We believe that as a responsible tobacco business, we can contribute, through information, ideas and practical steps, to helping regulators address the key issues surrounding our product
uk bat.com - Our views on key regulatory issues
We believe that views advocated in policy formation should be communicated transparently clear to everyone. Our views and positions covered below are the same as those we advocate in externally.
We also welcome the opportunity to respond to government consultations on regulatory issues. You can download a copy of our recent submissions below to the UK Government’s consultation on plain packaging of tobacco products below:
Submission to the UK government plain packaging consultation 2012 (1.6 mb) 
Plain packaging
Some governments are considering regulation to restrict the colours, designs and trademarks that can be used on tobacco packaging. Plain packaging is a policy with potentially significant consequences, not all of which are well understood. We believe governments need to think proposals like this through very carefully and conduct more robust research. Read more in plain packaging of tobacco products.
Alternative crops
The Framework Convention for Tobacco Control (FCTC) requires governments who are party to it to promote, as appropriate, economically viable alternative crops for tobacco farmers to grow where their livelihoods are seriously affected as a consequence of local tobacco control programmes. We support this.
We believe that while the demand for tobacco exists, farmers should have the right to choose whether they grow tobacco or not and that governments should not try to drive farmers out of tobacco growing as this can result in social, economic and other impacts for those farmers and their wider communities.
Any assessment of economically sustainable alternative livelihoods to tobacco cultivation should be evidence based, look at all the potential impacts and use a methodology agreed in consultation with impacted growers, key tobacco producing countries, tobacco merchants and manufacturers. We agree that governments should consider the protection of the environment and the health of people engaged in tobacco cultivation in their countries and decide what measures they may wish to introduce. But we believe that independent research should be carried out to assess the environmental and social impact of tobacco growing in comparison with other types of crops.
To help contribute to this evidence base, in 2011, we commissioned independent research into the impact of tobacco farming on communities and the environment, which you can read about in the debate on tobacco farming.
Ingredients bans
Some people claim that ingredients are used in tobacco products to make smoking more appealing to children and more addictive. FCTC guidelines recommend that governments restrict or prohibit the use of ingredients.
We support restrictions or prohibitions on ingredients that are shown through sound scientific evidence to enhance the pharmacological effects of nicotine or to lead to increased underage smoking. The ingredients our Group companies use have been selected based on criteria that, at the levels used, they do not add to the health risks of smoking, they do not encourage people to start smoking or make it more difficult for people to quit and they are not added to make our tobacco products appealing to children.
Instead of a ban on all ingredients, we advocate legislation prohibiting the sale of tobacco products with an overt fruity or candy taste that masks the taste of the tobacco and where the nature of the product or product packaging may be attractive to the underage.
Read more in tobacco ingredients.
Pricing and tax
A working group of parties to the FCTC is developing possible draft guidelines on pricing and tax measures intended to reduce demand for tobacco products.
The FCTC itself does recognise that it is the sovereign right of countries to determine their own taxation policies. We believe it is not within the competence of any FCTC group, the World Health Organisation or anyone other than each national government to decide the tax and fiscal policies it thinks appropriate for its country. These should also take into account any potential unintended consequences, for example, sudden and significant hikes in excise rates can result in price disparities between neighbouring countries. This can lead to an increase in smuggling across borders, driving the tobacco market into the hands of criminals and depriving the country of tax revenue. We recommend gradual and predictable increases in excise that address public health concerns, boost tax revenues and do not increase the illegal tobacco trade.
Retail display bans
Some countries have banned, or are considering banning, displays of tobacco products in shops. Instead of being on display, the products are hidden under the counter or behind curtains or screens, making it hard for customers to know what is available. This approach is based on claims that displays encourage people, in particular children, to smoke and that they demotivate people who are trying to quit.
However, in countries where display bans have been introduced, such as in Iceland and Canada, there is no clear evidence to show that these have had a significant effect on smoking prevalence among either children or adults. These bans may also have negative consequences, such as an increase in the illegal tobacco trade and damage to the livelihoods of small retailers.
To help address youth smoking, we instead advocate stronger enforcement of minimum age laws and more severe penalties for retailers caught selling tobacco products to the underage; the introduction of schemes such as a ‘No ID No sale’ programme; and programmes to raise retailers’ awareness of minimum age laws.
Where retail display bans are introduced we aim to work with retailers to minimise disruption to their business. For example, prior to the ban coming into effect in New South Wales in Australia, we gave the retailers practical guidance on how to comply with the legislation and how to maintain business as usual, as far as possible, for their customers.
Read more in retail display bans.
