british american tobacco p.l.c. sustainability report 2010 - Regulatory issues

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Sustainability Report 2010

Other key regulatory issues for British American Tobacco and the views our companies advocate on them are detailed below:

Regulatory issues

Packaging and labelling

We support the inclusion of appropriate health warnings on packs and other primary packaging. However, we are strongly opposed to plain packaging, the trend towards outsized product labelling requirements and the gradual removal of pack elements. There is no evidence to support the claims that plain packaging would achieve public health objectives and indeed it may even undermine them. Counterfeit would become easier to produce and branded illicit products that do not comply with the regulation could become more attractive to consumers.

Public place smoking

We support regulation to restrict smoking in enclosed public places and indoor work places that accommodates the interests of smokers and non-smokers alike, and limits non-smokers’ involuntary exposure to environmental tobacco smoke. We believe that smoking should be permitted in outdoor areas. We support ways to improve consumer education about cigarette butt littering.

Retail display of products

We oppose bans on tobacco displays in the retail environment as there is no clear evidence to suggest that bans lower smoking rates or reduce underage smoking. Bans could lead to an increase in illicit trade by driving the sale of the legal product under the counter and could also distort competition among tobacco companies.


Many national governments use tobacco taxation as a key instrument to reduce rates of smoking, while also raising significant excise revenue. However, sudden increases in excise rates can result in consumers switching to cheaper illicit products. We support gradual and predictable increases in excise that enable tax revenues to be increased and public health policy to be supported, without exacerbating the risk of illicit trade.

Product guidelines

As part of the Framework Convention on Tobacco Control, product guidelines are being developed that will provide direction on testing, measuring, disclosing and regulating the contents and emissions of tobacco products. It is our view that these guidelines should contain proportionate and evidence-based recommendations, supported by published and peer-reviewed scientific research, and guided by a clear public health rationale.