Tobacco Control Research Group: Evidence on Plain Packaging
Published research from the Tobacco Control Research Group (TCRG), part of the UK Centre for Tobacco & Alcohol Studies (UKCTAS), has shown how global tobacco companies commissioned, cited and critiqued evidence as part of a campaign to prevent the introduction of plain (standardised) packaging for their products in the UK.
Tobacco companies used this strategy to argue that plain packaging “won’t work” and will lead to “dangerous growth” of the illicit tobacco trade. Evidence to support these claims was promoted through the media and in submissions to government.
A series of peer-reviewed research papers authored by academics from the TCRG highlighted the misleading nature of tobacco companies’ evidence on plain packaging, emphasising that:
- Tobacco companies cited evidence that did not directly consider plain packaging to argue that regulation “won’t work”;
- Evidential critiques commissioned by tobacco companies used misleading techniques to discredit public health research on plain packaging;
Tobacco Company Evidence Weak or Off-Topic
Evidence cited by tobacco companies, in submissions to the first UK Consultation on the plain packaging of tobacco products in 2012, to support their argument that plain packaging “won’t work” was either low-quality or off-topic.
By analysing consultation responses, Hatchard et al. found that much of the ‘evidence’ cited by tobacco companies should be viewed sceptically. Of the 77 pieces of evidence cited by four global tobacco companies:
- Only 17 addressed the impact of plain packaging on smoking (see Figure 1);
- None were published in peer-reviewed journals, an important marker of scientific quality;
- 14 of the 17 (82 per cent) were either commissioned by or linked to global tobacco companies;
- In some cases this link was not clearly stated by the tobacco companies in their consultation responses.
- Tobacco company evidence on plain packaging (n=17) was significantly less relevant and less high quality than evidence (n=37) included in a systematic review of the policy, which found that removing all branding and design from cigarette packs would make them less attractive for both adults and children and increase the prominence of health warnings (see Figure 2).
Tobacco Companies Commission Misleading Evidential Critiques
These tobacco industry-funded reports fundamentally misreported papers in the systematic review. Papers were mis-quoted, distorting their main messages, and each paper was dismissed as flawed even though they had been published in peer reviewed journals.
A TCRG study found that BAT’s and JTI’s argument that there is no evidence that plain packaging will benefit public health was underpinned by three complementary techniques that systematically misrepresented the evidence base:
- Studies in the systematic review were repeatedly partially quoted or misquoted, distorting or even contradicting the main study messages, with the result that evidence supportive of standardised packaging was transformed into evidence against it.
- Industry-commissioned academics used what superficially resembled scientific peer review to discredit standardised packaging research. Micro analysis revealed this to be a “mimicked” version of scientific review that relied on essentially unscientific perspectives and methods. Four techniques were used:
- 1. Methodological perfectionism : Industry experts insisted that the policy could only be introduced if there was evidence of an actual reduction in smoking directly attributable to plain packaging. They dismissed as invalid research on psycho-social mechanisms (e.g. reduced appeal) through which such change may occur. This was neither feasible or appropriate, however, as observational evidence could not be obtained without the policy first being introduced. Additionally, they claimed that the limitations of a study – regardless of their nature and seriousness – invalidated the study in its entirety.
- 2. Methodological uniformity : The reviews were embedded in a market research paradigm and this narrow perspective was used to systematically dismiss any study that did not fit within the market research model. AS a result, qualitative research was similarly dismissed as invalid.
- 3. Lack of rigour: The objectives, experimental processes and analytic strategies of the reviewed papers were repeatedly misrepresented or incorrectly interpreted; steps taken by the original authors to minimise the impact of limitations were ignored; inconsistent quality criteria and double standards were used.
- 4. Litigation model : The reviews, rather than scientific critiques aiming to improve the original work, resembled courtroom testimonies aiming to demolish the adversary’s evidence by foregrounding and exaggerating every limitation and remaining silent on strengths. The experts (working outside the peer-review system) dismissed – piece-by-piece – the entire evidence base for plain packaging with disregard for the strength and rigour of existing evidence.
- Tobacco companies and commissioned experts used what researchers referred to as “evidential landscaping” to divert attention away from packaging to alternative evidential areas (e.g. psycho-social drivers of smoking) and to withhold highly relevant company evidence on the importance of packaging to marketing strategies.
Tobacco Companies’ Claims on Illicit Trade Lack Credibility
Tobacco companies used their own data to claim that levels of illicit tobacco use in the UK are high and increasing and will increase further if plain packaging is implemented.
Two TCRG studies showed that tobacco companies exaggerated the threat of illicit tobacco as part of a public relations strategy to undermine plain packaging. Therefore, their data and claims should be treated with extreme caution.
One forensically examined PMI’s 2010 Project Star report on the European illicit cigarette trade, commissioned annually by PMI. The second examined industry data and related press coverage in the UK, comparing industry data with independent data from various sources. It also examined industry reporting of Her Majesty’s Revenue and Customs (HMRC) data on illicit trade.
The TCRG studies showed that:
- Tobacco companies deliberately sought to solicit press coverage on illicit tobacco trade in the UK using their “empty pack surveys”, which involved the collection of discarded cigarette packs to determine their authenticity.
- Media stories citing industry data on illicit tobacco suddenly began in June 2011, two months after publication of the Tobacco Control Plan for England, which heralded plain packaging, and continued throughout policy deliberations.
- These stories contradicted official statistics showing steady declines in both non-domestic and illicit cigarettes from 2006 to 2012 and either a continued decline or small increase to 2013 (see Figure 3, Table 1).
- Methodological details of tobacco company surveys were either absent or inadequate to assess data quality:
- In the one instance where (inadequate) methodological details are given, in the Project Star report, it is apparent (albeit only on very close reading) that a methodological change will artificially inflate the 2012 data which cannot therefore be directly compared with earlier data.
- All industry data appear to come from their own empty pack surveys. These have a number of limitations, most notably that they can only measure non-domestic products, which includes legal and illegal products and it is therefore not possible to distinguish between legal (legal cross-border and duty-free shopping and products brought in by tourists) and illegal non-domestic products. Furthermore, they are often only undertaken in the largest cities and at sports events where illicit tobacco is likely to be more prevalent. As such they can exaggerate the scale of the illicit tobacco trade in the UK. The lack of transparency of data on illicit trade is problematic and serves industry interests.
Latest Evidence from Australia
In Australia, where plain packaging was introduced in December 2012, calls to Quitline increased, individual pack display decreased, Treasury figures show cigarette sales fell 3.4%, there has been no increase in transaction times, no defection to larger stores to make tobacco purchases, and the Borders and Customs Agency and recent research maintains there has been no impact on the illicit trade.
These early policy outcomes contradict the claims made by tobacco companies in the UK, and complement the TCRG’s research, which has raised serious questions about the trustworthiness and scientific value of tobacco companies’ arguments that plain packaging “won’t work” and will have “serious unintended consequences”.
For more TCRG research on the tobacco industry, see Tobacco Control Research Group: Peer-Reviewed Research.
- J. Hatchard, G.J. Fooks, K.A. Evans-Reeves, S. Ulucanlar, and A.B. Gilmore, A critical evaluation of the volume, relevance and quality of evidence submitted by the tobacco industry to oppose standardised packaging of tobacco products, BMJ Open 2014, accessed July 2014
- S. Ulucanlar, G.J. Fooks, J.L. Hatchard and A.B. Gilmore, Representation and Misrepresentation of Scientific Evidence in Contemporary Tobacco Regulation: A Review of Tobacco Industry Submissions to the UK Government Consultation on Standardised Packaging, PLOS Medicine 2014, accessed July 2014
- A. Rowell, K. Evans-Reeves and A.B. Gilmore, Tobacco industry manipulation of data on and press coverage of the illicit tobacco trade in the UK, Tobacco Control 2014, accessed July 2014
- A.B. Gilmore, A. Rowell, S. Gallus, A. Lugo, L. Joosens and M. Sims, Towards a greater understanding of the illicit tobacco trade in Europe: a review of the PMI funded ‘Project Star’ report, Tobacco Control 2013, accessed July 2014
- L.A. Bero, T. Montini, K. Bryan-Jones and C. Manqurian, Science in regulatory policy making: case studies in the development of workplace smoking restrictions, Tobacco Control 2001, accessed July 2014
- C Moodie, M. Stead, L. Bauld, A. McNeill, K. Angus, K. Hinds, I. Kwan, J. Thomas, G. Hastings, and A O’Mara-Eves, Plain tobacco packaging: a systematic review’, 2012, accessed July 2014
- British American Tobacco, UK Standardised Packaging Consultation: Response of BAT, 2012, accessed July 2014
- W. Keegan, Analysis of consumer survey evidence relevant to DG SANCO's proposal to increase the size of health warnings on tobacco packaging, 2010, accessed July 2014
- T. Devinney, Analysis of consumer research evidence on the impact of plain packaging for tobacco products (updated to 2012), 2012, accessed July 2014
- J.M. Young, I. Stacey, T.A. Dobbins, S. Dunlop, A.L. Dessais and D.C. Currow, Association between tobacco plain packaging and Quitline calls: a population-based, interrupted time-series analysis, Medical Journal of Australia, 2014, accessed July 2014
- M. Zacher, M. Bayly, E. Brennan, J. Dono, C. Miller, S. Durkin, M. Scollo and M. Wakefield, Personal tobacco pack display before and after the introduction of plain packaging with larger pictorial health warnings in Australia: an observational study of outdoor café strips, Addiction 109(4), 2014, accessed July 2014
- Department of Health, Australia, Tobacco key facts and figures, 2014, accessed July 2014
- A. Corderoy, Tobacco industry claims on impact of plain packaging go up in smoke, Sydney Morning Herald 2014, accessed July 2014
- M. Scollo, M. Bayly, M. Wakefield. Availability of illicit tobacco in small retail outlets before and after the implementation of Australian packaging legislation. Tobacco Control, 2014
- M.Scollo, M. Zacher, S. Durkin, M. Wakefield. Early evidence about predicted unintended consequences of standardized packaging of tobacco products in Australia: A cross-sectional study of place of purchase, regular brands and use of illicit tobacco. BMJ Open, In Press