british american tobacco p.l.c. sustainability report 2011 - Other regulatory issues

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Sustainability Report 2011

Ingredients bans

Some people claim that ingredients are used in tobacco products to make smoking more appealing to children and more addictive. Framework Convention for Tobacco Control (FCTC) guidelines recommend that governments restrict or prohibit the use of ingredients.

Other regulatory issuesHowever, the World Health Organisation has obtained and published comprehensive data on youth smoking rates in Canada, a country where cigarettes that do not use ingredients are preferred, and the United States, where cigarettes containing ingredients are popular, through its coordination of the Health Behaviour in School-aged Children study. This data allows for a comparison to be made of levels of underage smoking in the two countries. Further comparable data on smoking rates in the general population in both Canada and the United States have been reported in a joint study by Statistics Canada and the United States Centre for Disease Control, designed and conducted to allow for direct comparison.

Together, these studies indicate that cigarettes containing ingredients are no more attractive than those containing low levels of or no ingredients. Specifically there are no substantial differences in youth smoking initiation or smoking rates between the two countries.

Some of our products use small quantities of ingredients to help control moisture, maintain product quality or act as binders or fillers. They also help balance the natural tobacco taste, often replacing sugars lost in the curing process. We do not condone the use of ingredients for the purpose of making tobacco products more attractive to children by creating an overtly fruity or candy taste that masks the taste of tobacco.

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.

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 the FCTC working 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 levels 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.




Tobacco ingredients, in the context of proposed restrictions or prohibitions, predominately mean any substance that is added to the tobacco during the manufacturing process.

This does not include substances that make up other components of a tobacco product, such as the filter, tipping paper or adhesives used in a cigarette.

Tobacco ingredients have a specific function and should not be confused with organic substances, such as nicotine, which are naturally present in the tobacco plant, nor smoke constituents, such as carbon monoxide, which are produced when a cigarette is burned.
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