Tobacco Industry Interference with Endgame Policies

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Background

The World Health Organisation (WHO) Framework Convention on Tobacco Control (FCTC) is an international treaty that aims to reduce the demand and supply of tobacco. It entered into force in February 2005, and as of 2023, there are 183 Parties to the treaty.1

Article 3 of the WHO FCTC establishes that “the objective of this Convention and its protocols is to protect present and future generations from the devastating health, social, environmental and economic consequences of tobacco consumption and exposure to tobacco smoke by providing a framework for tobacco control measures to be implemented by the Parties at the national, regional and international levels in order to reduce continually and substantially the prevalence of tobacco use and exposure to tobacco smoke”.2

What is the endgame?

The tobacco ‘endgame’ is the concept of moving beyond a focus on tobacco control, towards implementing policies and strategies that could phase out tobacco products entirely.3 According to Cancer Research UK, among others, this would require systemic changes, including:

“initiatives designed to change/eliminate permanently the structural, political and social dynamics that sustain the tobacco epidemic, in order to achieve within a specific time an endpoint for the tobacco epidemic.”45

This could involve the reduction of prevalence of smoking to – or very close to – zero.

Policy Options

Research conducted into potential endgame strategies has identified plausible new policies for reducing smoking to minimal levels. These include:

  • A tobacco-free generation policy, which precludes the sale and supply of tobacco to individuals born after a certain year67
  • A ‘sinking lid’ strategy, which involves establishing steadily decreasing quotas on the sales or imports of tobacco products678
  • Substantially reducing the number of tobacco product retailers, which could include restricting retailer density, location, type, or licensing, or restricting tobacco sales to government run outlets67910
  • Mandating low-nicotine levels in tobacco products611
  • Banning the sale of one or more tobacco products106
  • Shifting control of the supply and distribution of tobacco products away from tobacco companies312

Implementation of endgame policies

National goals and policies

The first countries to propose tobacco endgame goals, and start developing legislation to achieve these targets, were Finland,1314 New Zealand,15 Ireland,16 Scotland,17 Sweden18 Canada,1920, Malaysia,21 Bangladesh,22 Denmark,23 and the  Vatican City,23  Other countries that have more recently adopted endgame goals include the Netherlands,2425 Australia,26 France,2327and the UK.28 Apart from in Bhutan, Bangladesh, France, and the Vatican City, the goal is to have a smoking prevalence of less than 5% of the population.23

As of 2023, the Campaign for Tobacco Free Kids (CTFK) policy database shows that 13 countries have banned the sale of waterpipe tobacco products, and 19 countries have banned the sale of smokeless tobacco products.29 A review carried out in 2020 showed that 40 countries had active or pending flavoured tobacco product policies that ranged from banning flavoured tobacco, to banning flavour descriptors and images on packaging.1030 No countries have yet implemented mandatory de-nicotinisation, substantial retailer reductions or the sinking-lid strategy at a national level.

In 2004 Bhutan was the first country to ban the sale of tobacco products and smoking in public places. In 2010 the government imposed a comprehensive ban on tobacco in Bhutan.3132 However, the legislation was reversed in 2021 due to concerns that increased tobacco smuggling could result in cross-border transmission of COVID-19.31

Subnational policies

Several US jurisdictions have also implemented endgame strategies. Brookline, Massachusetts introduced a generational tobacco ban in 2021 which prohibited the sale of tobacco products and e-cigarettes to anyone born after 1 January 2000.3334 Despite litigation brought by retailers, the Massachusetts Supreme Judicial Court upheld the ban in 2024.35 Following the adoption of the policy, there was a domino effect, with other towns in the Greater Boston area considering or passing bans.36

Some cities in California have prohibited the sale of tobacco and nicotine products,37 and others have restricted the number or types of retailers permitted to sell tobacco products.38 However, a bill that would have banned sales across the state was put on hold, after objections from multiple organisations, some of which cited the risk of an increase in illicit tobacco trade.39

In 2016, Balanga City in the Philippines banned the sale and use of all tobacco and nicotine products to those born after 1 January 2000. It also expanded the coverage of an existing smoking ban in the city’s University Town to cover a wider radius. However, both measures were overturned in 2018 after the tobacco industry pursued litigation.4041

 

Tobacco industry interference

As of 2023, Malaysia, New Zealand and the UK are the only countries that have announced plans to adopt a generational endgame policy. New Zealand also proposed introducing mandated denicotinisation and substantial retailer reduction.

Tobacco industry interference to prevent, delay or undermine the legislation has been observed in each of these countries, and is detailed below.

Malaysia

Proposed legislation

In 2022, Malaysia proposed the ‘Control of Tobacco Products and Smoking Bill 2022’ which aimed to phase out tobacco products and e-cigarettes by introducing a generational endgame policy, prohibiting their use and sale to everyone born on or after 1 January 2007.42

However, when the latest version of the bill was tabled in 2023, the generational ban clause was omitted for all products.43

Interference from industry and associated organisations

Prior to the bill being tabled, several organisations lobbied against the inclusion of e-cigarettes in the generational endgame policy.444546 One of these organisations, the Malaysian Vapers Alliance (MVA), is a member of the World Vapers’ Alliance,47 which has received funding from the Consumer Choice Center and BAT. The MVA urged the government to exclude e-cigarettes from the generational ban, and stated that it had conducted a survey of 5000 adult vape users, 96.6% of which did not agree with the ban.48

When the generational endgame clause was removed from the bill, Malaysia’s former health minister stated that this was due to strong lobbying from tobacco companies.43 According to local advocates the bill had seen an “unprecedented level of industry interference, some of which have been done in clear violation of the WHO Framework Convention on Tobacco Control”.49

In March 2024, the deputy Health Minister revealed that the generational ban component was dropped from the bill because of lobbying by the tobacco and e-cigarette industries.50 This lobbying was confirmed by the Minister of Health, although he stated that the generational element of the bill was excluded due to a “constitutional issue”.

New Zealand

Proposed legislation

In December 2022, as part of its ‘Smokefree Aotearoa 2025 Action Plan’,51 New Zealand passed the ‘Smokefree Environments and Regulated Products’ Amendment Act’ into law, which would have implemented several tobacco endgame policies.52 The legislation included three key approaches: a ban on tobacco products being sold to anyone born on or after 1 January 2009, a significant reduction in the amount of nicotine permitted in tobacco products (an 0.8mg/g nicotine limit, compared to 15-16mg/g present in full strength cigarettes), and a huge reduction in the number of retailers allowed to sell tobacco products across the country (from 6000 to 600).5253

The legislation was due to be implemented progressively starting with the reduction in retailer numbers from July 2024, however in November 2023, as part of an agreement between parties forming a new coalition government, it was announced that all three endgame proposals would be repealed. The new finance minister stated that the additional tobacco tax revenues resulting from repealing the smokefree legislation would be used to finance tax cuts promised during the election campaign.5455 The repeal was later confirmed in February 2024.56 It was reported that health officials had urged the coalition government to maintain elements of the bill and suggested compromises such as introducing a purchase age of 25, however the Associate Health Minister, Casey Costello, rejected this.57

In February 2024, public health experts published a briefing pointing to channels of potential tobacco industry influence on the new coalition government.58 The briefing highlighted past connections between coalition politicians and tobacco companies or industry linked organisations, and noted that the arguments used by the coalition government against tobacco endgame policies aligned with those used by tobacco companies.58 It also called for all government members to declare any past and current industry connections.5859

In March 2024, the broadcaster RNZ published an investigation showing that notes were sent from Costello’s office to healthcare professionals bore a strong resemblance in to the language of the tobacco industry, sparking allegations of big tobacco influencing the government.60 RNZ pointed out that the notes had delineated a set of actions including removing tax on smokeless tobacco products and grouping heated tobacco products (HTPs) under the definition of ‘vaping’.6162

 

Interference from industry and associated organisations

In 2021, following the release of the Smokefree Aotearoa 2025 Action Plan, Imperial Brands, BAT and JTI all submitted responses to the government consultation opposing the major endgame policies.63 Industry linked organisations and individuals also submitted responses opposing the legislation. These included submissions from Centre for Research Excellence: Indigenous Sovereignty and Smoking (COREISS),64 which is funded by the Foundation for a Smoke Free World, and The New Zealand Initiative,65 a think tank whose members include BAT and Imperial Brands.66

In June 2021, BAT reportedly facilitated a protest amongst convenience store owners to contest the proposed tobacco product restrictions.67 BAT supplied the dairy owners with postcards which opposed the measures, including the comment “If nicotine is slashed, filters banned and price goes up, many people will go to the black market – these will badly hurt my business, increase risk of robbery to personal safety and could force store to close.” Thousands of these postcards were reportedly delivered to the New Zealand Parliament.67

In August 2023, the ‘Save our Stores’ campaign, another seemingly grassroots initiative supported by convenience store owners,68 called for users to sign a petition urging the government to repeal the latest Smokefree 2025 laws. The campaign website stated that it was “supported by” BAT New Zealand and Imperial Brands New Zealand. The campaign website argued that “A ban on normal strength cigarettes will just mean the illicit trade in tobacco products will boom and be controlled by criminal networks”. It also stated that the legislation would destroy small businesses, and that taking away the tax revenue raised by tobacco sales would “hurt families who are already struggling to make ends meet”.69 These narratives were repeated in a series of Facebook adverts published as part of the campaign between August and November 2023, with one advert also stating “tobacco taxes pay for 35,000 police officers”.70

This kind of astroturfing is a well-documented industry tactic. In March 2024, lobbying group the New Zealand Taxpayers’ Union, which has received funding from BAT, cautioned against banning single use e-cigarettes, arguing that it could lead to unintended consequences, including a resurgence in smoking, increased health risks from the emergence of an unregulated black market.71 See also E-cigarettes: Tobacco Company Interests in Single Use Products.

UK

Proposed legislation

In October 2023, the UK Prime Minister announced plans to introduce a generational endgame policy. The bill would prohibit the sale of tobacco products to anyone born after 1 January 2009. All tobacco products, cigarette papers, waterpipe tobacco and herbal smoking products were included in the proposal.2872 Later that month, the Westminster government opened a four nations consultation on the tobacco endgame policy, as well as on potential measures to curb the rise in youth e-cigarette use.73

The consultation closed on 6 December 2023.74 In response to the submissions, the Westminster government confirmed its plans to introduce a generational tobacco ban, ban disposable e-cigarettes and bring forward new powers which would allow the government to restrict e-cigarette flavours, packaging and retail display.75 The Scottish and Welsh governments stated that they would also be introducing the new legislation.7677

After two readings at the House of Commons, on 17 April the government published a call for written evidence on the bill,78 with oral evidence sessions on 30 April and 1 May.79

In April 2024, Scotland introduced a Tobacco and Vapes Bill Legislative Consent Memorandum.80Evidence sessions were held in May, and UKVIA and the Scottish Grocers’ Federation were invited to contribute.8182 UKVIA described the session as “constructive”.83 See below for more on these organisation.

With the bill at Report stage,84 on 22 May, the UK Prime Minister  announced a general election to be held on 4 July.85 Although Sunak said in his speech that ‘[w]e will ensure that the next generation grows up smoke free,’ the bill was not among the legislation to be rushed through before the dissolution of parliament.868788

Accordingly, the UK bill has been shelved.89

Interference from industry and associated organisations

After the generational policy was announced, tobacco control researchers outlined arguments that they anticipated the industry would use to in an attempt prevent or undermine the UK legislation, based on previously used tactics. These included invoking libertarianism and arguments around personal freedom; claiming that the policy would be unworkable and impossible to police; and that it would have unintended consequences, such as increasing cigarette smuggling.90

In December 2023, there were reports that the tobacco industry was lobbying the government to increase the age of smoking to 21, instead of introducing the new generational endgame legislation.91 An industry source quoted by The i newspaper stated that the generational ban was “unenforceable, and the inevitability of such a ban leading to a black market run by dangerous criminal gangs, there’s a large number of libertarian Tory MPs that do not like the idea the government is limiting people’s free choice…if the Prime Minister does cancel the plan, then [the industry] won’t object to him raising the smoking age to 21”.91 The illicit tobacco trade has often been used by tobacco companies to promote key misleading narratives that advance their own business goals.  See also Arguments and Language.

The i also revealed that the tobacco industry had been “inundating MPs with lobbying material in a bid to persuade them to oppose the changes”. It also reported that a letter was sent to MPs, seemingly from constituents, but in fact drafted by employees of tobacco companies, which called the generational ban “ridiculous” and “impractical, illiberal and untested”.91 Andrea Leadsom MP, Parliamentary Under Secretary of State in the Department of Health and Social Care, warned that the industry was working behind the scenes to block the policy.92

Tobacco company lobbying

Tobacco companies lobbied the UK Department of Health and Social Care (DHSC) directly, using many of the same arguments, although only Philip Morris International (PMI) went as far as to issue a legal threat.

In November 2023, PMI sent a pre-action protocol (PAP) letter to the DHSC.9394 The PAP letter argued that the consultation was predetermined and that it failed to give adequate reasons regarding the inclusion of heated tobacco products (HTPs). It also argued that  the consultation period was not long enough did not allow the submission of sufficient additional evidence.93 In a preliminary response (December 2023), the government stated that it was already possible for organisations to upload supporting documents, but to make this clearer, this instruction had been added to the consultation landing page.95

The government’s full response a week later stated that the legal challenge was “misguided and wholly without merit” and would be “an unjustified attempt to delay or derail important legislative change”.96 With regard to HTPs, it stated that some of PMI’s claims were “highly subjective and lack supporting independent evidence”. The response concluded that:

“The Government does not intend to enter into any negotiations with the tobacco industry…and will not as you propose “discuss, on an urgent basis, the potential removal of HTP from the scope of the proposed legislation” …the proposed claim has no merit and your client is urged to reconsider its intention to pursue the claim”.96

The Telegraph newspaper reported that PMI later withdrew the threat, stating “We notified the government of procedural flaws in the consultation process. They subsequently amended the consultation procedure to allow substantive responses and answered other enquiries. As such, we withdrew the claim on 15th January”.94 PMI told the newspaper  that it agreed with the UK’s smoke-free 2030 plans, but did “not believe that reduced-risk smoke-free products—including heated tobacco—should be included alongside combustible cigarettes in any potential legislation”.94 In December 2023, PMI reportedly held roundtable events with UK MPs in to lobby for its heated tobacco products (HTPs) to be exempt from future smoking bans.91

Phillip Morris Limited (PML) also created a website, called ‘not a cigarette’ which states that HTPs and e-cigarettes(vapes) are not similar to cigarettes so should not be included in the ban. The site appears to be targeted at policy makers.97

In November 2023, a law firm acting on behalf of British American Tobacco (BAT) contacted the DHSC, arguing that  the proposals would “materially impact the rights of our clients and others”. It also argued that there was not enough information “regarding the impacts and costs and benefits of the proposals to permit intelligent consideration”, and – as had PMI – stated that consultation period was not long enough, and did not allow the submission of sufficient supporting evidence.98 BAT were reported to be sponsoring a roundtable due to be hosted by MP Graham Brady on behalf of the Centre for Policy Studies in December 2023 to “discuss the Government’s smokefree ambitions, what policies could support the goal, and what a Conservative approach to public health should look like.”9199 BAT stated that the proposed legislation would be difficult to enforce, and risked creating a new category of “under-age adults”.100 It also published briefing in response to the consultation, which outlined its stance on e-cigarette restrictions.101

Imperial Brands and the Tobacco Manufacturers’ Association also reportedly engaged with MPs and government officials regarding the proposals, with a spokesperson for Imperial Brands stating “We understand the Government’s desire for new tobacco control measures, because of the health risks associated with smoking. But, like any prohibition, the proposal to ban the legal sale of cigarettes over time threatens significant unintended consequences.”91

In December 2023, Imperial also wrote to the DHSC, arguing that the consultation was “materially deficient and unfair in several important respects”. As with PMI and BAT, Imperial stated that the consultation period was not long enough, and did not allow the submission of sufficient supporting evidence. It also argued that the evidence base for the proposal should be shared.102 Imperial published a summary of its response to the government consultation. It said it opposed the generational ban, as it would be “unworkable and unenforceable, and would see an explosion of illicit trade in tobacco”. It also argued that it would not reduce smoking rates.103 Imperial’s UK head of corporate and legal affairs stated in the retail press in January 2024 that it was having “direct conversations with government” and talking to MPs “to make them aware of illicit trade that is already a problem in their constituencies” including highlighting “loss of revenue for the average retailer”. Imperial also stated that it did not support e-cigarette restrictions including plain packaging, device standardisation, or flavour bans.104

In November 2023, Japan Tobacco International (JTI) carried out a survey of 1000 convenience retailers in the UK, and reported concerns that a smoking ban would harm business, increase illicit trade, make ID checks more complicated for retailer staff and impact staff training around underage sales.105106 A JTI feature in Talking Retail, ‘The Generational Ban: Explained’, described the ban as “an experimental policy not supported by evidence”, and encouraged retailers to respond to the government consultation.107

In March 2024, an article sponsored by JTI was published on Labour List (which is “supported by but independent of the Labour Party”)108 “as a contribution to public discussion”. Written by MP Virendra Sharma it criticised the generational smoking ban policy, it echoed industry arguments.109

Ahead of the second reading on 16 April 2024, The Guardian reported tobacco industry lobbying activities to derail the bill.110  According to Cancer Research UK the tobacco industry had been working behind the scenes on a variety of tactics, including direct e-mails to MPs from BAT. Arguments used included increasing the age from 18 to 21, excluding cigars from the ban, and adding a clause to allow future amendments.110Chris Whitty, England’s Chief Medical Officer, urged MPs to ignore tobacco industry lobbying and to support the bill:

“[tobacco industry] talking points, usually introduced by paid lobbyists, need to be addressed head on. They try to link their products to ‘choice’ despite the fact their sales are based on addiction (taking choice away)’.110

In total 56 submissions were made in response to the call for evidence.111 Each of the ‘big four’ transnational tobacco companies said they were supportive of the smokefree generation policy but raised various objections:

  • PML asked the government to reconsider integrating HTPs deeming this measure “inappropriate” and accusing it of ignoring supporting evidence.112
  • BAT stated that ‘smarter regulations’, are needed. It also opposed the inclusion of HTPs and criticised the age restriction, describing it as “ineffective”, unnecessary and impossible to enforce”. It suggested raising the age from 18 to 21 years citing “[i]ndependent evidence” on its effectiveness. BAT also opposed restricting flavours to adults .113
  • Imperial Brands said that the bill will lead to increase in illicit trade and violence against retailers. Imperial also criticised the government for “grant[ing] significant powers to ministers to regulate the vape category”. It also argued for increasing the age from 18 to 21, citing the “intrusion on the public’s freedom to make informed choices”. Imperial Bands opposed the inclusion of HTPs in the definition of tobacco products, and the restriction of flavours in electronic products .114
  • JTI argued that the bill “fails the test of proportionality; it is deeply illiberal; it would be impractical to implement; and it would hand the UK’s tobacco market to criminals.” Opposing the age restriction JTI argued that “[t]he Government’s own data, released as part of the consultation process for the Bill, shows that raising the age to 21 would have a similar effect on UK smoking rates without the need for a generational ban and the associated impracticalities ”.115

The Scandinavian Tobacco Group submission opposed the inclusion of cigars and pipe tobacco arguing that consumption of these product is low in the UK and restricted to specific demographics.116117 However, recent evidence from a nationally representative cross-sectional survey examining adult smoking in England revealed a significant increase in pipe, cigar, or waterpipe from approximately 150,000 in 2013 to over 770,000 in 2023. Cigars were the most popular of the three.118

There is a listing of the organisations and individuals that have submitted written evidence to the Tobacco and Vapes Bill Committee here

Lobbying by industry-linked organisations

The Institute of Economic Affairs, a British think tank with a history of tobacco industry funding, published a briefing paper in November 2023 titled ‘Prohibition 2.0: Critiquing the Generational Tobacco Ban’.119 The report echoed the industry narrative that a smoking ban would drive illicit trade and “bolster criminal gangs”. It also stated that a ban would “lead to a grey market in sales between friends” and that it “infantilises one cohort of adults, discriminates on the basis of age and raises issues of intergenerational unfairness.”119 The report disregarded figures published in a review commissioned by the UK’s Department of Health in 2022 relating to the cost of smoking to the NHS, and stated “The reality is that smokers pay far more in tobacco duty than they cost the state in healthcare, while nonsmokers cost the state more, on average, in both healthcare and social security payments”.119 Action on Smoking and Health (ASH) published an analysis in December 2023 which found that smoking costs England £49.2 billion each year in lost productivity and service costs, plus an additional £25.9 billion lost quality adjusted life years due to premature death from smoking – far outweighing the money brought in from tobacco taxes.120

 

The Consumer Choice Center (CCC), a US lobby group with a history of tobacco industry funding and links to the Atlas Network, launched a campaign titled ‘No2Prohibition’ which urged the public to contact their MP to oppose the new legislation.121 The campaign used the argument that the legislation would result in an increase in illicit trade and stated “Discriminating against adult consumers, depending on what year they were born, is unheard of and would set a dangerous precedent for future regulations. What’s next? Alcohol? Sugar? Fat? We can only imagine”.121 The campaign included a series of social media adverts centred on messages of freedom of choice and prohibition.122 These ads were removed by Meta as they did not include verified “paid for by” disclaimers.122

Forest, a British based Smokers’ rights group with a history of tobacco industry funding, stated that it had urged the government not to introduce a generational ban, ahead of the government consultation deadline in December 2023. It also commissioned a consultancy to carry out a survey, which it states found that “58% of respondents think that if a person can vote, drive a car, buy alcohol, or possess a credit card at 18, they should also be allowed to purchase tobacco”.123

The Association of Convenience Stores (ACS) is an organisation that represents local stores in the UK. Its “Premier Club” members include BAT, JTI, PMI, Imperial Brands and JUUL.124 ACS stated in December that it had responded to the government consultation, and in its submission “set out a number of concerns about the practical implications of the [generational endgame] policy”. It also stated that it did not support a ban on disposable e-cigarettes.125

In April 2024, ahead of the second hearing, the Association of Convenience Stores(ACS) along with the Tobacco Manufacturers’ Association (TMA) spoke out against the bill. They warned that age restrictions could lead to anti-social behaviour against retailers, who would have to deal with an increase in aggressive behaviour from customers.126127 The TMA said that any age ban should be fixed, rather than changing every year, so that that retailers would be able to credibly enforce it.127  ACS members, including major UK retailers, have also lobbied against a ban on single use products.128

The Scottish Grocers Federation (SGF), a trade association for convenience stores with tobacco company members, published an article opposing several possible new retail regulations, which included the generational tobacco policy and restrictions on the sale and visibility of e-cigarettes, stating that it would harm retail businesses.129 Regarding the disposable e-cigarette ban, the SGF Chief Executive warned against “unintended consequences such as an increase in illicit trade” and said that it would “engage with both governments to ensure the best outcome for retailers and their communities”.130 SGF also protested its exclusion from the government’s response to the consultation, due to SGF’s connections with the tobacco industry.131 SGF has also oppose the Scottish proposed tobacco free ban, stating that policy is not a practical solution speculating that the ban.132

However Action on Smoking and Health (ASH) polling showed that most small retailers in England and Wales support a smokefree generation policy.133The World Vapers Alliance (WVA), which has links to BAT, criticised the generational smoking ban. It argued that the UK should instead be “doubling down on its harm reduction strategy”.134 WVA also urged the public to respond to the government consultation to oppose e-cigarette flavour restrictions, the disposable e-cigarette ban and inclusion of heated tobacco products in the generational smoking ban.135 After the consultation closed, WVA published a press release which urged the government to reconsider its stance on banning disposable e-cigarettes.136

The UK Vaping Industry Association (UKVIA) published a press release opposing the e-cigarette regulations, stating “the tobacco industry and illicit markets will be the only winners from bans on disposables and flavoured vapes”.137 (UKVIA stated in September 2023 that all of its tobacco company memberships had ended. For details see the UKVIA page).

UKVIA, has also criticised the Tobacco and Vape Bill Committee for not inviting the industry to provide evidence to the bill describing the process as ‘fundamentally undemocratic’. UKVIA said it have submitted two amendments to the committee, but both have been ignored. The UKVIA said that ”[i]f the government ignores our warning, we will ensure we hold them to account for the impacts of an out-of-control black market, as they are now seeing in Australia.”138 On May 16, 2024 UKVIA sent a letter to the Prime Mister demanding an apology from the Public Health Minister Andrea Leadsom, who said that she would not consider a licensing scheme for e-cigarette retailers. This had been suggested by the e-cigarette industry, paid for by the industry, with funds passed to Trading Standards to “police underage and illicit sales”.139

 

 

Relevant Links

TobaccoTactics Resources

Tobacco Control Research Group (TCRG) Research

Sunak’s smoke-free generation: spare a thought for the tobacco industry, G. Hartwell, A.B. Gilmore, M.C.I . van Schalkwyk, M. McKee, BMJ, 2023; 383 :p2922 doi:10.1136/bmj.p2922

 

 

 

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References

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