British American Tobacco - Submission to the UK government plain packaging consultation

British American Tobacco has handed in its submission to the Department of Health outlining its views regarding the topic of Plain Packaging of tobacco products in the UK.

Phil Morse, UK & Ireland General Manager for British American Tobacco, said in response:

“As we have outlined in our submission, we oppose plain packaging for many credible reasons. In fact, we believe the arguments against plain packaging are overwhelming. In particular, we are concerned that the Department of Health’s research into the potential benefits of plain packaging relies on insufficient and unreliable evidence that fails to prove the crucial link between packaging and any reduction in smoking.

“We welcome this consultation and the Government’s stated commitment to a transparent debate and consultation process. We hope the Government’s commitment to maintaining an open mind is demonstrated over the coming weeks and months.

“As a  legitimate industry which employs thousands of people in the UK and raises billions in taxes for the Exchequer, all we are asking for is a fair, open, evidence-based debate regarding a serious issue that could have catastrophic unintended consequences.”

Notes to editors

The British American Tobacco submission raised the following key arguments:

• It would not be effective in reducing smoking prevalence since tobacco packaging is not a relevant factor in people’s decision to smoke or quit.


• The DoH has not considered the relevant research and relies on insufficient and unreliable evidence that fails to make the crucial link between packaging and any reduction in smoking. 


• It would exacerbate an already significant illicit trade problem in the UK. 


• It would have other significant adverse unintended consequences such as lowering prices and thereby increasing smoking, reducing government revenue, and harming  small business. 


• Plain Packaging is unlawful as it would not only breach several UK, EU and international laws and agreements, but would constitute a wholesale expropriation of BAT’s valuable intellectual property, requiring payment by the Government of very significant compensation. 


• Given the acknowledged risks, the DoH has not demonstrated that the benefits would outweigh the adverse consequences of Plain Packaging. 


• There a number of alternative evidence-based options that are proportionate, effective, workable and can achieve public health objectives.

NB – The submission response follows the specific DOH questions.

Key areas of interest:

• Effective Alternative Measures   Q1 (pg10)
• Lack of evidence    Q3 (pg 16)
• Ineffectiveness of PP     Q4 (pg 27)
• Impact of PP on the market    Q 5 (pg32)
• Legal Implications     Q6 (pg 38)
• Cost for Manufacturers   Q7 (pg46)
• Retailer impact    Q8 (pg 50)
• Illegal Tobacco Growth   Q9 (pg 54)
• Flaws in Consultation Process  Q 14 (pg 69)

UK standardised packaging consultation: Response of British American Tobacco UK Limited (1.6 mb)