Tobacco Control Research Group: Policy Impact

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The Tobacco Control Research Group’s monitoring and research of tobacco industry (TI) activity has achieved significant national, international and global policy impacts. As outlined below, some of our most impactful research is that which is triggered by our monitoring findings not least because this ensures the policy relevance of our work.
Here are some examples:

Plain Packaging and the EU Tobacco Products Directive


Independent research into plain packaging has consistently found that there is strong evidence that the measure will reduce the appeal of tobacco products and increase the prominence of health warnings. Australia was the first country to introduce plain packaging in 2012, followed by Ireland, UK, France, Norway and other countries. Our previous work had shown that the TI had successfully pushed for ‘Better Regulation’ which gives it a key role in supplying and contesting ‘evidence’ for policy decisions. Our monitoring suggested that contestations over evidence would be central to TI’s attempts to derail plain packaging legislation and we made that a key focus of our research.

Key Research Findings

We examined TI political activities to oppose plain packaging in the UK and the revision of the European Tobacco Products Directive (TPD), which included packaging provisions. We uncovered the following:

  • The TI produced highly misleading data on tobacco smuggling and counterfeiting, and widely disseminated this via the press in a deliberate attempt to mislead.123
  • The TI commissioned highly misleading ‘evidence’ claiming that plain packaging would have negative consequences and swamped the government’s consultation with this evidence.45
  • Opposition to plain packaging in the UK and the EU was primarily undertaken by third parties with financial relationships with major tobacco manufacturers often being undisclosed. Low levels of transparency regarding these links created a misleading impression of diverse and widespread opposition.678
  • Better Regulation provides a conduit for well-resourced industries to block, weaken and delay effective public health legislation because its use of impact assessment and stakeholder consultation enables them and their front groups to provide highly misleading evidence and give a misleading impression of opposition.5

Policy Impact

Our research made a significant contribution to enabling the introduction of plain packaging in the UK in 2016:

Evidence of impact at EU level was given by the office of Linda McAvan, Member of European Parliament, and lead Rapporteur on the TPD:
“… I just wanted to put in writing that we are very grateful for the TobaccoTactics website – this has been very useful for Linda’s work on TPD2. In her role as Rapporteur, Linda has been contacted by many individuals and organisations and the website has been a very helpful “one-stop shop” for quick background checks… It has also been useful as a third-party, independent reference in Linda’s conversations with colleagues and the media”9
Exposure of undisclosed meetings held between high level European Commission staff and the TI, contravening Article 5.3, and our evidence on the impacts of those meetings in delaying and weakening legislation8 helped trigger an EU Ombudsman’s inquiry which concluded that Article 5.3 had been improperly implemented.10
For more detailed information, see:

Tax and Price


Our routine monitoring of the TI identified that, despite selling increasingly cheaper products, tobacco industry profits were actually increasing. We sought to explain this by undertaking some of the first research on tobacco industry pricing globally as part of an EU-funded project (2009-2012).

Key Research Findings

Our research found that the TI was undermining the intended public health impacts of tobacco tax policy in the UK. It showed that:

  • The TI was absorbing tax increases on its cheapest products so they were not transferred to smokers, and the prices of these products were not therefore increasing in real terms. Simultaneously, the TI was increasing the price of more exclusive brands beyond the amount required by tax increases in order to increase its profits.11
  • The young and the poor were most likely to use these cheap tobacco products and that the TI’s pricing practices were therefore likely to be driving inequalities in smoking.12
  • Despite its claims that tobacco tax increases were driving illicit trade, the TI was in fact increasing its prices over and above government tax increases such that approximately 50% of the overall price increase in tobacco was due to TI price rises.13 This suggested the TI did not believe its own claims that price increases were driving the illicit trade as overall, tobacco companies were consistently raising the prices of its products. It also highlighted, alongside our work showing the immense profitability of the TI, that there was scope for further tax increases.1415

Policy Impact

Our research on TI pricing of cigarettes, published in 2013, recommended the introduction of a Minimum Excise Tax (MET) on tobacco. A MET would have the potential to reduce smoking rates significantly, particularly among the young and least well off, and would in turn lead to significant health benefits and a reduction in health inequalities, of which smoking is the leading cause. In response to our recommendation:

For more detailed information, see Impact Case Studies Winter 2017/18: Introduction of Minimum Excise Tax (MET) on Tobacco by Her Majesty’s Treasury in 2017.

Illicit Tobacco Trade


The TI opposes most key tobacco control policies, including tobacco tax, point of sales display ban, and plain packaging, arguing that they will increase illicit tobacco trade. We have undertaken diverse qualitative and quantitative work including analysis of leaked industry documents, and patent and trademark filings, to explore both the industry’s role in smuggling and the veracity of its arguments and data.

Key Research Findings

Our evidence challenges the TI’s illicit argument. It shows:

  • Historical and widespread TI involvement in tobacco smuggling.16
  • Contemporary TI involvement in tobacco smuggling despite tobacco company claims to now be the victim of the illicit trade.16171819
  • TI attempts to mislead the media and regulators on illicit tobacco with highly misleading tobacco industry data that exaggerate levels of illicit in order to scaremonger.231617
  • that, despite TI claims that the main problem in illicit is counterfeit, in fact the majority of the illicit tobacco market in the UK, EU and globally – approximately 70% in each – is still tobacco company cigarettes. In contrast to TI claims independent, comprehensive data shows the contribution from counterfeit is small (around 5%).17
  • The TI’s widespread use of front groups to promote its messages on illicit trade.120
  • That the agreements the EU reached with the TI have largely served the TI’s interests.19 Loopholes meant that the TI could classify seized cigarettes as counterfeits, seizure payments only accrued 0.08% of the estimated government losses from illicit cigarettes, making smuggling financially attractive for the TI.

Policy Impact

Our research has helped advance policies on tobacco smuggling at UK, EU and global levels in a number of ways including:

  • By exposing historical TI involvement in the illicit tobacco trade our research helped ensure the development of the Illicit Trade Protocol (ITP) – the first protocol to the Framework Convention on Tobacco Control (FCTC), which aims to address tobacco smuggling within the legal supply chain.2122
  • Our research subsequently exposed TI attempts to undermine the ITP and has thereby enabled its implementation. For example, it helped ensure that the technical standards that operationalise the ITP within the EU were more robust than first drafted with stronger requirements for independence from industry.2324
  • More broadly our work has changed policy makers’ understanding of tobacco industry actions and interests in the area of illicit tobacco including ongoing TI involvement in illicit. This in turn has helped ensure willingness to increase tobacco taxes and implement effective measures to address the illicit tobacco trade. Specific impacts here include the EU deciding not to renew its agreement with Philip Morris International on illicit tobacco.192526

Implementation Framework Convention on Tobacco Control Article 5.3


The FCTC, the first global treaty developed under the auspices of WHO, entered into force in 2005. It was developed to address the global tobacco epidemic, and is one of the most widely embraced treaties in United Nations history, with 181 WHO Member States Parties to the treaty.

Research Findings

Collectively, our research on TI influence over public policies in the UK and EU since 2008, and use of third parties, brought to attention wider concerns about TI attempts to limit efforts of FCTC implementation. We demonstrated that:

  • The TI has negatively influenced public health policies in numerous jurisdictions which raises concerns about transparency in policy-making.58
  • The TI did not only attempt to influence public health policies, but also enjoyed significant influence over upstream policies such as Better Regulation.2728
  • Regulatory reforms such as Better Regulation may pose a threat to public health.29

Policy Impact

Our research reduced the TI’s ability to influence public health policy on global level in the following ways:

  • Our evidence, and that of others, that the TI has negatively influenced public health policies prompted, in 2008, the inclusion of Article 5.3 with the FCTC, which specifically aims to reduce TI influence on public policy, by stating that “in setting and implementing their public health policies …. Parties shall act to protect these policies from commercial and other vested interests of the tobacco industry”.3031
  • The implementation of Article 5.3 was fraught with difficulty, given the strong lobbying of the TI against this Article. In the EU, the industry used the ’Better Regulation’ commitments it had secured to lobby against Article 5.3. The TCRG prepared a policy briefing for members of the EU Health Working Group, which was meeting to finalise the European position on the Article 5.3 Guidelines. This briefing, which summarised our research and its relevance to Article 5.3, “was instrumental in safeguarding enough support amongst European countries for Strong Article 5.3 Guidelines, in turn ensuring that strong guidelines were agreed at the November 2008 Conference of the Parties“.32
  • At the Conference of the Parties 6 in Moscow in October 2014, three TobaccoTactics pages detailing organisations and persons with tobacco industry links were quickly prepared and disseminated to relevant organisations, assisting WHO and Parties to the FCTC. This led the Parties to the treaty refusing to grant observer status to these organisations with hidden tobacco industry links.32

Bribery and Corruption


The tobacco industry’s use of bribery and corruption had long been alleged but there had never been clear evidence. Yet it was clear that progress in tobacco control was slower than expected particularly in Africa. For example, of the 44 (of 47) countries in the WHO Afro region that are parties to the FCTC, only two (Kenya and Uganda) have recently passed and none have yet implemented fully FCTC-compliant legislation.33 This is despite the strong regional commitment demonstrated during FCTC negotiations and some countries having invested more than a decade in attempting to implement it.34

Policy Impact

The TCRG worked with the BBC and its flagship programme, Panorama, on an investigation, entitled “The Secret Bribes of Big Tobacco” which was broadcast both in the UK and internationally in November 2015. The documentary was viewed by millions and resulted in over 100 articles and reports in the international press. This led to:

  • A petition calling for investigative agencies to hold British American Tobacco (BAT) accountable in the UK, US and African countries. Created by Corporate Accountability, this petition received over 48,000 signatures.35
  • Two international sign-on letters calling for accountability sent to the governments of Kenya, Comoros, Rwanda, Burundi and Uganda respectively, endorsed by 39 international public health organisations.36
  • The filing of an official complaint with the Ethics and Anti-Corruption Commission in Kenya calling for an investigation into BAT.37
  • A letter from 10 Members of US Congress calling for the Department of Justice to investigate a violation of the Foreign Corrupt Practices Act.38
  • The TCRG was also invited by Al Jazeera to collaborate with them on their investigative documentary on BAT in Kenya, “Kenya: Lighting Up”, which was released in December 2015 all across Africa. This led ultimately to the British Serious Fraud Office formally investigating BAT bribery and corruption, the first time ever this has happened against a tobacco company.
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  1. abK.A. Evans-Reeves, J.L. Hatchard, A.B. Gilmore, ‘It will harm business and increase illicit trade’: An evaluation of the relevance, quality and transparency of evidence submitted by the tobacco industry to the UK Consultation on standardised packaging 2012, Tobacco Control, 2015;24:e168-e177
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  31. Guidelines for implementation of Article 5.3 of the WHO Framework Convention on Tobacco Control, 2008, accessed May 2018
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  37. Consumer Information Network. Official complaint of the Consumer Information Network (CIN) against British American Tobacco (BAT) to the Ethics and Anti-Corruption Commission (EACC), 5 January 2016
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