce exposure to second-hand smoke amongst non-smoking adults? Cotinine analysis from the Health Survey for England. Environmental Health Perspectives, 2012, 120, 425-30
  16. M. Sims, L. Bauld, A. Gilmore, England’s legislation on smoking in indoor public places and work-places: Impact on the most exposed children. Addiction, 2012;107,2009-16
  17. J. Hatchard, A. Gilmore, Evidence-based policy making and ‘Better Regulation’: The battleground for standardised packaging of tobacco, Institute for Policy Research Policy Brief, University of Bath, September 2015, accessed March 2016
  18. K. E. Smith, G. Fooks, J. Collin, et al, “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
  19. K.E.Smith, A. Gilmore, G. Fooks et al, Tobacco industry attempts to undermine Article 5.3 and the “good governance” trap. Tobacco Control, 2009, 18; 509-11
  20. K. Smith, G. Fooks, A. Gilmore et al,Corporate Coalitions and Policy Making in the European Union: How and Why British American Tobacco Promoted “Better Regulation”, Journal of Health Politics, Policy and Law, 2015;40(2), 325-72, accessed March 2016
  21. Deloitte, Tobacco packaging regulation: An international assessment of the intended and unintended impacts. A Deloitte report for British American Tobacco, 2011, accessed June 2012
  22. abcCancer Council Victoria, Plain packaging of tobacco products: A review of the evidence, 2011, accessed July 2012
  23. S. Chapman, Projecting the impact of plain packets isn’t so simple, ABC News, 18 July 2012, accessed August 2012
  24. abS. Ulucanlar, G.J. Fooks, J.L. Hatchard et al, Representation and Misrepresentation of Scientific Evidence in Contemporary Tobacco Regulation: A Review of Tobacco Industry Submissions to the UK Government Consultation on Standardised Packaging, PLOS Medicine, 2014;11(3),e1001629, accessed July 2014
  25. abA. Rowell, K. Evans-Reeves and A.B. Gilmore, Tobacco industry manipulation of data on and press coverage of the illicit tobacco trade in the UK, Tobacco Control 2014;doi:10.1136/tobaccocontrol-201-051397, accessed July 2014
  26. abA.B. Gilmore, A. Rowell, S. Gallus, A. Lugo, L. Joosens and M. Sims, Towards a greater understanding of the illicit tobacco trade in Europe: a review of the PMI funded ‘Project Star’ report, Tobacco Control 2014;23,e51-61, accessed July 2014
  27. J.M. Levy, Innovations Overview presentation, BAT investor day, 2011, Hampshire
  28. Rothman’s of Pall Mall Canada Limited, Rothmans of Pall Mall Canada Limited 1957-1982 history. Toronto: Rothman’s of Pall Mall Canada Limited
  29. M. Hulit, Marketing issues corporate affairs conference, 27 May 1994, accessed June 2012
  30. L. Heise, Unhealthy Alliance, World Watch, 1988, p20
  31. BAT, Review 04: Annual reviews and summary financial statement 2004
  32. abcC. Moodie, M. Stead, L. Bauld et al, Plain tobacco packaging: A systematic Review, Public Health Consortium, 2012, accessed July 2012
  33. O. Maynard, M, Munafo, U. Leonards, Visual attention to health warnings on plain tobacco packaging in adolescent smokers and non-smokers, Addiction, 2013;108(2), 413-9, accessed August 2012
  34. I. Rootman, B.R. Flay, D. Northrup, et al. A study on youth smoking: Plain packaging, health warnings, event marketing and price reductions. Updated figures. 2003, Toronto: Centre for Health Promotion
  35. D. Northrup, J. Pollard, Plain packaging of cigarettes, event marketing to advertise smoking, and other tobacco issues: A survey of grade seven and grade nine Ontario students. 1995, Toronto: Institute for Social Research
  36. D. Raphael, E. Single, A study on youth smoking: Plain packaging, health warnings, event marketing and price reductions. Toronto: Centre for Health Promotion
  37. C. Moodie, A. Ford, A.M. Mackintosh et al, Young people’s perceptions of cigarette packaging and plain packaging: An online survey. Nicotine and Tobacco Research, 2012;14(1),98-105
  38. C. Chantler, Standardised packaging of tobacco: Report of the independent review undertaken by Sir Cyril Chantler, King’s College London, 2014, accessed March 2016
  39. D. Hammond,Standardised packaging of tobacco products: Evidence review, prepared on behalf of the Irish Department of Health, Irish Department for Health website, March 2014, accessed March 2016
  40. J.M. Young, I. Stacey, T.A. Dobbins, et al. Association between tobacco plain packaging and Quitline calls: a population-based, interrupted time-series analysis, Medical Journal of Australia, 2014;200(1),29-32, accessed July 2014
  41. M. Zacher, M. Bayly, E. Brennan, et al. Personal tobacco pack display before and after the introduction of plain packaging with larger pictorial health warnings in Australia: an observational study of outdoor café strips, Addiction, 2014;109(4), accessed July 2014
  42. Department of Health, Australia, Tobacco key facts and figures, 2014, accessed July 2014
  43. A. Corderoy, Tobacco industry claims on impact of plain packaging go up in smoke, Sydney Morning Herald 2014, accessed July 2014
  44. abM. Scollo, M. Bayly, M. Wakefield. Availability of illicit tobacco in small retail outlets before and after the implementation of Australian packaging legislation. Tobacco Control, 2013; doi:10.1136/tobaccocontrol-2013-051353
  45. abM. Scollo, M. Zacher, S. Durkin, et al. Early evidence about predicted unintended consequences of standardized packaging of tobacco products in Australia: A cross-sectional study of place of purchase, regular brands and use of illicit tobacco. BMJ Open, 2014;4(7),e005873
  46. M. Wakefield, K. Coomber, M. Zacher, et al. Australian adult smokers’ responses to plain packaging with larger graphic health warnings 1 year after implementation: results from a national cross-sectional tracking survey, Tobacco Control, 2015;24,ii17-25, accessed March 2016
  47. S. Durkin, E. Brennan, K. Coomber, et al. Short-term changes in quitting-related cognitions and behaviours after the implementation of plain packaging with larger health warnings: findings from a national cohort study with Australian adult smokers, Tobacco Control, 2015;24,ii26-32, accessed March 2016
  48. V. White, T. Williams, M. Wakefield,Has the introduction of plain packaging with larger graphic health warnings changed adolescents’ perceptions of cigarette packs and brands?, Tobacco Control, 2015;24,ii42-49 accessed March 2016
  49. V. White, T. Williams, A. Faulkner et al. Do larger graphic health warnings on standardised cigarette packs increase adolescents’ cognitive processing of consumer health information and beliefs about smoking-related harms?, Tobacco Control, 2015;24,ii50-57, accessed March 2016
  50. abDepartment of Health, Australian Government,Post-Implementation Review: Tobacco Plain Packaging 2016, accessed March 2016
  51. Philip Morris Limited,Submission to Australia’s plain packaging post-implementation review, March 2015, accessed March 2016
  52. KPMG, Illicit Tobacco in Australia Half-year report, 13th October 2014, accessed March 2016
  53. A. Corderoy, Tobacco industry claims on impact of plain packaging go up in smoke, Sydney Morning Herald 2014, accessed July 2014
  54. Department of Health, Australian Government,Post-Implementation Review: Tobacco Plain Packaging 2016, accessed March 2016
  55. Japan Tobacco International, Australian Government Report Jumps to Conclusions to Mask Failure of ‘Plain’ Packaging, JTI Media, 26 February 2016, accessed March 2016