Association of Convenience Stores

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

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’

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. 

Affiliations

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

TobaccoTactics Resources

• British American Tobacco
• Imperial Tobacco
• Philip Morris
• Japan Tobacco International
• Third Party Techniques
• Plain Packaging in the UK
• PMI’s Anti-Plain Packaging Lobbying Campaign
• Industry Arguments Against Plain Packaging
• Countering Industry Arguments against Plain Packaging
• EU Tobacco Products Directive Revision
• Industry Interference and the 2001 EU Tobacco Products Directive
• All Party Parliamentary Small Shops Group

TCRG Research

• Evidence on Plain Packaging