british american tobacco p.l.c. sustainability report 2010 - Tobacco regulation and engagement

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Sustainability Report 2010

Tobacco regulation and engagementWe support balanced regulation that is based on sound evidence, meets public health objectives and enables our business to grow but does not damage the livelihoods of farmers or retailers. The Group’s businesses operate under increasingly stringent regulatory regimes around the world. Further regulation is expected, particularly as a result of the World Health Organisation’s Framework Convention on Tobacco Control (FCTC). Unduly restrictive regulation could impair our ability to communicate with adult smokers and has the potential to increase operating costs. Our challenge is to overcome perceptions that we subvert the regulatory process for our own gain and demonstrate that we deserve a seat at the table.

In 2010, the FCTC continued to drive the industry’s regulatory agenda. Governments are increasingly incorporating recommendations in FCTC guidelines into national regulation.

The World Health Organisation's FCTC

The FCTC contains provisions aimed at reducing both the supply of, and demand for, tobacco products. It came into force in 2005, and by the end of 2010, some 170 governments had ratified the Convention. The FCTC provisions include public place smoking bans; comprehensive advertising bans; packaging and labelling requirements; ingredients and emissions testing and disclosure; promotion of economically sustainable alternative crops for tobacco farmers and the development of a Protocol to address illicit trade in tobacco products. The governments that have ratified the Convention must consider how they will implement its provisions into national law.

We support effective, evidence-based regulation that reduces the public health impacts of tobacco consumption. We also seek to be involved in shaping regulation, contributing our experience and expertise. It concerns us that governments have begun to exclude not only the industry from the debate, but also other stakeholders, such as tobacco farmers.

We believe that views advocated in policy formation should be communicated transparently. We also support best practice principles on the development of regulation, including those of the Organisation for Economic Cooperation and Development (OECD), the UK Better Regulation Executive and the EU Communication on ‘smart regulation’. The views we advocate are detailed on Opens in new window.

In 2010, we continued to coordinate a consistent approach to key regulatory issues by our companies. Our regulatory centre of expertise led this work by developing global engagement positions and providing support to our companies.

Our engagement in 2010 focused on the FCTC product guidelines and the progress report on alternative crops. These include recommendations to restrict or prohibit ingredients and recommendations that could see farmers obliged to phase out tobacco growing ahead of any decline in market demand. Our views on these issues are set out below and you can read our positions on other issues, such as packaging and retail display of products in Regulatory issues.

Ingredients bans

Small quantities of ingredients have been added to tobacco products for centuries. These help to control moisture, maintain product quality or act as binders or fillers. Certain food-type ingredients balance the natural tobacco taste, often replacing sugars lost in the curing process. We support any restrictions on ingredients that, based on sound evidence and supported by published and peer-reviewed science, are found to encourage underage smoking or make tobacco products more harmful.

In some countries, smokers prefer cigarettes that blend types of tobacco, such as burley and oriental, which need additional ingredients. If allegations about the health risks, addictiveness and attractiveness of these ingredients were valid, we would expect to see increased incidence of tobacco-related disease, lower quitting rates and more people taking up smoking in these countries compared to those where smokers prefer unblended cigarettes, which contain few or no added ingredients. Many independent and internationally recognised studies show this is not the case.

Ingredients - our view

All tobacco products pose risks to health. The ingredients our companies use have been selected based on the following criteria:
  • At the levels used, they do not add to the health risks of smoking. Nor do they encourage people to start smoking or make it more difficult for people to quit.
  • They are not added to make our tobacco products appealing to children.
  • They do not create a sweet, chocolate-like or fruity taste in the smoke. In short, our cigarettes still taste like cigarettes and not sweets or candy.

We voluntarily publish the ingredients we use at Opens in new window.

Ingredients bans that are not based on sound evidence could unjustly damage the livelihoods of some burley and oriental tobacco growers as demand for their crop would reduce. A coalition of tobacco growers, including the International Tobacco Growers’ Association, which represents over 30 million growers, states that a ban will damage the economies of countries where communities depend on tobacco growing (for more information see the coalition’s website Opens in new window). Illicit trade may also increase if consumers turn to the black market to find the tastes they prefer.

Alternative crops

Many of the social, environmental and economic challenges given as reasons for moving farmers out of tobacco growing are common to all agricultural crops. For example, water would be required whatever the crop grown and deforestation occurs to make land available for many crops other than tobacco.

Less than one per cent of the world's agricultural land is given over to tobacco farming and for part of the year that land is used to grow non-tobacco crops. Our Social Responsibility in Tobacco Production (SRTP) programme addresses the sustainability issues associated with growing tobacco.

We believe that any assessment of alternative livelihoods for tobacco farmers should be based on evidence, use an agreed methodology and involve growers, merchants, manufacturers and unions.

In 2010, along with other industry players, we engaged with the International Labour Organisation (ILO) on the impact of regulation on employment and working conditions in the sector. We also supported the International Tobacco Growers’ Association to represent tobacco growers’ interests in the regulatory debate.

Regulation: what's next?

We will continue to advocate effective regulation based on evidence and sound science, which takes into account the views of interested parties. Our engagement with the ILO and other international organisations will continue to aim to ensure that prospective regulation is assessed for its impacts on issues including employment and free trade.