Imperial Brands’ Use of the EU Citizens’ Initiative

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In February 2019, Imperial Brands funded and promoted a European Union (EU) Commission’s Citizens Initiative campaign, called “Let’s demand smarter vaping regulation!” 1 This aimed to revoke Article 20 of the EU Tobacco Products Directive (TPD), which relates to the regulation of e-cigarettes (also known as electronic nicotine delivery systems, or ENDS).2


The European Citizens’ Initiative is a democratic tool meant to benefit individuals, or groups of individuals, with rules in place to exclude companies.34 However, one of the organisers of the ‘Let’s demand smarter vaping regulations’ initiative was Valerio Forconi, Head of EU Corporate Affairs and registered lobbyist for Imperial Brands.1 Imperial Brands made the initial donation of €10,000 (around GB£8,700) on 8 October 2018, to set up the campaign.1

PR company Instinctif Partners were contracted by Imperial to promote the campaign (see below).

Imperial’s Aim

The campaign sought to replace the existing TPD regulations with:

“bespoke scientific, evidence-based legislation in line with the functioning of the internal market that distinguishes vaping products from tobacco & pharmaceutical products; (…) Vaping policy should (…) ensure smokers and vapers have clear information and access to tobacco-free less harmful alternatives.”1

The initiative was launched in April 2019, with the intention of gathering one million signatures in one year from at least 7 EU countries. This would then require the European Commission to consider the request to revoke Article 20.13

The accompanying website, set up by Imperial Brands (see below), portrayed it as a “grassroots” campaign to support a change in regulation, by differentiating e-cigarettes from conventional tobacco products.5 This is a clear example of ‘astroturfing’, a well-known tactic used by the tobacco industry to interfere with tobacco control legislation.6

Others listed as organisers of the initiative included representatives from two e-cigarette trade associations with Imperial as a member (along with other tobacco companies): Michael Kenneally, registered lobbyist and Director of Vape Business Ireland;178 and Vincent Durieux, President of France Vapotage.1910

The main representative of the organising committee was listed as Dustin Dahlmann, from German e-cigarette-business association Bündnis für Tabakfreien Genuss (BfTG), which donated EURO€8,000 to the campaign. BfTG states that it is “tobacco-free” and has no tobacco industry members.1111213 Another organiser was listed as Mosè Giacomello, from Vapitaly, which organises an annual trade event in Italy, and provided EURO€16,000 in funding to the campaign.113

Set Up Website to Promote the Initiative

Imperial also set up a website called ‘Vaping is NOT Tobacco’, launched in April 2019, to promote the petition and enable people to sign it direct from the site.35

It also provided forms for visitors to contact their Member of the European Parliament (MEP):

“Don’t hesitate to let them know how vaping products improved your life by helping you switch from tobacco. That way, when they deal with the regulation of these products, they will remember your stand on the topic”.14

The website listed France Vapotage as a supporter, and stated that it was “promoted by Imperial Brands”.15Brandon Mitchener, Managing Partner at Instinctif Partners the PR company contracted by Imperial to run the campaign, was listed as the only Team Member of the ‘Vaping is NOT Tobacco’ Facebook page.3161718 Neither the campaign’s Facebook page nor its Twitter bio (@vapeNOTtobacco) declared a link to Instinctif or Imperial. The campaign press release gave Instinctif Partners as the contact but did not mention Imperial Brands.19

Despite the direct connection to Imperial Brands, and the involvement of a PR company being paid to run the campaign, the website stated that this “Citizen’s” initiative was a “grassroots campaign” and a “bottom up movement”.5 Corporate watchdog Corporate Europe Observatory condemned Imperial’s activities, stating that the tobacco company had:

 “vested commercial interests in getting vaping products excluded from the Tobacco Products Directive and is abusing a democratic tool for citizenship participation”.3

By December 2019, the total number of signatures gathered by the campaign was fewer than 50,000, far short of the one million required.2011

As of 2021 the campaign website no longer existed.21

Tobacco Tactics Resources

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  1. abcdefghiEuropean Union Commission, EU Commission Citizens Initiative, 20 February 2019, accessed April 2019
  2. European Parliament, Revision of the Tobacco Products Directive 2014/40/EU, 3 April 2014, accessed May 2019
  3. abcdeK. Jennings, Big Tobacco’s push for Big Vape, Politico, 26 February 2019, accessed April 2019
  4. EU Citizens Initiative: FAQs, undated, accessed 2022
  5. abcSign the European Citizens’ Initiative,, undated, accessed May 2019
  6. S. Ulucanlar, G.J. Fooks, A.B. Gilmore, The Policy Dystopia Model: An Interpretive Analysis of Tobacco Industry Political Activity, PLoS Med, 2016; 13(9): e1002125
  7. Standards in Public Office Commission, Vape Business Ireland, Register of Lobbying, 9 January 2018, accessed December 2019
  8. Vape Business Ireland, Vape Business Ireland: Ireland’s Largest Vape Trade Association, website, archived 24 April 2019, accessed December 2019
  9. France Vapotage, Vapotage, archived 26 September 2018, accessed December 2019
  10. EU Transparency Register, France Vapotage, register entry, updated 12 August 2019, accessed December 2019
  11. abS. Rosel, A Call For Common Sense, Tobacco Reporter, December 2019, accessed December 2019 (paywall)
  12. BfTG vaping association, Bündnis für Tabakfreien Genuss (Alliance for tobacco fee enjoyment), archived July 2019, accessed March 2021
  13. abVaping is NOT Tobacco Press Conference, YouTube video, 30 April 2019, accessed March 2022
  14. Vaping is Not Tobacco, Make your voice heard to drive change, Vaping is Not Tobacco website, undated, accessed October 2019
  15. Vaping is Not Tobacco, Supporters, Vaping is Not Tobacco website, undated, accessed May 2019
  16. EU Transparency Register, Instinctif Partners, last modified 25 February 2019, accessed February 2019
  17. B. Mitchener, Linkedin Profile, undated, accessed October 2019
  18. Vaping is Not Tobacco (@VapingIsNOTtobacco), About:Team Members, Facebook page, undated, accessed October 2019
  19. Vaping is NOT Tobacco Campaign: A Pan-European Push for Smarter Vaping Rules, Business Wire, press release, 30 April 2019, archived 1 May 2019, accessed February 2022
  20. European Citizens’ Initiative,, undated, accessed 20 December 2019
  21. Imperial Brands,, website, archived December 2021