Standardised tobacco packaging - Purpose of the briefing
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March 2015
Standardised tobacco packaging
Purpose of the briefing
This briefing sets out the public health case for standardised tobacco packaging. It defines standardised
packaging, explains the legal and political context, summarises the research to support the measure, and
addresses the counter arguments put forward by the tobacco industry and their allies in opposition to the
measure.
Summary
• Now that tobacco advertising and sponsorship is prohibited, tobacco packaging has become one of
the tobacco industry’s leading promotional tools.
• Research suggests that standardised packaging would increase the impact of health warnings,
reduce false and misleading messages that one type of cigarette is less harmful than another, and
reduce the attractiveness of smoking to young people.1
• Australia has become the first country in the world to require all tobacco products to be sold in plain,
standardised packaging.
• An independent review by Sir Cyril Chantler found no evidence to support the tobacco industry’s
arguments that standardised packaging would increase the illicit trade in tobacco.
• In January 2015 the Government announced that it would implement standardised packaging,
subject to a final vote on the regulations. In March, the regulations were approved by both Houses
of Parliament. The law is due to take effect in May 2016.
ASH Briefing: Standardised tobacco packaging
What is standardised packaging?
Standardised packaging, also known as plain, generic or homogenous packaging, refers to packaging
that has had the attractive promotional aspects of tobacco products removed and the appearance of
all tobacco packs is standardised including the colour of the pack.
The Australian regulations require:
• No branding other than the product name in a standard font, size and colour
• Prohibition of all other trademarks, logos, colour schemes and graphics
Only the following are permitted:
• Standard shape, size and colour for the pack and contents
• Graphic health warnings covering 75% of the front and 90% of the back of packs
• Qualitative rather than quantitative information on constituents and emissions
• Tax stamps
• Quitline number and web address on all packs
• All packs to be a standard drab brown colour in matt finish.
The road to legislation in the UK
In April 2012, the UK Government launched a public consultation which sought people’s views on
whether or not standardised packaging should be adopted, or whether a different option should
be considered.2 Coinciding with the consultation launch, the Public Health Research Consortium
published a systematic evidence review.1 The consultation closed in August 2012. In July 2013,
a summary report on the consultation was published together with a written Ministerial Statement
in which the Secretary of State for Health said that the Government “has decided to wait until the
emerging impact of the decision in Australia can be measured before we make a final decision on this
policy in England”.3 In September 2013, the Public Health Research Consortium published an update
of its systematic review.4
In November, a cross-party group of peers tabled an amendment to the Children and Families Bill to
introduce standardised tobacco packaging.5
Facing possible defeat in the House of Lords over the matter, on 28 November 2013 the Government
announced that it would introduce its own amendment to the Children and Families Bill to give the
Secretary of State for Health the power to introduce standardised packaging through regulations.
However, the Government also announced that before the introduction of any regulations there would
be a review of the public health evidence to be conducted by a paediatrician, Sir Cyril Chantler. Sir
Cyril published his report on 3rd April 2014 in which he concluded that standardised packaging would
have a positive impact on public health (See public health section below.).6
Responding to the Chantler report, the Minister for Public Health said that she was “minded to
proceed with introducing regulations to provide for standardised packaging”, subject to a further short
consultation to take into account any evidence that had arisen since the end of the 2012 consultation.7
In January 2015 the Government announced that it would bring forward legislation and that
regulations would be laid and voted on before the end of the parliamentary session on 30th March.8
The regulations were tabled in February.9 On 11th March MPs voted by a clear majority in favour of
the measure (367 for versus 113 against).10 The following week the regulations were debated and
approved in the House of Lords without a vote.11 The new law is due to take effect on 20 May 2016 to
coincide with the implementation of the revised EU Tobacco Products Directive.
Public Opinion
There is widespread public support for tobacco to be sold in plain, standardised packaging. A YouGov
survey in March 2014 found that overall 64% of adults in Great Britain support or strongly support this
while just 11% oppose the measure.12
A recent study found that since standardised packaging was introduced in Australia, smokers’ support
for the measure has risen sharply from 28.2% prior to its introduction to 49% after implementation.13
2 - ASH Briefing: Standardised tobacco packaging
Other Countries
Australia became the first country in the world to require all tobacco products to be sold in plain,
standardised packaging. The law came into effect on 1 December 2012.14
In addition to Australia and the UK, Ireland has passed legislation to introduce standardised packaging
which is also expected to be implemented in 2016.15 The measure is also under formal consideration in
Finland, France, New Zealand and Norway.16 Standard packaging is supported by a range of experts
and international bodies.17 Furthermore, under the terms of the revised EU Tobacco Products Directive,
Member States will be permitted to introduce standardised tobacco packaging.18
Tobacco Advertising & Promotion: UK and EU law
EU law defines tobacco advertising as “any form of commercial communication with the aim or direct
or indirect effect of promoting a tobacco product”.19
In 2003, the Tobacco Advertising and Promotion Act came into effect in the UK.20 The Act prohibited
virtually all forms of tobacco advertising and promotion, i.e. advertising in print media, on billboards
and in the form of direct marketing. By July 2005, sponsorship of sport by tobacco companies was also
prohibited.
As part of the Health Act 2009, regulations to prohibit the display of tobacco products at the point
of sale were implemented. The regulations entered into force in April 2012 for large shops such as
supermarkets. All remaining shops will be required to comply with the display ban by April 2015. For
further details see the ASH Briefing on Tobacco Displays at the Point of Sale (pdf). While this measure
protects children from tobacco promotion in retail settings, standardised packaging is also needed to
prevent exposure to tobacco imagery elsewhere.
The current (2001) EU Tobacco Product Directive21 states that: “texts, names, trade marks and
figurative or other signs suggesting that a particular tobacco product is less harmful than others shall
not be used on the packaging of tobacco products.” The revised Directive passed by the European
Parliament on 26th February 2014 and due to enter into force in 2016 will require the following:
• Cigarette and hand-rolling tobacco packaging to include a combined picture and text health
warning covering 65% of the front and the back of the package, placed at the top of the pack
• Standardised cuboid shape of cigarette packs to ensure clear visibility of health warnings
• Ban on the sale of packs containing fewer than 20 cigarettes
• Removal of misleading information on tar, nicotine and carbon monoxide
• Ban on use of any promotional descriptors such as references to flavours
In addition, Member states will have the option of introducing further measures such as standardised
packaging to remove the promotional features.
Since implementation of the EU Directive in 2003, the tobacco industry has been required to remove
misleading descriptors such as ‘light’ or ‘mild’. However, the legacy of ‘low-tar’ advertising has resulted
in certain colours such as white and silver being associated with ‘lighter’ or ‘lower-tar’ products giving
the impression that they are less harmful than regular brands. The continuing use of colours as
indicators of ‘less harmful’ brands by the tobacco industry can be viewed as being in contravention of
the law.
Packaging as advertising
While the tobacco products display ban will help to reduce children’s exposure to tobacco promotion
this measure alone is not sufficient to protect children. Tobacco packaging is now the most ubiquitous
form of tobacco advertising. Smokers display the branding every time they take out their pack to
smoke. In doing so they are making a statement about how they want to be seen by others as they
display and endorse the brand they have chosen. The importance of the pack as a communication
tool is acknowledged by the tobacco industry as this response from Philip Morris Limited to the
Government’s consultation on the future of tobacco control illustrates:
3 - ASH Briefing: Standardised tobacco packaging..”as an integral part of the product, packaging is an important means of differentiat-
ing brands and in that sense is a means of communicating to consumers about what
brands are on sale and in particular the goodwill associated with our trademarks, indi-
cating brand value and quality. Placing trademarks on packaged goods is, thus, at the
heart of commercial expression.”22
Similarly, legal representatives of Japan Tobacco International, in proceedings in the
Australian High Court, asserted that the Commonwealth “is acquiring our billboard, your Honour, in
effect”.23
Branding recruits children and young people to a life-time of addiction
Currently approximately 100,000 people die prematurely from smoking-related diseases every year in
the UK. Tobacco companies therefore need to recruit new smokers to stay in business. New customers
are nearly always children and young people. Two thirds (66%) of regular smokers start before the age
of eighteen – the legal minimum age for the purchase of tobacco - and two fifths (39%) start before the
age of sixteen.24 Of those who take up smoking, only about half will manage to stop before they die.25
The UK Tobacco Advertising and Promotion Act has been effective in removing overt promotional
activity and has brought about a consequent reduction in awareness of tobacco marketing amongst the
young.26 However, branding continues to drive teen smoking, and awareness of packaging and new
pack design is a key element of this ongoing marketing.27,28 Research shows that this has already had
an effect: between 2002 and 2006 there was an increase in the proportion of young people aware of
new pack design from 11% in 2002 to 18% in 2006.26
Lambert & Butler – case study
In a presentation to an industry conference in 2006, Imperial Tobacco’s Global Brand
Director, Geoff Good, acknowledged that the tobacco advertising ban in the UK had
“effectively banned us from promoting all tobacco products” and noted that “In this
challenging environment, the marketing team have to become more creative” adding: “We
therefore decided to look at pack design.”
Focusing on the UK’s most popular cigarette brand, Lambert & Butler, Imperial developed
a new version of the Lambert & Butler brand to mark its 25th anniversary in the UK
market. The “Celebration” packs were launched in November 2004 as a 4-month special
edition, replacing the original pack until February 2005. According to Good: “The effect
was very positive. Already the no.1 brand, our share grew by over 0.4% during this period
– that might not sound a lot – but it was worth over £60 million in additional turnover and a
significant profit improvement.”
Good concludes: “Often in marketing, it is difficult to isolate the effects of individual parts
of the mix. But in this case, because the UK had become a dark market, the pack design
was the only part of the mix that was changed, and therefore we knew the cause and
effect.”
Good, G. Global Brand Director, Imperial Tobacco Group plc. Presentation at UBS Tobacco Conference,
01 December 2006
Established adult smokers tend to be brand loyal and the majority know which brand they will ask
for before they walk into a shop.29 Therefore, new, young smokers are the primary target of industry
marketing. Brand imagery is much more important to younger age groups and they respond more
effectively to it than older groups.30 Moving to standardised packaging would therefore reduce brand
appeal and reduce smoking initiation.
4 - ASH Briefing: Standardised tobacco packagingThe public health case for standardised packaging There is a growing body of research evidence in support of standardised packaging. Peer reviewed studies have found that, compared to branded cigarettes, plain standard packaging is less attractive to young people, improves the effectiveness of health warnings, reduces mistaken beliefs that some brands are ‘safer’ than others and is likely to reduce smoking uptake amongst children and young people.4,31,32,33 Key findings of the Public Health Research Consortium review A Government-commissioned systematic review of 37 studies providing evidence of the impacts of plain, standardised tobacco packaging was conducted by the Public Health Research Consortium (PHRC).1 Nineteen studies examined perceptions or ratings of attractiveness of plain, standardised packs. All of these studies found that standard packs were rated as less attractive than branded equivalent packs, or were rated as unattractive, by both adults and children. In addition, those studies that tested a range of branded and unbranded packs found that this difference increased progressively as more branding elements and descriptors were removed. With regard to health warnings, the studies reviewed found that plain packs were perceived as being less cluttered and therefore less likely to detract from the health warning, and that the dullness or seriousness of the packs enhanced the seriousness and credibility of the warnings. Studies which examined the impact of plain packs on perceptions of harm and strength found that results were mixed as perceptions varied according to the colour of the packs. However, studies which examined perceptions of which pack was more effective in terms of raising awareness of health risk tended to find that plain standardised packs were perceived as more effective than branded packs. Sixteen studies in the PHRC review examined whether and how plain packs impact on smoking- related attitudes and beliefs. Although the findings were mixed, the overall pattern tends to be supportive of standard packaging being perceived to have a likely deterrent effect on smoking. Studies that looked at differences by age found that younger respondents were more likely than older respondents to perceive that standard packs would discourage take-up of smoking, encourage cessation or reduce consumption. An update of the review examined a further 17 studies which have added to the evidence suggesting that standardised packaging would: reduce the appeal of cigarettes and smoking; enhance the salience of health warnings on packs; and address the use of packaging elements that mislead smokers about product harm.4 Chantler Review In November 2013, Sir Cyril Chantler was commissioned by the Government to examine whether the introduction of standardised packaging would have an effect on public health, in particular in relation to the health of children.6 Chantler reviewed evidence from both public health bodies and that provided by the tobacco industry. 5 - ASH Briefing: Standardised tobacco packaging
He concluded by saying that he was:
“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 [tobacco] industry”.
And added:
“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.”
Evidence from Australia
Emerging evidence from Australia shows that standardised packaging may have an impact on
smoking prevalence. Before the measure was introduced in December 2012, daily smoking
prevalence stood at 15.1%. By December 2013 it had fallen to 12.8%.34 Standardised packaging
is the only new policy intervention over this time period and is therefore the most likely reason for
the significant fall in smoking prevalence. In addition, the Australian Government has released
figures showing a significant fall in consumption as measured by estimated expenditure on tobacco
products.35
New evidence published as part of a collection of articles in the journal Tobacco Control36 has
revealed that the introduction of standardised packaging has reduced the appeal of cigarette packs
to adolescents.37 Another study found that, contrary to tobacco industry claims, there has been no
evidence in Australia of increased use of illicit tobacco.38 Research has also revealed that smokers
are now less likely to openly display their cigarette packs following the introduction of standardised
packaging. The authors conclude that this is likely to reduce smoking-related social norms, thereby
weakening an important influence on smoking uptake and better supporting quit attempts.39
Tobacco Industry fears about standard packaging
According to Philip Morris International the world’s major manufacturers have agreed to fight the
introduction of standard packaging stating that they ‘do not want to see plain packaging introduced
anywhere regardless of the size and importance of the market.’ 40
In 2008 Tobacco Journal International reported that according to analysts Morgan Stanley, if generic
packaging becomes a legal requirement in the UK it “could result in considerably reduced profits.” 41
What industry analysts say about plain packaging:
“regulations… have to date neither undermined industry profitability nor led
to commoditization of the cigarette category. However, a ban on conventional
packaging graphics could prove to be a very different matter.” 42
“Plain packaging would significantly reduce the power of tobacco brands.”
“The industry is so profitable only because consumers are willing to pay a premium
of £1.50 for certain brands. We think this measure would cause a rapid worsening
of the downtrading trend. Over time this would hurt profitability significantly.” 43
“Clearly, smokers won’t like it. However, I suspect that the majority of the
population that does not smoke will be in favour of the proposal. Anything which
boosts the public health is good.” 44
6 - ASH Briefing: Standardised tobacco packagingTrade agreements and trade marks Where standard packaging has been suggested, the tobacco industry has responded with vigorous campaigning, claiming that it would contravene national and international legal obligations on free trade and the protection of trade marks. On the day that the Australian government passed legislation to introduce plain packaging Philip Morris immediately launched a lawsuit to challenge the law 45 despite the fact that the tobacco companies are aware that all these trade agreements contain important exceptions for health-related issues which have been defended successfully.46 In response to the Australian government’s proposed legislation, the tobacco industry claimed that standardised packaging laws would involve the acquisition of trade mark and be in breach of article 16 of The Agreement on Trade-Related Aspects of International Property Rights (TRIPS). However, Article 16 does not create a right to use a trade mark, it simply prevents third parties from using trade marks and this right would not be affected by plain packaging.47 The industry challenge was rejected by the Australian High Court in August 2012.48 Despite the tobacco industry’s public protestations, its own internal documentation has revealed that it does not believe it has a case under the TRIPS agreement, that “current conventions and treaties afford little protection”, and that there is “little joy” in GATT/TRIPS.49 Impact on illicit trade Contrary to industry claims, there is no evidence that standardised packaging will lead to an increase in the illicit trade in tobacco.50 In his examination of the Australian experience, Sir Cyril Chantler reported that he had found “no convincing evidence to suggest that standardised packaging would increase the illicit market”.6 Tobacco packs are already easily counterfeited which is why the industry is required to add covert markings to distinguish legitimate products from counterfeit.51 Standardised packs will have all the health warnings and other markings required on current packs so they will be no easier to counterfeit than branded packs. Impact on retailers The tobacco industry argues that standardised packs will lead to an increase in tobacco smuggling so reducing legal sales and cause confusion and additional costs to retailers which will disproportionately affect small retailers. As noted above, there is no convincing evidence that standardised packs would result in a rise in illicit sales. The industry has claimed that selling standardised packs would incur extra staff time, taking up to 45 seconds longer per sale compared to selling branded packs. This was based on a small sample of only six tobacco retailers who were asked to estimate what the impact would be.52 However, evidence- based research measuring over 5,000 transactions found that standardised packs if anything reduced transaction times and selection errors.53 The findings of this simulation exercise have subsequently been confirmed in actual retail settings in Australia. Following implementation of standard tobacco packaging in December 2012, researchers found overall improvements in retailer efficiency.54 Tobacco sales will decline gradually but not overnight as the main impact will be on reducing uptake amongst young people not on current smokers, so shops will have time to adapt. Small retailers will still be located far more conveniently to smokers than will large retailers so there is no reason why they should be disproportionately affected by any change in sales due to standardised packaging. Impact on price The tobacco industry has argued that standardised packaging would lead to a reduction in the price of tobacco products and, consequently, smoking would increase.55 A review of this analysis commissioned by ASH56 found the research overstated the extent to which prices would fall. A similar conclusion was reached by Sir Cyril Chantler who, after commissioning further research, concluded that the risk of such effects undermining the objective of standardised packaging were small and that the impact could be mitigated by raising the tax on tobacco.6 For further analysis of the tobacco industry arguments see www.tobaccotactics.org For information on the campaign for standardised packaging see www.smokefreeaction.org.uk/plain-packaging.html 7 - ASH Briefing: Standardised tobacco packaging
References
1 Moodie C, Mackintosh AM, Stead M, et al. Plain tobacco packaging: a systematic review, Public
Health Research Consortium, University of Stirling, 2012
2 Consultation on standardised packaging of tobacco products, Department of Health, 16 April 2012.
3 Consultation on Standarised Packaging of Tobacco Products. Written Ministerial Statement, Department
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9 Standardised Packaging of Tobacco Products Regulations 2015
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12 Opinion research from YouGov. Total sample size was 12,269. Fieldwork was undertaken between
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representative of all GB Adults (aged 18+). Question asked of respondents: The image above is an
example of a ‘plain standardised pack’ based on Australian legislation passed two years ago (Source:
ASH, 2012). Thinking about the packaging above, to what extent would you support or oppose the
following? Requiring tobacco to be sold in plain standardised packaging with the product name in
standard lettering.
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the UK, all members of the Smokefree Action Coalition support standard packaging,
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30 Beyond Smoking Kills: protecting children, reducing inequalities. London, Action on Smoking and Health,
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8 - ASH Briefing: Standardised tobacco packaging31 Plain packaging of tobacco products: A review of the evidence. Cancer Council Victoria, 2011
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42 Plain packaging is a serious threat but quite unlikely. Morgan Stanley, 2008
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ASH briefings are available on our website at www.ash.org.uk/briefings
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