India Archives - TobaccoTactics https://tobaccotactics.org/topics/india/ The essential source for rigorous research on the tobacco industry Thu, 04 Apr 2024 13:54:06 +0000 en-GB hourly 1 https://wordpress.org/?v=6.4.3 https://tobaccotactics.org/wp-content/uploads/2020/02/tt-logo-redrawn-gray.svg India Archives - TobaccoTactics https://tobaccotactics.org/topics/india/ 32 32 India Country Profile https://tobaccotactics.org/article/india-country-profile/ Thu, 14 Sep 2023 14:58:55 +0000 https://tobaccotactics.org/?post_type=pauple_helpie&p=14953

Key Points India is a country located in South Asia, part of the World Health Organization’s South-East Asia Region. It had a population in 2022 of 1.42 billion. Amongst those aged 15+, tobacco use prevalence is 28.6%. Smoking prevalence in India is 10.7%. However, the most popular form of tobacco in India is smokeless tobacco, […]

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Key Points

  • India is a country located in South Asia, part of the World Health Organization’s South-East Asia Region.
  • It had a population in 2022 of 1.42 billion. Amongst those aged 15+, tobacco use prevalence is 28.6%.
  • Smoking prevalence in India is 10.7%. However, the most popular form of tobacco in India is smokeless tobacco, with use prevalence of 21.4%.
  • India ratified the WHO Framework Convention on Tobacco Control in 2004, and the Protocol to Eliminate Illicit Trade in Tobacco Products in 2018.
  • The Indian cigarette market is dominated by four companies, which together accounted for 98% of sales in 2022. ITC Limited holds by far the largest market share, at over 73%.
  • The tobacco industry has deployed a wide range of tactics in India in recent years, including mobilisation of front groups and third parties; litigation against tobacco control measures such as graphic health warnings; and corporate social responsibility, including in partnership with government.

Since the early 2000s, India has made significant progress in tobacco control, introducing a comprehensive tobacco control law in 2004, reducing the affordability of tobacco products, and introducing graphic health warnings (GHWs) consistent with best practice worldwide.12 However, major challenges persist. The wide range of tobacco products available in India makes regulation and enforcement particularly complicated. The Indian state is also a major shareholder of ITC Limited, which has by far the largest share of the Indian market. This means that the government has an interest in socio-economic issues – such as ensuring the welfare of farmers and manual labourers working in the Indian tobacco industry, and protection of exports – as well as in public health.3

India remains the world’s second largest consumer, producer and exporter of tobacco.45

Tobacco Use in India

In 2022, the population of India was 1.42 billion.6 In the 2016-17 Global Adult Tobacco Survey (GATS), approximately 29% of the population aged 15+ reported current tobacco use – over 42% of males, and over 14% of females.27 This means that in absolute numbers, there were almost 267 million tobacco users in India aged 15 and over.4 In the 2019 Global Youth Tobacco Survey (GYTS), amongst adolescents aged from 13 to 15, 8.5% reported using some form of tobacco – nearly 10% of males, and over 7% of females.28

Amongst India’s smokers, the most popular product was not factory-made cigarettes but bidis: cigarettes rolled by hand in a dried leaf of the tendu tree. 7.7% of Indian adults reported smoking bidis, compared to 4% who smoked cigarettes.7

However, the most popular tobacco product in India overall is smokeless tobacco (SLT). More than 21% of Indians aged 15 and over reported being SLT users, compared to less than 11% who smoked, whether cigarettes, bidis, or both.27 SLT use is also significant amongst women and girls: nearly 13% of females aged 15 and over were SLT users, compared to 2% who smoked.27 The majority of female tobacco users in low- and middle-income countries (LMICs) are SLT users in India and Bangladesh.9 However, amongst adolescent tobacco users, smoking is more common than SLT use. Over 7% of adolescents reported current smoking, compared to just over 4% who were SLT users.28

India has the second highest number of oral cancer cases globally, accounting for a third of the total.10 More than 90% of India’s oral cancer cases are caused by tobacco use and of these, more than half are caused by SLT.11 The poor and less educated are worst affected, with much higher SLT use prevalence amongst these sections of the population.11 There were also over a million deaths attributable to smoking in 2019, accounting for nearly 11% of all mortality in India that year.12

A 2020 study put the economic cost of all illness and death attributable to tobacco use between 2017 and 2018 for those over 35 years of age at US$27.5 billion.13 Smoking accounted for 74% of this cost; smokeless tobacco 26%.13 Direct medical costs alone amounted to 5.3% of all health expenditure.13 However, the excise tax revenue from tobacco the previous year was just 12.2% of its economic cost.13 In simple terms, the economic burden of tobacco use is more than eight times the value of revenue the Indian government receives in excise from tobacco products.13 This economic burden accounts for over 1% of India’s GDP.13

Tobacco in India

Market share and leading brands

The Indian cigarette market is dominated by four companies:  ITC Limited, Godfrey Phillips India Limited (GPI), VST Industries Ltd., and Philip Morris International (PMI), which together accounted for 98% of sales in 2022.14

India banned foreign direct investment in tobacco manufacturing in 2010, which means that the transnational tobacco companies (TTCs) can only access the Indian market via shareholdings and licensing agreements with local producers.1516

ITC Limited

ITC Limited (formerly India Tobacco Company Limited), dominates the Indian tobacco market, with a share of over 73% in 2022.14 Its largest shareholder is British American Tobacco (BAT), which held just under 30% of shares until March 2024.1718 The Indian state is also a major shareholder, via various state-owned insurance corporations and investment portfolios.18 Its products include India’s three bestselling brands of cigarettes: Gold Flake, Wills and Scissors.19

In a presentation to investors in June 2023, BAT CEO Tadeu Marroco stressed the importance of the company retaining at least a 25% shareholding in ITC, given that this provides BAT with seats on the ITC board and the right to veto company resolutions.20 Marroco also highlighted the potential of the vast Indian market in terms of newer nicotine and tobacco products, particularly oral products such as nicotine pouches.20 In March 2024, BAT reduced its holdings in ITC to 25.5%.21For more details see ITC Limited.

Godfrey Phillips India Limited (GPI)

GPI had a market share of almost 10% in 2022, the second largest after ITC.14 PMI is the second-largest shareholder with a stake of just over 25%.22 Major brands include Four Square, Cavenders and Tipper.19

VST Industries Ltd

VST, formerly Vazir Sultan Tobacco Company, had a market share of over 9% in 2022, the third largest.14 With a stake of over 32%, BAT is its largest shareholder.23 Its major brands include Total, Charms and Charminar.19

TTCs’ licensing agreements

PMI has a licensing agreement with GPI, under which GPI manufactures and sells the brands Marlboro and Red & White in India, though PMI retains brand ownership internationally.141924 This gives PMI a 5.4% market share from a global ownership perspective.14 Similarly, ITC manufactures and sells the brands Berkeley and Benson & Hedges in India, though Japan Tobacco International and British American Tobacco are the global owners, respectively.1419 Both companies have a market share of less than 2%.14

Smokeless tobacco and bidis

The Indian smokeless tobacco industry is based largely on small scale, rural production, for which accurate data is not available.25 Local manufacturers account for significant segments of the market in several regions of India.25 Similarly, bidi production depends largely on small home-based manufacturing operations and accurate data is not available.25

At the national level, the biggest companies in the chewing tobacco/gutkha (see section “Undermining the gutkha ban”) market are believed to be Dhariwal Industries, Dharampal Satyapal (DS Group) and Som Sugandh Industries, which together accounted for around a quarter of sales in 2010.25 There is also interest from the big cigarette companies in smokeless tobacco; Godfrey Phillips launched its own range of chewing products in 2010.26 A 2021 paper found that 93% of SLT products bought in India were non-compliant with packaging regulations: either they did not have graphic health warnings, or the warnings were too small.27

Tobacco farming

India is the world’s second biggest tobacco producer after China, producing over 766,000 tonnes of leaf in 2020.28 This accounts for 9% of all global production.5 Though tobacco production in India has increased significantly in recent decades – from 438,500 tonnes in 1980 – it has fallen slightly from a high of 830,000 tonnes in 2011.29

Child labour

Indian bidis feature on the U.S. Department of Labor’s 2022 List of Goods Produced by Child Labor or Forced Labor.30 While information on child labour in the bidi industry is not widely available, a study published in 2009 found that more than 1.7 million children worked rolling bidis in India.31 This disproportionately affects girls, who are often drawn into the industry to support their families. Bidi rollers may work 10 to 14-hour days to produce over 1,000 bidis, in what a BBC report from 2012 described as “slave-like working conditions”.31

Tobacco and the economy

India is the world’s second largest exporter of tobacco leaf, after Brazil.5 According to UN Comtrade, India exported nearly US$816 million in raw tobacco in 2022, compared to nearly $21 million in imports.3233 Export figures for 2021-2022 from the Indian Brand Equity Foundation (IBEF) – a trust established by the Indian Department of Commerce – were slightly higher, at US$842 million.5

India exports tobacco to more than 115 countries around the world, the biggest recipient of which is Belgium, which accounts for around 18% of India’s total tobacco exports. Other major export destinations for Indian tobacco include the United Arab Emirates, Singapore and the United States.5

India is also a major net exporter of cigarettes. According to UN Comtrade, it exported over US$100 million in cigarettes in 2022, compared to nearly $26 million in imports.3435

According to IBEF, the tobacco industry in India employs about 36 million people in farming, processing, manufacturing and export activities.5

Illicit trade

The Tobacco Institute of India, an industry body established by ITC, GPI and VST in 1992, puts the scale of the illicit tobacco trade at a quarter of the market.36 However, independent studies put that figure much lower, at around 3% to 6%.37 This makes illicit trade in India relatively small by global standards.38 A 2018 study, which found that 2.73% of the empty cigarette packs collected in India were illicit, noted significant differences across the country.39 Areas with greater illicit trade penetration are often targeted by studies funded by the tobacco industry to exaggerate overall levels of illicit trade.40

Studies have also cast doubt on industry claims that tobacco tax increases have led to expansion of illicit trade. For example, according to ITC, tax increases during the period 2012 to 2017 resulted in rapid growth of illicit trade, making India the fourth largest illicit market globally.41 However, a study published in 2020 by experts from the WHO and the Indian government put the illicit cigarette trade at 6% of the market in 2016-17 – an increase of just 0.9% from 2009-10.38

Similarly, a joint report published in 2017 by the accountancy firm KPMG and the Federation of Indian Chambers of Commerce and Industry (FICCI) argued that illicit trade – driven in part by higher taxes on cigarettes – was providing funds for terrorism and organized crime.42 However, both ITC and GPI are members of FICCI, which has a history of opposing tobacco control measures in India (see Influencing policy: graphic health warnings). Similarly, KPMG has strong ties with the tobacco industry going back decades, and its work on illicit trade has been strongly criticised elsewhere. Critics argue that KPMG’s research has exaggerated the scale of illicit trade and has been used to oppose tobacco control regulations such as plain packaging.

Tobacco and the environment

A 2018 study estimated that in order to produce 100 billion cigarettes, nearly 67,500 tonnes of CO2 equivalent were emitted in India in 2010 – the equivalent of 14,544 petrol-powered vehicles driven for a year.4344 The industry has also been a major cause of deforestation: it is estimated that 680 square kilometres of scrub forest were destroyed and degraded for tobacco curing and the manufacture of cigarettes and other smoking consumables between 1962 and 2002.45

A 2022 study estimated that 170,000 tonnes of waste is produced by the packaging of tobacco products annually in India, two-thirds of which correspond to smokeless tobacco (SLT) products.46 Analysis of segregated waste revealed that 73,500 tonnes of plastic, 6,100 tonnes of foil and 1,350 tonnes of used filters are discharged annually into the environment.46 Cleaning up this waste costs Indian taxpayers roughly US$766 million every year.47

Roadmap to Tobacco Control

India was the eighth country to ratify the WHO Framework Convention on Tobacco Control (WHO FCTC) in 2004.48 It ratified the Protocol to Eliminate Illicit Trade in Tobacco Products in 2018.4950

The Cigarettes and Other Tobacco Products Act (COTPA), passed in 2003, is the main comprehensive tobacco control law in India. Amongst other provisions, it banned smoking in most public places, prohibited the advertising of cigarettes and other tobacco products, and banned sales to anyone under the age of 18.51 Since then, a number of rules have been introduced to aid implementation of COTPA and provide definitions.1 In 2007-08, the government launched the National Tobacco Control Programme (NTCP), which aimed to reinforce COTPA and facilitate implementation of the tobacco control strategies contained within the WHO FCTC.52

In 2020, an amendment to COTPA was drafted by the Ministry of Health.53 Aiming to further strengthen the original legislation and boost compliance with WHO FCTC, it will abolish designated smoking areas, prohibit the sale of individual cigarettes (single sticks), and raise the legal age required for purchase of tobacco products from 18 to 21.5354 However, as of September 2023, this amendment has yet to become law.

Citing concerns about the health impacts of vaping on young people, the Indian government introduced a ban on electronic cigarettes in 2019. The law prohibits the production, manufacture, import, export, transport, sale, distribution, storage and advertisement of e-cigarettes.155 Though their use remains rare in India as of 2023, the law closes off a huge potential market for e-cigarette companies.56

For more details, please see the following websites:

Tobacco Industry Interference in India

Tobacco industry tactics in India include mobilisation of front groups and third parties; litigation against tobacco control measures, such as graphic health warnings; and corporate social responsibility, including in partnership with government.

Delaying rollout of larger graphic health warnings

In October 2014, the Indian Ministry of Health and Family Welfare announced its intention to increase the area covered by graphic health warnings (GHWs) on tobacco products, from 40% to 85%.57 GHWs are a well-established, evidence-based and cost-effective measure of reducing tobacco use.58 They may also be particularly effective in India, given both the country’s linguistic diversity and its literacy rate (as of 2018, over a quarter of the population was unable to read or write).5960

The tobacco industry deployed various tactics in an attempt to block this legislation. These included mobilising third parties and front groups, spreading misleading information, and submitting more than 30 legal challenges in state-level courts throughout India.6162

Third parties and front groups which mobilised against the legislation included the following:

These groups wrote letters to and met with policy makers, launched campaigns in the media against the proposal, and filed legal challenges.6162

For example, FAIFA bought full-page advertisements in leading national newspapers, claiming that larger GHWs would be detrimental to the livelihoods of tobacco farmers and fuel the illicit trade.6163 FAIFA, CII and FICCI all wrote letters to the Minister of Health, J.P. Nadda, echoing these arguments.6465 The Tobacco Institute of India filed a legal challenge against the government in the High Court of Karnataka.66 Finally, ASSOCHAM addressed a communiqué to the government, stating that the GHWs would endanger the livelihoods of more than 45 million people and lead to a flood of illicit imports.67

These industry strategies succeeded in delaying the rollout of the 85% GHWs for a year, from April 2015 until April 2016.68 However, the legal challenges continued even after implementation. In 2017, the High Court of Karnataka ruled that India should revert to the pre-2016 40% warnings. This decision was overruled in 2018 by the Indian Supreme Court and the 85% warnings have remained in force ever since.62

The eventual introduction of the 85% GHWs saw India jump from 136th to third position in the global ranking for size of health warnings on tobacco products.69

Undermining the gutkha ban

Gutkha, one of India’s most popular smokeless tobacco (SLT) products, is a mix of crushed Areca nut (a well-known risk factor for several cancers even when consumed without tobacco), with tobacco, catechu, paraffin, slaked lime and flavourings.7071 Highly addictive and very cheap, gutkha is popular amongst women and young people.72

Since 2012, there have been state-level bans throughout the country in an attempt to reduce its prevalence, but it remains widely available.7374 Producers have found ways to circumvent the bans, such as by packaging and selling the constituent ingredients of gutkha separately.7475

In the state of Tamil Nadu, gutkha remained widely available despite being banned in 2013.7677 In 2016, officials from India’s Income Tax Department discovered details of a series of suspected bribes worth nearly US$6 million made by leading manufacturer MDM to public officials, allegedly to facilitate the storage, transport and sale of gutkha.617678

Alleged recipients of bribes included a government minister, police officers and senior civil servants.79 In November 2022, after four years of investigations in three states, India’s Central Bureau of Investigation filed charges against 21 individuals.7976

Corporate social responsibility: partnerships with government

Tobacco companies often use corporate social responsibility (CSR) initiatives to enhance their public image and corporate reputation.

In the implementation guidelines for Article 5.3 of the WHO FCTC, the WHO states that these activities fall within its definition of tobacco advertising, promotion and sponsorship – and should therefore not be endorsed by Parties to the treaty.80 However, in India, under the Companies Act 2013, all large corporations are required to spend at least 2% of their average net profit in the previous three years on CSR.81 This helps to legitimise tobacco industry CSR, as companies argue they are only fulfilling their legal duties.3In its sustainability reporting, ITC states that its CSR initiatives fall within the scope of the 2013 legislation.82

ITC has contributed frequently to government programmes and has worked with government institutions.3 For example, in 2017, ITC contributed to a fund set up by the Indian government to attract funding from corporations and private donors for the provision of sanitation and clean drinking water; and to the Clean Ganga Fund, established by the government to rehabilitate the River Ganges.82 In his speech to shareholders at the 2017 AGM, the then ITC CEO cited several public-private partnerships with state governments in India on water management projects, stating that they aligned with a national programme which aimed to expand irrigation coverage and improve efficiency of water use.8384

This type of public-private CSR was particularly widespread during the COVID-19 pandemic. In total, between March and June 2020, the Indian tobacco industry contributed around US$36.7 million in donations to various government funds, both at federal and state level.81 The industry also partnered with other stakeholders, including NGOs, other private sector actors and even popular Bollywood singers. ITC was the biggest cash and in-kind contributor.8185

Corporate trademarks were widely visible during these CSR activities, and the initiatives were publicised in leading newspapers and by senior politicians.818687

Relevant Links

Tobacco Tactics Resources

TCRG Research

For a comprehensive list of all TCRG publications, including research that evaluates the impact of public health policy, go to TCRG publications.

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Factasia https://tobaccotactics.org/article/factasia/ Fri, 06 Nov 2020 16:17:42 +0000 https://tobaccotactics.org/?post_type=pauple_helpie&p=7613 Background Factasia.org is a Hong Kong based organization, founded in 2013, which promotes newer nicotine and tobacco products, including e-cigarettes (also known as electronic nicotine delivery systems, or ENDS) and heated tobacco products, and campaigns for their use in tobacco harm reduction. It is registered as a company, Fact Asia Consultants Ltd, in Hong Kong. […]

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Background

Factasia.org is a Hong Kong based organization, founded in 2013, which promotes newer nicotine and tobacco products, including e-cigarettes (also known as electronic nicotine delivery systems, or ENDS) and heated tobacco products, and campaigns for their use in tobacco harm reduction. It is registered as a company, Fact Asia Consultants Ltd, in Hong Kong.8889

As of October 2020, Factasia´s website stated:

“factasia.org seeks to represent the rights of adults in Asia who choose to enjoy smoking or other related forms of consumption of nicotine. factasia.org aims to protect their interests and to provide independent and unbiased data on the issues surrounding smoking – and related issues – in Asia. 90

According to the tobacco industry publication Tobacco Reporter, Factasia.org was formed to represent the rights and interests of smokers who choose to smoke or consume tobacco, and to provide data on the issues surrounding smoking in Asia.91

Factasia.org receives funding from Philip Morris International, as well as the Tobacco Vapor Electronic Cigarette Association (TVECA) and other companies providing services to the tobacco industry, according to its website.92

However, Factasia.org states that it does not work for the tobacco industry. 91

Activities

Factasia.org conducts its activities under three main themes that it describes as: “consumer choice, rational debate and sensible regulation”.90 It states that Factasia.org aims to communicate with consumers as well as politicians, legislators and appropriate law enforcement officials”.90 According to Tobacco Reporter, Factasia “aims to lobby on behalf of the millions of growers, distributors and retailers throughout the region whose livelihoods are under threat from bad legislation and excessive taxation” 91

Commissioned Surveys to Argue for Reduced Regulation

The organisation conducted several opinion surveys of smokers in Asia-Pacific markets through the polling company IPSOS. One survey conducted in 2015-2016 included responses from nine countries (Mecau, India, Malaysia, Singapore, Australia, Hong Kong, Taiwan, Philippines, and New Zealand) and over 4,200 smokers.93 This survey evaluated awareness, use and perception towards e-cigarettes. A similar survey was conducted in Hong Kong in 2018 with 1,000 respondents.94 Results of these surveys were presented in global pro-vaping conferences and used to develop support for reduced regulations and restrictions on e-cigarettes.95

In 2015, Factasia.org held an E-cigarette Symposium with speakers from the Institute of Economic Affairs (IEA). 96

Lobbied at COP8

Factasia has lobbied against the Conference of the Parties (COP) of WHO FCTC. Heneage Mitchell, cofounder and director of Factasia.org, was among the group who protested outside COP8 in Geneva in 2018, arguing that the WHO should accept harm reduction as a “basic human right” (Image 1).9798

Heneage Mitchell was present with Martin Cullip, a pro-tobacco blogger and Simon Clark, the Director of the tobacco industry front group Forest at a COP8 side event, hosted by the tobacco industry-funded, representing the Institute of Economic Affairs. The International Network of Nicotine Consumer Organisations (INNCO) was also present, after being denied FCTC observer status. For more information see the page on INNCO.

A picture of people.

Image 1.”Heneage Mitchell from Factasia (second from left) was part of a group protesting outside FCTC COP8 event in Geneva, 2018 (Source factasia.org)

Lobbied COP8 via Twitter

Researchers from the Tobacco Control Research Group (TCRG) analysed Twitter data to gain insights into activity of the tobacco industry and its allies, including Factasia.org, in the run up to COP8, and their attempts to influence the FCTC.99100

The researchers concluded that:

“The extensive activity by NGP advocates with links to organisations funded directly and indirectly by PMI … as well as a substantial online presence by PMI executives themselves, suggests a strategic approach by PMI to influence COP8 debates”.99.

For more details see International Network of Nicotine Consumer Organisations (INNCO)

Factasia.org is a supporter of the “Smoke Free for Life” (SF4L) campaign, organised by Coalition of Asia Pacific Tobacco Harm Reduction Advocates (CAPHRA).See below for details.101102

Relationship with the tobacco industry

According to Factasia.org’s website, Philip Morris International and Tobacco Vapor Electronic Cigarette Association (TVECA),  an e-cigarette trade association, are among its supporters.92

Other supporters listed on their website, as of October 2020, were are:92

  • Axiom Select LLC – Service provider to tobacco industry from machinery to services which include “regulatory issues, product development, harm reduction, cost / project management and sourcing.”.92103
  • Cerulean – Provider of test and measuring equipment for the tobacco industry. As a provider, it has presented at several tobacco industry events as the Global Tobacco & Nicotine Forum, World Tobacco Middle East, Tobacco Science Research Conference, among others. 104
  • Moisttech – Provider of moister & measurement control products, that provides services to the tobacco industry.
  • Primary Engineering (Thailand) Ltd – Provide service & maintenance for tobacco industry equipment

As stated on the Factasia.org website, its cofounder and director Heneage Mitchell has commentated on the tobacco industry across the Asia region for over 15 years.105 His LinkedIn profile states, he was the former managing editor/co-publisher at October Multimedia from 2009-2013 and managing editor of Lockwood Publications from 2002 –2009. 106  Lockwood publications was the publisher of industry publication Tobacco Asia.107.

John Boley, the other cofounder of Factasia.org was a speaker at the Global Forum on Nicotine (GFN) in 2016 and 2017. GFN is an event organised by Knowledge-Action-Change (K-A-C) which is funded by PMI-funded Foundation for a Smoke-Free World.

The panel of speakers at the Factasia.org E-cigarette Symposium 2015 included;  e-cigarette researcher Dr. Konstantinos Farsalinos, representatives of TVECA and the Asian Vape Association (AVA), and Terry Barnes representing Institute of Economic Affairs(IEA) (see image 2) 90. The IEA is a think tank which has a history of collaboration with the tobacco industry.108

Picture of Factasia E-cigarette symposium 2015

Image 2: Factasia.org E-cigarette symposium held in Hong Kong in 2015. From Left: Ray Story (TVECA), John Boley, Dr. Konstantinos Farsalinos, Heneage Mitchelle , Nav Lalji (AVA) (Source: Factasia)

Staff

Heneage (‘H’) Mitchell and John Boley, are both founders and directors of the organisation.106 109

According to his LinkedIn profile, Mitchell became Managing Director of factasia.org in October 2013, after working in journalism, publishing and other businesses, including writing on tobacco (see above for details). 106 He states that his specialities include public relations and campaign management.106 and in 2017.110 His presentation in 2016 was titled “Developing a united front for consumers to public health authorities in Asia-Pacific – challenges and opportunities” and, in 2017, “The lexicography of harm reduction”.111

Lobbying decision-makers

Collaborating with third party organizations and funding their activities in order to reach out to decision makers is one of the most common tobacco industry tactics.(See Third Party Techniques) Factasia has not been the exception, as evidenced in the promotion of  looser regulations for newer products in Australia:

Lobbied Therapeutic Goods Administration (TGA)

Regarding PMI´s IQOS, Factasia made a submission in June 2020, after the Australian medicines regulator, the TGA, made an interim decision refusing Philip Morris Ltd application to exempt its IQOS product from the Poison’s Schedule. Factasia´s submission argued that “It is unconscionable that Australia continues to ignore the evidence and is now seeking to further restrict access by adult smokers to these life-saving technologies by considering legislation to require a doctor’s prescription to purchase nicotine-containing vape products.” 112 Despite intense lobbying by PMI to allow the sale of IQOS, in August 2020, the Australian government’s Therapeutic Goods Administration rejected the sale of HTPs in Australia.113114.

Lobbied Australian parliament:

After lobbying with CAPHRA for fewer restrictions on e-cigarettes in Australia, in summer 2020,115   Factasia made a formal submission to the Australian Parliament on October 16, 2020, arguing that “The government has a unique opportunity to act for the good of its citizens by recognizing that harm reduced nicotine products save lives and benefit all Australian citizens by reducing the death and disease caused by smoking. Smokers need to be able to access the life-saving technology of harm reduced nicotine products. This should be a key part of Australia’s Tobacco Control policy”.  116 Furthermore, Factasia lobbied for newer products to be legalized in Australia and regulated differently than tobacco products. 116

Partnerships

Factasia.org is associated with the Coalition of Asia Pacific Tobacco Harm Reduction Advocates (CAPHRA)115  and supports its SF4L campaign.101 Heneage Mitchel was at the launch of SF4L, along with Peter Paul Dator, president of Vapers PH; Clarisse Virgino, the CAPHRA Philippine representative; and Nancy Loucas, executive director of CAPHRA (see image 3 below).117 102

A picture of the people at the launch of Smoke Free 4 Life

Image 3: (from left) Peter Paul Dator, president of Vapers PH; Clarisse Virgino, the Philippine representative to the Coalition of Asia Pacific Tobacco Harm Reduction Advocates; Nancy Loucas, executive director of CAPHRA; and Heneage Mitchell  at the Asia-wide education and information campaign #SmokeFree4Life in Poblacion, Makati City.

Relevant Link

Factasia.org

Tobacco Tactics Resources

TCRG Research

Robertson, A. Joshi, T. Legg T, et al., Exploring the Twitter activity around the eighth meeting of the Conference of the Parties to the WHO Framework Convention on Tobacco Control, Tobacco Control Published Online First: 11 November 2020, doi: 10.1136/tobaccocontrol-2020-055889

Stopping Tobacco Organizations and Products, Tweetable Influence: The Tobacco Industry’s Attempt to Engage in COP8, STOP blog, 12 November 2020, available from: exposetobacco.org

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Centre for Health Research and Education (CHRE) https://tobaccotactics.org/article/centre-for-health-research-and-education-chre/ Tue, 23 Jun 2020 11:11:53 +0000 https://tobaccotactics.org/?post_type=pauple_helpie&p=6586 The Centre for Health Research and Education (CHRE) states that it is “A health research and education company run by medical doctors in service of public health” and its aim is “bridging the policy & practice gap”. CHRE receives grants from the Foundation for a Smoke Free World (FSFW), an organisation wholly funded by Philip […]

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The Centre for Health Research and Education (CHRE) states that it is “A health research and education company run by medical doctors in service of public health” and its aim is “bridging the policy & practice gap”.118 CHRE receives grants from the Foundation for a Smoke Free World (FSFW), an organisation wholly funded by Philip Morris International (PMI).119120121122

Background

According to the CHRE website, the company is based in Hampshire, UK, at the University of Southampton Science Park.123124125 It was registered as a private limited company with UK Companies House in August 2018, with the registered business address in Chandlers Ford, Hampshire.119126

In 2020, CHRE’s website stated its goal as “preventing Cancer through research and evidence based policy and practice interventions” and it identifies its priorities as smoking cessation and obesity prevention. The cessation resources on its website recommend Nicotine Replacement Therapies (NRT) and e-cigarettes.127

As of 2020, its website stated that “CHRE does not receive any funds from tobacco, pharmaceutical or e-cigarette companies”.128

It also stated that:

“If there are research and evidence gaps regarding “unhealthy” behaviours, those gaps need to be plugged by all the stakeholder groups that have a vested interest in improving public health in the context of those behaviours. We are committed in advocating for and enabling such research, shaping policy, and help bridge the divide between policy and practice.”
[original text in bold]129

The CHRE website was updated in 2021.130

Relationship with the tobacco industry

According to his LinkedIn profile, CHRE Medical Director Dr. Sudhanshu Patwardhan worked for British American Tobacco (BAT) from 2005 until February 2019, and became one of the two directors of CHRE in February 2019.131 According to UK Companies House records he was appointed Director of CHRE in August 2018 (see below for more details).132 A conflict of interest statement on a 2021 journal paper about nicotine pouches highlighted S. Patwardhan’s prior work with BAT subsidiary Nicoventures and also that co-author Karl Fagerström “currently receives consulting fees from Swedish Match [a manufacturer of nicotine pouches] and has received fees in the past from tobacco companies to assist their development of less-risky tobacco products.”133

CHRE received project funding from the Foundation for a Smoke-Free World in 2019, 2020, 2021 and 2022 (see below).119120121122

Activities

On the centre’s “Projects” webpage it states that it is “working with local partners in South Asia to build capacity among healthcare professionals in tobacco de-addicton [sic] and national health programmes for TB, cancer prevention and Maternal and Child Health.”134 Other CHRE material states that they have projects in India and Bangladesh.135

The Projects webpage includes a logo for a “Tobacco Research and Cessation Network” (TRC-NET) but there is no further information on CHRE’s website about this network.134 The logo is also included on web pages and materials for CHRE’s summits on cessation and mental health (see below). FSFW’s July 2020 country report on India featured an expert endorsement from Dr. Gaurav Kale, stating that he represented the “Maharashtra Secretariat” of TRC-Net.136 The report was also endorsed by Sudhanshu Patwardhan and Dr. Pooja Patwardhan.136

In 2020, it appeared that CHRE was exploring the feasibility of establishing a network for tobacco research and cessation in India, with funding from FSFW (see below). An article by director Sudhanshu Patwardhan, published in July 2020, states that “ the authors are involved in preparing a systematic training programme for HCPs [Healthcare Professionals] to upskill them using global best practice applied to locally available cessation treatments.”137 It goes on to say that this work will involve the creation of “nationally relevant cessation protocols and guidelines, including those for smokeless tobacco products” (defined elsewhere in the paper as oral tobacco).137 After piloting and validation, the intention is for the programme to be rolled out across India, and shared with neighbouring countries in South Asia.137 The article refers to findings from the authors’ research in India, and they note that this is not yet published.

The planned programme does not appear to be restricted to using standard Nicotine Replacement Therapy (NRT) but mentions the use of other newer nicotine and tobacco products including e-cigarettes (also known as electronic nicotine delivery systems, or ENDS) and nicotine pouches, stating that:

“Regarding alternative nicotine products, manufacturers need to work with policymakers to create and comply with regulatory frameworks that ensure consumer safety and quality assurance and prevent youth uptake. This is particularly true in the case of e-cigarettes and nicotine pouches, both product categories with a promising role in smoking cessation due to their harm reduction potential.”137

A law was passed in India in 2019 banning the manufacture, sale and promotion of e-cigarettes.138

In December 2023 The Times newspaper published an article that described how CHRE helped promote e-cigarettes in the UK.139

See below for details of publications and other outputs.

Funded by the Foundation for a Smoke-Free World

CHRE received project funding from the Foundation for a Smoke-Free World in 2019 and 2020.119120 Information published on the FSFW website, stated that the project aim was the “Development of insights on UK’s remaining smokers and their healthcare advisers’ needs and wants to help achieve smoking cessation; identification of priority interventions needed to achieve maximal and broadest impact of smoking cessation in the UK.”140 (Note that in 2020, the FSFW website stated that the aims were  to “Synthesize and formulate lessons learned from countries with ANDS availability which have seen drastic drops in number of smokers” [ANDS, not defined here: Alternative Nicotine Delivery Systems]; and the “identification of observable smoker characteristics that are linked to cessation success”.141 However, as of 2021 this text appeared in the entry for Ernst and Young.140)

According to the FSFW’s 2020 tax return, CHRE was awarded a total of US$3,449,956 between 2019 and 2021.120121 As of 27 May 2021, there was no information about FSFW funding on the CHRE website. In 2022 CHRE was awarded US$3,584,019 by FSFW, the majority of which was for its work in India (see below).122

In November 2019, CHRE was awarded a grant of US$450,115 (GB£348,570) to fund a “Smoke-free UK landscaping project – reaching the ‘hardcore’ of smokers and supporting quitting”, according to the FSFW’s 2019 tax return.119 The tax return also stated that the aim of the funding was to “Achieve and sustain smokefree at UK’s Priory Group Mental Health Hospitals”.119

The Priory Group is a private healthcare company that provides services to the UK National Health Service (NHS) and was listed as a co-sponsor of CHRE’s 2019 and 2020 mental health summits (see below).142 A Director of Priory Group gave a presentation on smoking cessation and mental health at CHRE’s summit in September 2019.143 Searches of the Priory Group website in May 2020 for mentions of CHRE produced no results until a blog post was published on 31 May, on World No Tobacco Day.144 This stated that “At Priory Group, we have been working with experts from Centre for Health Research and Education (CHRE) to upskill and empower our staff to provide support to patients for quitting smoking successfully.”144 It quoted Dr. Rick Driscoll, Visiting Consultant at Priory Hospital Bristol and Expert Adviser to the CHRE, and said that Priory had been working with CHRE since 2019 “to support all willing smoker patients in their quitting journey”.144

CHRE declared the FSFW grant on an event listing for its 2020 “Smoke-Free Mental Health Summit”.145  The text, in small type at the bottom of the page (see Figure 1), stated that “FSFW has no role in determining the agenda, content or programme of the project including the Summits.” 145 The event was listed as a “report or publication” sponsored by FSFW.146 It was postponed due to the Covid-19 pandemic; as of July 2020, it was not clear whether or when the event


Figure 1: Screenshot of CHRE event web page with reference to the FSFW grant.145


Although it was not clear if he was due to speak at the 2020 summit, Sudhanshu Patwardhan, Medical Director of CHRE, spoke at the 2019 event (see below).

Funded for research in India

In July 2020, information on grants uploaded to the FSFW website showed that CHRE was also awarded a grant in January 2020 for “Evaluating the feasibility and establishment of a multi-center network for tobacco research and cessation in India”. This included scoping work and “Development of a coherent and bold vision” by July 2020.147 The 2021 FSFW tax return indicated that CHRE had been paid US$1,527,783 that year for “Capacity building to reduce tobacco related death and disease in India”.121 and in 2022 CHRE received an additional US$1,196,504 from FSFW to “Build and strengthen tobacco harm reduction and cessation knowledge and capacity in India”, as well as a further US$2,037,044 for the capacity building project.122

Since the grants were awarded, the directors of CHRE have discussed cessation in India in various articles and webcasts (see below for details). The two directors of CHRE are also listed as directors of a private company registered in Pune, India. (see below)

Key staff

CHRE’s website did not have a page listing staff, as of July 2020. According to Companies House, its two directors and sole shareholders are Sudhanshu Ramesh Patwardhan and Pooja Sudhanshu Patwardhan.148149

Sudhanshu Patwardhan is named as Medical Director.131 His role has been described as including responsibility for Policy.150 According to his LinkedIn profile, he worked for British American Tobacco (BAT) for nearly 14 years. From 2005 to 2008, he held scientific roles. From 2008 to 2013, he was responsible for “Corporate and Regulatory Affairs” where he “Strategically led the business to make the first global acquisition by a FTSE 10 company in the electronic cigarettes category, to bring scale and global availability of reduced risk alternatives for smokers who would not or could not quit smoking”.131 BAT’s first e-cigarette acquisition was Vype in 2012. In 2013, he then went on to work in BAT’s newer nicotine products company Nicoventures, on the “global nicotine KOL ecosystem to facilitate smoking cessation and serve public health”131 (The term KOL stands for “Key Opinion Leaders”). During this time, his job title was Senior International Engagement Manager.151152

On a BAT webpage, in connection to its 2008 Sustainability Report, Sudhanshu Patwardhan described his role as BAT’s “interface with the medical and public health communities” and stated that:153

“One of the biggest challenges we face is our limited freedom to finance external research because of restrictions on third parties receiving funds from the tobacco industry. It’s frustrating that, unlike other multinational companies, we are unable to collaborate freely with academic centres of excellence to drive science and innovation. We are actively seeking constructive solutions to overcome this challenge”.153

He left BAT in February 2019.131

Sudhanshu Patwardhan is listed as a mentor for the Tobacco Harm Reduction Scholarship programme run by Knowledge Action Change (KAC), which is also funded by FSFW.119154

He was listed as a speaker at the Global Forum on Nicotine (organised by K-A-C) in 2016,155 and in 2018.156157 He has also attended the tobacco industry event the Global Tobacco and Nicotine Forum (GTNF), previously called the Global Tobacco and Networking Forum.

In September 2020, he was listed as key speaker and co-organiser at an event funded by FSFW called “15 Years of Framework Convention on Tobacco Control”, which ended on 1st October 2020.158 See Events below for further details. Sudhanshu Patwardhan was described as “guest editor” of the associated special edition of journal Drugs and Alcohol Today.159160

Pooja Patwardhan’s role is Clinical Director of CHRE.145 As of June 2020, her LinkedIn profile states that she is a “Medical Doctor: Self-employed” but contains no further information.161 She has been registered as a General Practitioner (GP) with the UK General Medical Council (GMC) since 2011, is licensed to practice in the UK, and is on the GP register (a requirement to be employed as a GP in the UK).162

Sudhanshu Patwardhan has been registered as a (GP) with the GMC since 2013, and is licensed to practice in the UK. As of June 2020 he is not listed on the GP register.163

Sudhanshu Patwardhan and Pooja Patwardhan are named as two of the three directors of a private company registered in Pune, India in August 2019, called the Paarth Centre for Healthy Futures, whose registered address is Utkarsha Hospital in Solapur in the state of Maharashtra.164 The third director is listed as Vikas Vinayak Kirpekar, who is also a director of Utkarsha Hospital Private Ltd.164165

Outputs

Webinars, Podcasts & Radio Interviews

On 29 April 2020, Pooja Patwardhan took part in a podcast on ‘global health perspectives’ hosted by Derek Yach, President of FSFW.166167 The FSFW website states that she has “upskilled and empowered 100s of influencers in UK as well as in India, as part of the mission of creating local champions, to support tobacco users in their quitting journey”.166 It also states that she has been “at the forefront of creating and disseminating “Quit During Covid” message using innovative ways”.166 It is not clear what the term “influencer” here refers to as no further details are given on the website.

In June 2020, around the time of World No Tobacco Day, Pooja Patwardhan was interviewed by several local radio stations in the UK, including two local BBC stations. According to the FSFW website, she talked about quitting tobacco and “national and regional results of the COVID-19 poll”.168 This refers to a poll commissioned by FSFW and conducted by market research company Nielsen, in the UK, Italy, South Africa, India, and the US.169

In August 2020, Sudhanshu Patwardhan was listed as the only guest speaker at a webinar hosted by the Lee Kuan Yew School of Public Policy, Singapore, and chaired by Professor Tikki Pangestu, Visiting Professor at the Lin School of Medicine, National University of Singapore.170 The webinar was titled “FCTC- the policy and practice gap” and aimed to “propose a set of approaches and solutions for realising the public health potential of FCTC”.170 Invitations to the seminar were sent to public health advocates, but by 21 August the event had been cancelled, with no explanation given on the event web page.170 Tikki Pangestu was former Director of Research Policy & Cooperation at the World Health Organization, for over a decade, until he left in 2012.171172 He also took part in a FSFW podcast, in May 2020. 166173

Articles

On 7 April 2020, Pooja Patwardhan (PP) published an article in BJGP Open, the journal of the British College of General Practitioners, discussing the risks for smoking rates rising during the COVID-pandemic.174 According to the author’s disclosure: “PP or CHRE have not received any funding from pharmaceutical, electronic cigarette, or tobacco industries.”174 The article was not peer reviewed.174 In July 2020, this paper was listed as an FSFW sponsored publication.146 A correction to the ‘competing interests’ section of this article was subsequently issued by BJGP Open on 19 January 2021. The correction removed the statement “PP or CHRE have not received any funding from pharmaceutical, electronic cigarette, or tobacco industries”, instead saying “CHRE has received grants from Foundation for a Smoke-free World, Inc (FSFW)… FSFW describes itself as a non-profit, independent organisation which is funded by Philip Morris International Global Services, Inc.” and that “PP did not receive specific funding and it has been written in a personal capacity,”.175 Pooja Patwardhan says that the paper was removed from the FSFW website at the author’s request in August 2020.176 It is no longer listed on the site.177

Sudhanhsu Patwardhan published a related blog article on the Royal Society for Public Health (RSPH) website.178 The conflict of interest statement said that “SP or CHRE do not receive any funding from pharmaceutical, electronic cigarette or tobacco industries.”178 Pooja Patwardhan also contributed a news item on the RSPH website where she talks further about the role of GPs and smoking cessation during the Covid-19 pandemic and the material the CHRE has produced for GPs.179 There is no mention of who funds the CHRE in the article or on the infographics produced.

On 26 May 2020, Pooja Patwardhan published a blog post on the same topic in Nicotine Science and Policy, which is produced by Knowledge Action Change.180181. In the blog, Pooja Patwardhan said:

“As a practising GP and a firm believer in preventive medicine, I have been involved in upskilling GPs and other clinicians on smoking cessation around the world. I have seen that when accurate information reaches them in a practice-friendly way from another clinician, they are very receptive and supportive of helping their patients quit smoking and manage cravings using the harm reduction principle.”181

Nicotine Science and Policy offers readers “daily news, research, comment and policy analysis on nicotine containing products, electronic cigarettes and other novel nicotine delivery systems.”182

A short communication paper written by Sudhanshu Patwardhan and Ira Banerjee was published in the Journal of Addiction Science on 8 May 2020 on “Nicotine Withdrawal, the Role of NRT in Hospitalised Smoker Patients and its Implications for Covid-19”.183 The paper stated that Ira Banerjee was Communications Manager at CHRE, and that neither the authors nor the centre received funding from tobacco companies.

On 4 June a paper about cessation in mental health settings written by Pooja Patwardhan and Richard Driscoll (Visiting Consultant at Bristol Priory Hospital and CHRE) was published on the e-journal website ecancer medical science.184 The conflict of interest statement said that “PP or CHRE have not received any funding from pharmaceutical, electronic cigarette or tobacco industries”. The funding statement said that “CHRE has received a grant for a project in Smokefree Mental Health from The Foundation for Smokefree World”. This paper was listed as an FSFW sponsored publication.146

On 1 July 2020, Pooja Patwardhan published an article with Marewa Glover, on smoking among minority groups including those with mental health conditions.185 This paper was also listed as an FSFW publication and jointly credited to CHRE and COREISS.146
CHRE’s FSFW funding was not disclosed in the article until February 2021, seven months after publication. When the funding was declared an “Expression of Concern” statement was also added by the publisher, emerald insight, “to inform readers that credible concerns have been raised regarding the editorial process for this article”.186 In correspondence with TobaccoTactics, Pooja Patwardhan has said that “This funding statement was omitted by the publishers during the publication process”.187

Glover is the director of COREISS, a private registered company based in New Zealand established with funding from FSFW. For more information see our page on COREISS.

On 17 July 2020 Sudhanshu Patwardhan published a paper with Jed E. Rose on “Overcoming barriers to disseminate effective smoking cessation treatments globally” (see above).137 The conflict of interest statement declared CHRE’s funding from FSFW for “work in smoking cessation” and stated that it did not receive funding from tobacco companies.137 Co-author Jed Rose (President and CEO of the Rose Research Center) declared funding from tobacco companies and Juul Labs.137 For more information see our page on Jed E. Rose. The authors acknowledged the input of FSFW President (at the time), Derek Yach. (Both July papers were to be presented by the authors at the 2020 FCTC-themed online event funded by FSFW.158 See below for more details.)

Before this, in May 2020, an article by Sudhanshu Patwardhan on the cost of nicotine replacement therapy in India was published on The Economic Times healthworld.com website, co-authored by Professor Amir Ullah Khan from the Indian School of Public Policy.188

In July 2021, CHRE published a report on its website titled: “Reclaiming Stolen Years: A survey report on barriers and opportunities to reduce tobacco related harms in the UK among the two million people with mental health conditions who smoke”.189190 It stated that part of this project was supported by a grant from FSFW and was supported by Ogilvy Consulting.189190 (See Ogilvy Group for more on the company and its relationship to the tobacco industry and FSFW)

In May 2022, Sudhanshu Patwardhan and Karl Fagerstrom co-authored a paper on the harm reduction potential of nicotine pouches.191 The authors stated that they had not received any external funding for the article.191 The declaration of interests stated that CHRE had received grants from FSFW for “some of its smoking cessation projects”, that Patwardhan had previously worked for BAT’s Nicoventures, and that he had no financial interest in nicotine pouches. It stated that Fagerstrom set up Niconovum (now owned by Reynolds/BAT) and was in receipt of consulting fees from Swedish Match.191192 (Swedish Match sells nicotine pouches as well as snus. PMI announced its bid to buy the Swedish company in April 2022. See Philip Morris International for details).

Presentations

Prior to the FSFW grant being awarded, Sudhanshu Patwardhan gave a presentation at CHRE’s smoking cessation summit on 30 September 2019, titled “Smoking Cessation and Mental Health What does the future hold for us?”.193 One presentation slide included an image of Nordic Spirit, a snus-type nicotine pouch made by Japan Tobacco International (JTI).193 It is not known if the product was discussed as a cessation tool at the conference. The same slide contained a graphic representing the Voke nicotine inhaler, a product licensed by the British Medicines & Healthcare products Regulatory Agency (MHRA) as a medicine since 2014.194 Until 2017, BAT had a commercial agreement with Kind Consumer Ltd to commercialise this device, but the product was never marketed directly by the tobacco company. In 2017, the licence was handed back to Kind Consumer, which began selling Voke in 2019.  Sudhanshu Patwardhan was working for Nicoventures during the period Voke was licenced to BAT.131

Partnerships

Sudhanshu Patwardhan stated in his 2019 CHRE summit presentation slide that “CHRE is working with technology and healthcare partners to rapidly test and roll out innovation in smoking cessation”. Its partners were not specified.193

His speaker profile at the 2016 GFN stated that he worked with the British Standards Institute (BSI) steering group “to create the world’s first quality and safety specifications for vapour products” and that he was a “Co-convenor at the European CEN working group on definitions and terminology related to vapour products”.155 He was working for BAT during this period.131

Events

In September 2019, CHRE organised a conference on smoking cessation and mental health in partnership with Priory Health Group.195 Its 2020 Smoke Free Mental Health Summit, funded by FSFW, was postponed due to the Covid-19 pandemic.145

On 5 May 2020, Sudhanshu Patwardhan was hosted for a Twitter chat by the pan-African Centre for Harm Reduction Alternatives (CASA).196 Based in Kenya, CASA’s Chair is Joseph Magero, who has received scholarship funding from the FSFW-funded organisation Knowledge Action Change.197

In September 2020, an event called “15 Years of Framework Convention on Tobacco Control”, hosted by the journal Drugs and Alcohol Today, featured Sudhanshu Patwardhan and Pooja Patwardhan as speakers. The event appeared to be jointly presented by Sudhanshu Patwardhan and journal editor Axel Klein.158  The event website stated that “The 15 Years Conference is supported by the Foundation for a Smoke-Free World. The Foundation played no part in determining the planning or execution of the event.”158 For more information see The Foundation for a Smoke-Free World.

Relevant Links

The Centre for Health Research and Education (CHRE) website

TobaccoTactics Resources

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Waterpipe https://tobaccotactics.org/article/waterpipe/ Thu, 28 May 2020 07:57:08 +0000 https://tobaccotactics.org/?post_type=pauple_helpie&p=6281 Background What is waterpipe? Waterpipe has different names in different countries such as narghileh, shisha, hookah, hubble-bubble, or goza. The World Health Organization (WHO) defines waterpipe tobacco smoking (WTS) as “a form of tobacco consumption that utilizes a single or multi-stemmed instrument to smoke flavoured or non-flavoured tobacco, where smoke is designed to pass through […]

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Background

What is waterpipe?

Waterpipe has different names in different countries such as narghileh, shisha, hookah, hubble-bubble, or goza.

The World Health Organization (WHO) defines waterpipe tobacco smoking (WTS) as “a form of tobacco consumption that utilizes a single or multi-stemmed instrument to smoke flavoured or non-flavoured tobacco, where smoke is designed to pass through water or other liquid before reaching the smoker”.198 Some countries have developed their own definition of waterpipe tobacco smoking (WTS).199

The origin of WTS is somewhat unclear. In the late 19th century, it was popular among older men in the Middle East but with the introduction of sweetened and flavoured tobacco in the early 1990’s, waterpipe use surged among youth, and expanded globally, through universities and schools.200201

Social acceptability of waterpipe use has increased, due to the growth of ‘café culture’ in the Middle East and globally, becoming the focus of social gatherings of young people, as a waterpipe can be shared by a group of friends over an extended time, with a slow puff rate. Tourists have taken the waterpipe habit back to their countries, and expatriates from the Middle East have opened waterpipe cafés and restaurants around the world.198201202203In this way waterpipe has spread beyond the Middle East and become integrated into the global tobacco market.204 While there are restrictions on tobacco advertising in other regions, products have been promoted throughout the Middle East via satellite television, internet and social media. As these media are largely unregulated the industry is able to circumvent most advertising bans (see below for more on product regulation).202203198

Transnational tobacco company interests

Historically, transnational tobacco companies had little interest in waterpipe tobacco smoking. A review of tobacco industry documents showed no focus on waterpipe tobacco or its accessories, except for some ‘waterpipe-inspired’ products that did not become mainstream in the market.205

This was the case until  2012, when Japan Tobacco International (JTI) acquired Egyptian company Al Nakhla.206 At the time Al Nakhla was globally the largest company manufacturing waterpipe tobacco products.207 However, even this was perceived as a strategy to enhance the sale of cigarettes.205

In 2019, Philip Morris International (PMI) filed a patent ‘Shisha device for heating a substrate without combustion.’205  However, as of 2023, this product had not yet appeared on the market.

  • See Waterpipe market below for details on companies, brands and market shares

Use

an image of waterpipe device and its components

Image 1: Waterpipe device (Source: Waterpipe Briefing, National Centre for Smoking Cessation and Training/Jawad et al 2013)208209

Waterpipe tobacco is smoked using a device like that in image 1. As the smoker draws from the mouthpiece, a piece of lit charcoal heats the waterpipe tobacco leaf within the head of the apparatus. This heat generates smoke that travels through the device’s body and enters the water-filled bowl. By inhaling through the hose attached to the top of the bowl, the smoker pulls the smoke through the water, resulting in bubbles, before finally inhaling the smoke via the mouthpiece. Typically, the head is filled with flavoured and sweetened, and it is separated from the charcoal by a perforated aluminium foil. While the specific design and characteristics may vary across different regions, the fundamental principle remains consistent: the smoke is filtered through water.202

E-hookahs or e-shisha or hookah pens are not waterpipe devices as they do not involve burning charcoal. These are classified as electronic nicotine devices, similar to e-cigarettes, where a sweetened liquid is electrically heated creating an aerosol to be inhaled.198

The role of flavour

The traditional type of waterpipe tobacco smoking (WTS) uses unflavoured types of leaf (Ajami, Tumbak, or Jurak). However, since the 1990s flavoured tobacco has become more popular.202203198

The most common type is Maasel (or Mo’assel), or ‘honeyed’ tobacco, which consists of one-third tobacco and two-thirds honey and fruit flavours, usually a combination of tobacco, molasses, glycerine and fruit flavours.210. A review looking at waterpipe use in the USA, Canada and the UK has shown that young adults use waterpipe mainly for its appealing flavours, always preferring it over other tobacco products.211  A study among , adults in Lebanon indicated that the introduction of novel tobacco flavours contributed to people initiating WTS and increased its use.212 Similarly, a study from Iran indicated that the wide variety of flavours has as well contributors to the increase in prevalence of smoking among youth and women. The different flavours were considered ‘tempting’.213

Health effects

Evidence shows that waterpipe, like other tobacco and nicotine products, is addictive.214

As with cigarettes and rolling tobacco the smoke of waterpipe is toxic and carcinogenic. One study identified 27 known or suspected carcinogens. 215As a waterpipe is often shared, it is also a mode of transmission for communicable diseases, a particular concern during the COVID-19 pandemic.216 Consequently, waterpipe has both  short-term and long-term harmful health impacts on people who use it, and additional harms for those exposed to second-hand smoke.198217218219

Among many groups of users there is a belief that the smoke of waterpipe is filtered in water, making it less harmful than cigarette smoking. This perception has contributed to a growing popularity and acceptance.202203198 For example research from the UK found that:

“[w]aterpipe was perceived to be safer than cigarette smoking due to the pleasant odour, fruity flavours, and belief that water filtered the toxins.”220

However, waterpipe contains similar or greater levels of toxic substances, leading to the same cellular effects as conventional products, leading to pulmonary and arterial diseases.215221

Prevalence

A 2018 systematic review, which included 129 studies from 68 countries, found that use of waterpipe was highest among adults in the Eastern Mediterranean region (EMR). However, among youth, prevalence was similar in Europe and EMR. Comparing WTS between adults and youth, globally the study reveals that smoking is higher among youth.222

A WHO advisory note about waterpipe, published in 2015, indicated that although waterpipe smoking was traditionally associated with the Eastern Mediterranean region, Southeast Asia and Northern Africa, its use is growing globally among youth and adults of both genders. Use is particularly increasing among schoolchildren and university students. Research reported in the WHO advisory note 203 and a study from Lebanon indicates that the shape, colour and size of the apparatus contributed to the popularity of WTS product mainly among women.223

Africa

Research in South Africa from 2012, shows that 20% of poor high-school students reported using waterpipe daily, and 60% reported ever having used one.224 A study in Western Cape from 2013, reported higher figures: 40% current use, and 70% ever use.225 Even among medical students, use may be relatively high; a study in Pretoria in 2010 found that nearly 20% of participants had used a waterpipe at some time.226

The Americas

Although there is limited research on waterpipe in Latin America, some has been conducted in the United States (US) and Canada. In US a national study of 104,434 university students, published in 2014, shows that after cigarette smoking, waterpipe smoking was the most frequent form of tobacco use (8.4%, compared to 29.7% for cigarettes), and over 30% reported using waterpipe at some time.227 In Canada, although cigarette smoking among young people had significantly decreased, waterpipe use increased by 2.6% among young people between 2006 and 2010.228

Eastern Mediterranean

This region has the highest prevalence of waterpipe use. Studies (1999 – 2008) suggest that waterpipe use was more frequent than cigarette smoking among children aged 13–15 in most countries of the region.229 It also increased in multiple countries, with prevalence ranging from 9% to 15%.230

Europe

Evidence compiled in 2012 showed that, among people aged 15 years or over, 16% had tried waterpipe at least once. Studies suggest waterpipe prevalence ranging from 35-40% in Latvia, Estonia, and Lithuania, but below 10% in Malta, Spain, Portugal, and Ireland. Use was growing sharply in Austria, the Czech Republic and Luxembourg.231 In England, data from 2013 indicated that for people aged 16-18 the level of waterpipe smoking was low, at 3%.232

However, a study looking at adult smoking in England using a nationally representative cross-sectional survey found that since then pipe, cigar or waterpipe smoking increased five times – from around 150, 000in 2013 to over 770, 000 in 2023. Cigars was the most used of the three product types, closely followed by waterpipe, and the increase was higher among young adults.233.

South-East Asia

Studies (2008 – 2011) suggest that waterpipe prevalence among men was just over 1% in Bangladesh, and in India, and much lower in in Indonesia and in Thailand (0.3%). Fewer than 1% of women use waterpipe in India Bangladesh,  Indonesia, and Thailand.234235 However, waterpipe “hookah” bars and restaurants are becoming increasingly common and are most often frequented by young people.

Western Pacific

Waterpipe is called “bong” and is different in design from the popular Middle Eastern waterpipe, and therefore is often not included in waterpipe studies. It can be made of bamboo, metal or glass and is used in China, the Lao People’s Democratic Republic, Myanmar, and Vietnam. In 2010 in Vietnam around 13% of males aged or over 15 used bong.234

Regulation

In many higher income countries, waterpipe products are exempted from tobacco control policies. In many lower income countries, even if there is a policy, enforcement is very weak. Although flavouring is a major factor in the appeal to young people, flavour bans often do not cover waterpipe tobacco products. Consequently, the use of waterpipe has increased globally, largely unchecked.202203198201

The WHO Framework Convention on Tobacco Control (WHO FCTC) identifies tobacco products as “products entirely or partly made of the leaf tobacco as raw material which are manufactured to be used for smoking, sucking, chewing or snuffing”.236 This definition covers waterpipe tobacco products. WHO FCTC issued COP decisions specifically for waterpipe tobacco control:

  • At COP3 in 2008, Parties were invited to consider introducing health warnings and messages on tobacco packages, including waterpipe, and to use innovative measures requiring health warnings and messages to be printed on instruments used for waterpipe smoking.237
  • At COP6 in 2014, Parties were invited to strengthen the implementation of WHO FCTC on waterpipe, including conducting surveillance of its use and research on its market. This decision also invited the Secretariat of the Convention to work with the WHO to support countries in waterpipe control.238
  • At COP7 in 2016, more detailed instructions were given to Parties, including to ban the use of flavourings in waterpipe tobacco products.239
  • At COP8 in 2018, there is a decision on the implementation of Articles 9 and 10 of the WHO FCTC (Regulation of contents and disclosure of tobacco products, including waterpipe, smokeless tobacco and heated tobacco products), including the establishment of an expert group to examine the reasons for low implementation of Articles 9 and 10 of the Convention.240

The full list of articles covering waterpipe are listed in the Fact sheet: Waterpipe tobacco smoking & health.198

In January 2016, the Secretariat of the WHO FCTC signed a Memorandum of Understanding with The American University of Beirut making it the global knowledge hub for WTS, in particular with respect to education, research, and the dissemination of information that contributes to the implementation of the Convention. 241

In 2018, the WTS knowledge hub submitted a report to the WHO FCTC COP8 that summarized Parties’ regulations concerning waterpipe.242 This report was updated in 2022, and found that, of the 90 countries reviewed, over half (47) had policies relating to waterpipe.199 The majority of policies, nearly 45%, were in Europe and around 21% in EMR.199

For up-to-date information on tobacco regulation, see the Tobacco Control Laws website, published by the Campaign for Tobacco Free Kids (CTFK).
Information on progress by parties can be found in the FCTC Implementation database.

During the COVID-19 pandemic in 2020, many countries temporarily banned the use of waterpipe as part of their efforts to stop the spread of the infection.216 In EMR alone, 17 countries banned waterpipe tobacco use in public places.243

Waterpipe, along with heated tobacco products, had been exempted from the EU flavour ban, stipulated by the 2014 European Tobacco Products Directive (TPD) and implemented in 2020. A new directive was issued in 2022 and came into force in 2023. This removed the exemption, bringing regulation of these products in line with cigarettes and hand rolled tobacco.244245 This means that waterpipe tobacco with a “characterising flavour” can no longer be sold legally in the EU. For more information see Menthol Cigarettes: Industry Interference in the EU and UK.

Waterpipe market

According to advocacy group It’s Still Tobacco, the region with the largest global market share of WTS is the Middle East and Africa (MENA), a range estimate for the two years2016-2017 to be 54% to 69% in.246

The WTS market is still concentrated in the Middle East and Africa, followed by  Europe.247 Market analysis company Valuates estimated that as of 2022 the global WTS market was worth over US$ 800 million, forecast to nearly double by 2029.247

Market research company Euromonitor International publishes data on waterpipe, as part of the broader pipe tobacco category. It is therefore hard to estimate global market shares specifically for waterpipe tobacco. However, it is possible to identify specific waterpipe brands in the data. In 2022, JTI held the largest share with Al Nakhla, making up nearly 13% of the entire pipe tobacco market, followed by Al Fakher and Eastern brands (including Moassel) at around 12% and 8% respectively.248

Tobacco industry interference

The waterpipe industry is multidimensional, composed of both tobacco and non-tobacco actors, including third parties. Interference can therefore be less obvious, making it difficult to develop effective WTS policy.249 However, there is some evidence of the tactics used by the industry and its allies.

Tobacco industry tactics used to interfere with and undermine regulation relating to waterpipe include:

Use of third parties

The third-party technique includes creating, funding and empowering allies and front groups.

The public representation of the WT industry primarily revolves around the hospitality sector (waterpipe cafes, bars, and restaurants).246 Products are promoted online by users via social media, rather than WT companies.246  A study from Lebanon indicates that, following the passage of the tobacco control law, enforcement of a ban on indoor smoking came to a halt due to the lobbying of policy makers by establishments where waterpipe was available.250

In 2012, the hospitality sector in Lebanon commissioned Ernst & Young (now EY) to evaluate the effects of the smoke-free law on their financial revenue and impact on employment.246251

Spreading misleading information

Waterpipe companies have published misleading information, including on the risks of tobacco products.

A study of 16 company websites indicated that most (n=12) published misleading marketing information This was mostly prominent among non-MENA companies (n=8) compared to MENA companies’ websites (n=4).   Several companies in Jordan (Al-Rayan, Al-Tawareg, Al-Waha, and Mazaya) were found to have disseminated misleading information on the quality and safety of WTS.246  WTS charcoal companies in particular published misleading information about charcoal being ‘100% natural’ and ‘free of chemicals’.246

Another study looking at marketing materials at a European trade fair,  and from the MENA region, found the prevailing message was that waterpipe is less risky compared to cigarettes.252

Industry science

Al Fakher Tobacco Trading LLC, the second largest WT company, has a ‘shisha science’ section on its website and publishes its own research. A poster of a study published on its page indicates that the paper was presented at the CORESTA Smoke Technology Conference, in 2019. The study argues that a comparisons of Total Particulate Matter (TPM) yields between waterpipe and cigarettes do not provide meaningful information to inform an assessment of relative risk of its products.253

For information on science websites of transnational tobacco companies, see:

Illicit trade

Although cigarettes form most of the illicit tobacco trade, there is some evidence of illicit trade relating to waterpipe, specifically in the Eastern Mediterranean and South-East Asian regions.246198.

Research from Turkey indicates that the majority (up to 99%) of waterpipe tobacco is illicitly traded, reflecting the significance of the informal economy in the waterpipe tobacco market.254 The illicit products are from both unauthorized domestic production, and increasingly tobacco smuggled from other countries, reported to taste better than locally manufactured products.255

OLAF, the European anti-fraud office, has identified suspicious shipments of waterpipe tobacco heading into Europe. In 2022, OLAF detected a truck carrying 20,000 kg of waterpipe tobacco as it was leaving Türkiye on its way to Denmark.256

Tax evasion

There have been some documented cases of the under reporting of imports and exports of waterpipe tobacco, in order to evade tax.

In 2022, New Zealand changed its taxation law related to WTS to base it on product weight rather than the content declared by importers, as the customs authority suspected that some importers had been under-declaring tobacco content in order to avoid paying tax. 257

In 2023, the Mozambique the tax authority seized two containers of waterpipe tobacco, reporting the lack of a proper declaration for taxes and other customs fees.258

Relevant Links

TobaccoTactics Resources

TCRG Research

Waterpipe tobacco smoking (WTS) control policies: global analysis of available legislation and equity considerations,  H. Alaouie, R.S. Krishnamurthy, M. Tleis, L. El Kadi, R.A. Afifi, R. Nakkash, Tobacco Control, 2022, 31(2):187-197. doi: 10.1136/tobaccocontrol-2021-056550

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Greenwashing https://tobaccotactics.org/article/greenwashing/ Tue, 28 Apr 2020 16:23:37 +0000 http://tobaccotactics.wpengine.com/?post_type=pauple_helpie&p=5503 “Greenwashing” refers to the practice used by controversial industries to market their goods and/or image as environmentally friendly in an effort to increase product sales and divert public attention from their own environmentally damaging practices. Reporting environmental impact and funding environmental corporate social responsibility (CSR) projects and organisations, serves to "greenwash" tobacco companies, and detract from the harms the industry inflicts on the environment and environmental health.

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“Greenwashing” refers to the practice used by controversial industries to market their goods and/or image as environmentally friendly259 in an effort to increase product sales and divert public attention from their own environmentally damaging practices.260 Reporting environmental impact and funding environmental corporate social responsibility (CSR) projects and organisations, serves to “greenwash” tobacco companies, and detract from the harms the industry inflicts on the environment and environmental health.

Background

In the summer of 1999, nearly a decade after it was first used by environmental activists, the term “greenwash” entered the Concise Oxford Dictionary, defined as: “disinformation disseminated by an organization so as to present an environmentally responsible public image”.261

The first report on “greenwashing” gave the following examples as illustration: “A leader in ozone destruction takes credit for being a leader in ozone protection. A giant oil company professes to take a ‘precautionary approach’ to global warming…Another giant multinational cuts timber from virgin rainforest, replaces it with monoculture plantations and calls the project ‘sustainable forest development’”.262

In the decades since, greenwashing has been employed by most polluting or controversial industries, including oil, chemicals, and nuclear energy.260 The tobacco industry has historically greenwashed its reputation and products through programmes such as beach clean-ups,263marketing of new products as “eco-friendly”264 and funding environmental and disaster-relief organisations,265 especially in low and middle income countries (LMICs), as the examples below illustrate. As consumers have grown to care more about corporate environmental performance, and choose more sustainable products,266 corporations including the tobacco industry have made environmental sustainability an integral pillar of their corporate social responsibility (CSR)/corporate social investment (CSI) strategies.

  • More information on CSR as a tobacco industry tactic can be found on our page CSR Strategy.

From the early 2000s, the industry started pushing its CSR and greenwashing message. For example, in the introduction to British American Tobacco (BAT)’s “Social Report” in 2002/2003, the company Chairman, Sir Martin Broughton, said “Corporate social responsibility is integral to our approach to the management of our businesses globally”.267268 Critics were quick to point out the dichotomy and hypocrisy of this statement. A report by ASH, Christian Aid and Friends of the Earth argued that “British American Tobacco, while trying hard to convince shareholders and government otherwise, flies the flag for corporate social irresponsibility”. If nothing else, the report argued, BAT’s cigarette’s “kill smokers”.269 Since 2009, BAT has published annual “Sustainability Reports” on its website.270

In an investor presentation in March 2020, BAT executives highlighted the importance of sustainability and sustainable messaging to consumers. The presentation detailed how BAT plans to put sustainability “front and centre”, including the targets of achieving carbon neutrality and 50 million non-combustible consumers by 2030 (Image 1). Sustainability appears to be a key part of BAT’s 2020 rebranding, which saw the company tagline change to “BAT: A Better Tomorrow”, accompanied by a new logo and rainbow-themed website. “Sustainability” also appears as one of the five featured headers on the top menu bar (Image 2).

Three slides from a British American Tobacco corporate presentation emphasising the importance of Sustainbility to its business vision. Top left slide (1) reads "Our ESG Mission: A business where sustainability has always been important, to one where it is front and centre in all that we do". Bottom left slide (2) reads "Big Ambitions for the future: "50 million non-combustibel consumers by 2030; Carbon neutral by 2030". Right (3) reads "Putting sustainability front and centre: (H) Reducing the HEALTH impact of our business; (E) Excellence in ENVIRONMENTAL management; (S) Delivering a positive SOCIAL impact; and (G) Robust corporate GOVERNANCE".
Image 1: Three slides relating to sustainability from British American Tobacco’s March 2020 Capital Markets Day.271
A screenshot of the British American Tobacco website, taken in March 2020. The website is rainbow themed and has new logo. A yellow box emphasises the presence of a "Sustainability" tab in the top menu header.
Image 2: The re-designed British American Tobacco website. Note that “Sustainability” appears in the top menu bar (emphasis added).272

Since the 1950s, when the connection between smoking and negative health effects was first made, tobacco companies have made significant investments in CSR campaigns. They have also used environmental impact disclosure processes and sustainability awards from external bodies to try to create a sense of legitimacy and present their industry as socially and environmentally friendly. However, tobacco companies have maintained the same harmful framing and production practices. Tobacco companies save considerable amounts of money by not having to pay the full cost of the environmental impact of tobacco cultivation, product manufacturing or cleaning up post-consumer waste. The amount of money companies make while using harmful practices involved in their supply chain, such as child labour and deforestation, dwarfs the amount they spend on sustainability CSR projects.273

A 2013 collaborative study between TEEB (The Economics of Ecosystems and Biodiversity) for Business, hosted by the United Nations Environment Programme, and TruCost (the risk assessor arm of S&P Global) found that if major industries were held financially accountable for their currently unaccounted, environmental impacts, they would not be profitable.274275

In addition to avoiding full financial responsibility for the environmental impact of their business, tobacco companies are able to enhance their reputations and minimise harms through existing environmental impact disclosure organisations and practices.

Environmental impact disclosure

Transnational tobacco companies (TTCs) are eager to position themselves as responsible corporations who care about the environmental sustainability of their products. Philip Morris International (PMI) and British American Tobacco (BAT), for example, both state that reducing the environmental impact of their operations is a key part of their visions for corporate sustainability.263276 Company sustainability reports feature awards and recognitions from organisations such as the Carbon Disclosure Project and Alliance for Water Stewardship in places of prominence.263276265277 All of the ‘big four’ TTCs (BAT, PMI, Japan Tobacco International and Imperial Brands) and Altria have been rated “A”, the highest possible rating, across various indices by the Carbon Disclosure Project (CDP), a not-for-profit independent index since 2003, for climate change, water, or forests.273278 Tobacco companies have also been included in the Dow Jones Sustainability Index (DJSI), which ranks top-performing companies across industries by sustainability performance.279

Problem of legitimation

The Carbon Disclosure Project (CDP), and other environmental rankings, featured prominently in the 2018 sustainability reports of each of the ‘big four’ tobacco companies.276263265280 Until it was expelled in September 2017, the tobacco industry also participated in the United Nations Global Compact (UNGC), a voluntary sustainability pact to encourage sustainable business practices and reporting.281 In 2016, for the last UNGC at which the tobacco industry was allowed to participate, Philip Morris International (PMI) authored a brief entitled “Communication on Progress”. The brief, as Image 3 illustrates, minimized the amount of water needed to produce tobacco by comparing it with the amounts necessary to produce tea or chocolate, per weight of finished product.282

An infographic from a Philip Morris International presentation prepared for the 2016 meeting of the UN Global Compact (UNGC) showing water droplets of relative sizes of industry water use between chocolate, tea and tobacco. The tobacco droplet is the smallest.
Image 3: This infographic authored by Philip Morris International emphasises the relative size of chocolate, tea and tobacco industries water use.282

As the World Health Organization (WHO) noted, “PMI’s comparison attempts to put tobacco on par with these other products, ignoring the differentiator that these other products do not kill one in two of their daily users, as tobacco does”.283 The CDP draws a similar conclusion in its reports on corporate environmental disclosure: “industries tend to deemphasise severity of own transgressions and disagree over what constitutes a ‘significant environmental health’ issue.”284

Participation in the CDP, DJSI, and UN Global Compact (UNGP) may lead to companies disclosing more environmental information, but it also supports the legitimisation of the tobacco industry, allowing companies “to be seen more as ‘partners’ in public health and environmental sustainability than their deserved reputation as sullying both”.275 The public and investors may see inclusion on sustainability leader boards as endorsements of companies’ environmental credentials.273

Mandated reporting by governments can limit the opportunity for “trading data for legitimacy”.275 In Brazil and Canada, for example, tobacco companies are required to disclose manufacturing practices, product ingredients, toxic constituents and toxic emissions to national health services. In Brazil, the National Health Surveillance Agency (ANVISA) has the power to impose fines on companies that are not in compliance with tobacco control regulations.285

Problem of voluntary standards

Because environmental impact disclosure is generally voluntary, companies can set their own standards for disclosure. Voluntary disclosure results in environmental impact data that is vague, unclear and inconsistent in its coverage and methodologies.275 This creates several problems.

Firstly, there is no industry-wide standardised format that disclosed data must follow. This makes it difficult for researchers and external evaluators to track progress over time or make comparisons between companies. Though PMI, BAT and JTI all release yearly sustainability reports,263276265 Imperial Brands and the Altria Group only release short summaries on their websites and include minimal information on environmental impact in their annual reports.280286

Secondly, a lack of standards leads to the creation of new units of measurement that can obscure the true scale of environmental impact. By 2018, for example, tobacco companies reported environmental impact data in units known as “intensity”.275 “Intensity” refers to units environmental cost per net revenue (e.g. tonnes of CO2 equivalent emissions per GBP£ million net revenue from smoked and vapour products).280 By reporting environmental costs in this way, tobacco companies are able to obscure year-on-year rise in resource consumption as product volume rises.275 For example, even as the environmental harm per cigarette decreases, the total volume of cigarettes produced rises, and therefore so does the total environmental impact.

Third, companies are free to set environmental goals to whatever level they like and choose to disclose on topics that portray their practices in the best light. In 2017, after BAT-owned leaf suppliers exceeded the company’s global target of 1.5kg chemicals per hectare , BAT announced it “would no longer have a global average target”.287 It now discloses no data on the usage of agrochemicals in its leaf cultivation operations.276 This strategy also applies to external disclosure: BAT, JTI and Imperial Brands have all opted out of CDP Forestry reporting after receiving “F” ratings on disclosure and impact in 2017 (BAT,288 JTI289) and 2019 (Imperial290).

Finally, companies are not required to take responsibility for all environmental impacts associated with the life cycle of their products. Tobacco companies have long placed the responsibility for the disposal of cigarette butts on the shoulders of consumers and local government.291 Through the CDP’s Supply Chain Leadership Collaboration, companies can encourage their suppliers to disclose their environmental impact data to CDP.292 Tobacco companies have participated in this programme since 2007.273 PMI, BAT, JTI and Imperial Brands all appear on the CDP Supplier Engagement Leaderboard,284 a fact which they all promote in their sustainability reports. However, these same companies do not always account for “Scope 3” emissions in their sustainability reporting.293 Scope 3 emissions include “indirect” emissions from independent suppliers in the company’s supply chain, purchased goods and services and capital goods.275 Tobacco companies can thus exclude water used by contracted tobacco suppliers, for example, from their total reported water usages.

Sustainability corporate social responsibility programmes

Tobacco companies implement a variety of environment/sustainability-themed corporate social responsibility (CSR) programmes across the world in order to enhance their corporate image. As with disclosure and sustainability awards, tobacco companies use CSR programmes around sustainability to pre-empt regulation and influence policymakers.294295 The cases below detail where tobacco companies have implemented CSR programmes on this topic and the organisations with which they collaborate in greenwashing efforts.

Global tobacco industry-funded programmes

On both a global and regional level, individual tobacco companies often fund the same organisations. The Eliminating Child Labour in Tobacco Growing (ECLT) Foundation was co-founded in 2000 by British American Tobacco (BAT) and its front group, the International Tobacco Growers’ Association (ITGA), in response to criticism over the incorporation of child labour in its leaf supply chain in Malawi and elsewhere.296 All big four tobacco companies have since joined.297 Until 2019, ECLT had a long-standing partnership contract with the International Labour Organisation (ILO). After pressure from tobacco control organisations, ILO allowed the contract to expire. Both BAT and Imperial Brands are also members of the Slave-Free Alliance (SFA), which is part of a UK-based charity, Hope for Justice.276298 In its 2018 annual report, Imperial Brands stated it was a “founding member” of SFA and that SFA, alongside the ECLT Foundation, received the majority of its charitable contributions.298

Another industry-founded initiative is the Sustainable Tobacco Programme (STP). Launched in April 2016, the STP sought to provide a “single sustainability programme for the tobacco industry”.299 It is managed by independent supply chain consultant AB Sustain, a subsidiary of AB Agri.300

Total LandCare (TLC) is another sustainability NGO popular with tobacco companies. Its mission is “to improve the livelihoods and standards of living of smallholder farm households across the region”.301 Its funders include the Altria Group, PMI, BAT, Japan Tobacco and the ECLT Foundation as well as non-tobacco companies like Coca-Cola. TLC began receiving tobacco industry funding in 2001 from PMI and Philip Morris USA (now a member of the Altria Group).301

From 2001 to 2014, BAT, PMI, Japan Tobacco and Imperial Tobacco spent a combined US$22 million on CSR projects through Total LandCare and ECLT targeting child labour and deforestation. Researchers calculated that this amount was roughly equivalent to 2% of the cost savings these companies derived from deforestation and the use of child labour.273 TLC has since partnered with international non-governmental organisations, including the United Nations Food and Agriculture Organization (FAO) and international development agency USAID, as well as government bodies in southern Africa.301 According to Dr Athena Ramos, public health disparities researcher at the University of Nebraska Medical Center, CSR programmes targeted at child labour “represent more of a public relations strategy than any real meaningful change in practice”.302

These partnerships have at times simultaneously involved the tobacco industry and governments. From 2009 to 2014, for example, Imperial Tobacco (now Imperial Brands) funded a TLC project for the Government of Mozambique.303 Specific examples of the programmes TLC has implemented with tobacco industry funding are detailed below.

Country-level programmes

Transnational tobacco companies (TTCs) also fund specific country- or community-level programmes. Below are examples of CSR programmes implemented by TTCs from countries across the globe, alongside information on in-country tobacco industry activity.

Bangladesh

In 1980, British American Tobacco Bangladesh’s (BATB) launched the afforestation project Bonayan, in collaboration with the Ministry of Forest and Environment, Government of Bangladesh. BATB reported that it had distributed 5 million saplings in 2019.304305 BATB also runs a project, launched in 2009, entitled Probaho, to provide safe drinking water.305 In 2021, BATB expanded the project to the remote areas of Bandarban, launching in the Langi Para area. The Minister for Hill Tracts Bir Bahadur Ushaising MP inaugurated the local 5,000-liter capacity clean water plant, alongside a representative from BATB.306

The company has received awards for this work, including from the Prime Minister of Bangladesh.307308 In 2021, for example,  it received award in the Asia Corporate Excellence and Sustainability Awards,309 and in 2022 another from the Social Enterprise Research Academy.310 BATB has stated that they plan to continue working with the government.311

Bangladesh is the 12th largest tobacco producer in the world,312 due, in part, to BAT’s investments in the 1970s.313 Over 45,000 hectares of land are used for tobacco cultivation in the country.314 Tobacco farmers are being encouraged to continue to expand cultivation, thanks to incentives like loans and buy back guarantees from tobacco companies.312

Tobacco curing uses firewood sourced from local community forests. This leads to widespread deforestation throughout the world. In Bangladesh, an estimated 170,000 individual trees are logged for this purpose each season, in the districts of Bandarban and Cox’s Bazar alone.314 In the district of Kushtia, deforestation has meant that local forests can no longer supply the firewood needed for curing plants. Farmers have to rely on imported straw and jute instead.315 Tobacco cultivation also leads to water contamination due to the use of chemical pesticides and fertilisers, as well as soil contamination and depletion of nutrients. A 2020 study by Hussain et al found that, in Bangladesh, levels of water and soil contamination were higher for bodies of water next to tobacco cultivating land.312

Brazil

Souza Cruz, British American Tobacco (BAT)’s Brazilian subsidiary, has partnered with the National Service of Rural Learning (SENAR) since 1999 to implement the “Growing Up Right” programme intended to minimise the risk of child labour.276 Since 2011, BAT has also been involved with the Brazilian Tobacco Growers Association, the Brazilian Institute of Environment and the Ministry of the Environment for the preservation of forest on the south coast of the country.277

In Brazil, where criticism of the soybean industry for its contribution to deforestation has led to global outcry, tobacco farming ranks alongside soybeans and wheat as one of the leading causes of vegetation loss.316 In the south of the country, British American Tobacco’s biggest operational area in the world, tobacco shares responsibility for the reduction of native forest cover to less than 2% of its original extent.317 During the same period of escalation of industry forestation CSR programmes, the scale of destruction of forests actually increased in LMICs during the same period as escalating CSR promotion, providing an “entrée for the tobacco industry into civil society and CSR, thus avoiding direct responsibility for the environmental consequences of the industry” according to Professor Kelley Lee, widely cited Canadian global health scholar.316

Canada

Unsmoke Canada Cleanups is an initiative which raises awareness of cigarette butt waste and organises litter clean-ups. Launched in September 2020, this grant-giving programme operates through a partnership between the national nonprofit The Great Outdoors Fund318 and Unsmoke Canada, an initiative of Rothmans, Benson & Hedges Inc., a Philip Morris International subsidiary.319320 KAB has attracted criticism for being a corporate greenwashing front group.321

China

In 2020, the China National Tobacco Corporation (CNTC), donated CNY 40 million (US$ 6.3 million) to support the development of a water supply system in the Yonghe County Shanxi Province of China, with a capacity of 5,000 cubic meters of clean water per day.322.

China produces 40% of the world’s tobacco as well as holding nearly one-third of the world’s smokers. As the single largest tobacco producer in the world, the China National Tobacco Corporation produces as many as 2.5 trillion cigarettes per year.323 Tobacco growing and the manufacturing of cigarettes are extremely water-intensive activities.A 2018 study estimated that the water footprint of a single cigarette is around 3.7 litres.324 CNTC could be using as much as 9.25 trillion litres of water for cigarette production.

India

Imperial Brands funds education, sanitation and health through its leaf partnership with Alliance One in the Kurnool district of Andhra Pradesh, including environmental education through PROTECT, a local NGO, and an after-school programme, which Imperial said was intended to “minimize the risk of child labour”.325

Individual interventions on a community level do not address the structural, ecological and financial harms that tobacco cultivation causes to local communities. In India, where tobacco cultivation causes the loss of 45 kg of topsoil per acre cultivated per year, a government report called mono-cropped tobacco “the most erosive crop”, beating out cotton (7.5 kg), grapes (11 kg) and groundnut (12.5) (Reddy & Gupta, 2001).326 Child labour in the tobacco industry has also been documented in Andhra Pradesh as well as across the country.327 According to Dr Ramos, tobacco industry CSR programmes that propose to address child labour “represent more of a public relations strategy than any real meaningful change in practice” and disincentivise external monitoring efforts, especially in LMICs.302

Indonesia

Sampoerna, PMI’s Indonesian subsidiary, operates a wide number of environmentally-focussed CSR programmes under its “Sampoerna untuk Indonesia” scheme. These include a two-year (2018-2020) production sludge waste to fertiliser research project with Insitut Peranian Bogor (IPB) and Indonesian Agricultural Department in East Java (BPTP). A second major programme is the “Hope Project”, which re-purposes factory materials like pallets for its “adult consumer events” and forms a key part of Sampoerna’s marketing strategy. The company stated that: “In 2018, this project successfully recycled 52 tons worth of materials while simultaneously reducing 20% in marketing costs”.328 Sampoerna has won national and international awards for these programmes, such as the Green Company Performance Rating Program from the Ministry of Environment and Forestry in 2022,329, a Global CSR Award and a Global Good Governance Award in 2021.330

Human Rights Watch (HRW) reported that in the course of a 2014-2015 study on child labour in Indonesian tobacco fields, nearly half of all children interviewed reported symptoms consistent with acute nicotine poisoning. HRW concluded that “companies’ human rights due diligence practices were not sufficient to eliminate hazardous child labor in the supply chain” and therefore tobacco companies “risk contributing to the use of, and benefitting from, hazardous child labor”.331 Both BAT and PMI have major operations in this area: PT Bentoel Internasional Investama (Bentoel) and PT Hanjaya Mandala Sampoerna Tbk (Sampoerna), respectively.332

Malawi

From 2001 to at least 2013, Total LandCare (TLC) received millions of dollars of funding from the tobacco industry and ECLT Foundation for forestry,333334 crop diversification335336 and child labour337338 projects in Malawi.

Malawi and Mozambique are “strategic leaf sourcing locations” for Imperial Brands in Africa. In Malawi, Imperial has been piloted many sustainability initiatives across areas including water conservation,298339340 afforestation,341 combatting soil erosion,342 and crop diversification.343

In 2018, PMI signed a Memorandum of Understanding with Palladium, the in-country implementer of USAID’s Feed the Future Malawi Agricultural Diversification project,344 to implement “select initiatives” in Malawi.263 It is unclear whether this partnership includes funding. Palladium is also funded by the Foundation for a Smoke-Free World, a foundation funded solely by PMI. Read more on our page on the Foundation for a Smoke-Free World Grantees.

Tobacco industry harms to the environment and to smallholder farmer communities are well-documented in Malawi. Estimates have placed responsibility for 70% of national deforestation in Malawi on the shoulders of the tobacco industry, making it the main cause of deforestation in the country.345 In 2015, Malawi devoted 5% of its agricultural land to farming tobacco, the highest proportion in the world, but also had the fourth fastest deforestation rate in the world.346 BAT is also being sued by the British legal firm, Leigh Day, for deriving “unjust enrichment” from underpayment and forced/child labour in tobacco farming operations in Malawi. Although BAT and Imperial Brands are named on the lawsuit filed on behalf of tenant farmers in Malawi, this case could protect children and serve as legal precedent to force tobacco supply chain reform, according to Margaret Wurth, a senior researcher at Human Rights Watch.347348

Mexico

Philip Morris International (PMI) runs an initiative in Mexico which involves collecting lighters and other litter to prevent fires. It also helps to promote “smoke-free” messaging and its heated tobacco product, IQOS. Participants collect used lighters and take them to PMI stores and other “strategic points.”349

Mozambique

From 2009 to 2014, TLC was one of a several organisations implementing the government initiative “Promoting Rural Investment in Smallholder Enterprises” (PRISE) in Mozambique. This project was majority funded by Imperial Tobacco (now Imperial Brands).303

Food insecurity has been tied to tobacco cultivation in Mozambique. In 2019, the Global Hunger Index rated the situation in Mozambique as “serious”: 27.9% of the population was undernourished. Tobacco farming takes arable land away from food crops, depletes soil nutrients and contaminates local water supplies, further harming staple crop production. This in turn further diminishes food security and contributes to malnutrition in communities.350351

New Zealand

British American Tobacco New Zealand (BATNZ) provides funding to Keep New Zealand Beautiful for its anti-littering education programmes.276

More than six million cigarette butts are discarded in the environment in New Zealand each year. Researchers have called initiatives that encourage individual-level interventions to address tobacco product waste largely ineffective: “Fundamentally, these ’corporate social responsibility’ initiatives position butt disposal as a smokers’ problem, reinforce negative stereotypes of smokers, and relocating responsibility away from tobacco companies”.352

Portugal

PMI has funded ABAE’s “#Breakthehabit” anti-littering education campaign since 2018 in Portugal.263 PMI is not, however, listed as a partner on the organisation’s website.353 Beach clean-up initiatives sponsored by tobacco industry in the United States, for example, have attracted criticism for contributing to greenwashing.321

Cigarette filters are commonly the most collected item on beach clean-ups. Worldwide, an estimated 4.5 trillion cigarette butts are deposited each year.354 The industry has consistently and disingenuously marketed cigarette filters as “biodegradable”, with the explicit aim of pre-empting environmental legislation.355

Pakistan

In 2021, BAT subsidiary Pakistan Tobacco Company (PTC) donated 500,000 seed balls to the Khyber Pakhtunkhwa Forest Department for the governmental afforestation project “Ten Billion Trees”.356 In 2022, PTC ran a project comprising free distribution of saplings of indigenous species.357 The company received awards for these initiatives, including for Clean Energy Transition, Responsible Investment, Community Impact and Environment –Carbon footprint reduction.358

To produce cigarettes, raw tobacco is cured using wood for fuel. Farmers either obtain this wood from the market, or by cutting down local and indigenous trees. One study observed 4,500 tobacco-curing kilns in just one tobacco-growing village, servicing around 11,000 acres of land under tobacco cultivation. Combined, these kilns burn about 6,300 tons of fuel wood each curing cycle.359 In 2020, around 125,500 acres (50,800 hectares) of land in Pakistan was devoted to tobacco growing.360

For World Cleanup Day 2022, Philip Morris (Pakistan) Limited (PMPKL) launched a litter clean-up project titled #MissionCleanerPakistan, including a litter pick on Clifton Beach, Sea View, Karachi, volunteers collected over 3300 kilograms (3.3 tonnes) of trash for this project.361 PMPKL has won awards for its CSR activities in Pakistan, including in “Employee Volunteerism” and “Waste Management/Recycling”362 and “Green Energy Initiatives”.361363

After the Sri Lankan government publicly announced its intention to ban tobacco cultivation by 2020, Ceylon Tobacco Company (CTC) engaged in spreading misleading information about the contribution of tobacco cultivation to sustainable development, attempted to interfere in the policymaking process, organised a Buddhist ritual against the ban and promoted its SADP programme through media tours.364

Tanzania

The JT Group (JTI parent company) partnered with TLC from 2007 to 2014 to fund the Community Reforestation and Support Program in Tanzania and Malawi.365

Loss of biodiversity due to tobacco cultivation deforestation-driven habitat fragmentation is well-documented in Tanzania. Excessive wood use during tobacco curing and uncontrolled land clearing are important factors leading to deforestation and desertification. The tobacco industry has a history of funding and promoting afforestation programmes in order to distract and refute research that shows the negative effects of tobacco cultivation on forest cover, biodiversity, soil erosion and ground water retention.366

United Kingdom

In January 2021, Philip Morris Limited entered a multi-year agreement with the non-for-profit, Clean Up Britain (CLUB) to “tackle cigarette butt litter”. Within this voluntary agreement, CLUB acts as independent administrator for a PMI-funded project. 367 PMI reportedly paid a “seven-figure sum” to fund the project, which consists in applying “emotional” pressure on smokers caught littering cigarette ends.368 The campaign was launched in January 2022 in Bristol, under the title “Get Your Butt Off Our Streets”, to be later rolled out across Britain.369 An estimated 4.5 trillion cigarette butts are discarded every years in the environment, making them the most littered item on Earth.354 Post-consumer waste, largely in the form of discarded cigarette butts, and its disposal, is however only the last step of life-cycle of a cigarette. Each step of the tobacco supply chain, from agriculture to distribution, contributes substantially to climate change and environmental degradation.

United States 

Altria, Reynolds American International (BAT) and Santa Fe Natural Tobacco Company (BAT) all provide funding for the Cigarette Litter Prevention Programme run by Keep America Beautiful (KAB).370. The Cumberland Plateau Stewardship Fund, of which Altria is a member along with US government departments, has provided a total of US$3.1 million to the National Fish and Wildlife Foundation to fund conservation programmes in the US Cumberland Plateau, which spans parts of eastern Kentucky, Tennessee, Alabama and Georgia, from 2017-2019.371372373 RAI and Altria are also both members of the Supply Chain Resource Cooperative hosted at North Carolina State University (NC State).276286 The Cumberland Plateau is located in key tobacco growing states. A 2013 investigation by Human Rights Watch revealed that, of 133 children interviewed in North Carolina, Kentucky, Tennessee and Virginia, where over 90% of tobacco grown in the US is cultivated, 66% reported symptoms consistent with acute nicotine poisoning. At least eight major cigarette manufacturers, including BAT, PMI, Altria, Imperial Brands, JTI and China National Tobacco Company all sourced tobacco leaf from the US at the time.374

Philippines

In 2019, PMFTC, the Philippine affiliate of PMI, donated 30 waste bins to the Armed forces at camp Servillano Aquino, Tarclac City.Tobacco accounts for 2 million tons of solid waste worldwide, every year.354

Tobacco industry charitable donations

Charitable donations are a key part of tobacco industry CSR strategy Though companies are not always obliged to disclose the amounts and destinations of their charitable donations, both Philip Morris International and the Altria Group publish information on their funding of third-party organisations online.375376

The tobacco industry also commonly donates to disaster relief efforts where they operate, including: Ecuador, Guatemala, Haiti,375 Indonesia,265377375 Italy, Japan, Malaysia,375 Mexico,265375 Mozambique,378 the Philippines,265375 Romania, Senegal and Serbia.375

These lists are not comprehensive. Evidence of funding for sustainability programmes in Australia, Colombia, the Dominican Republic, Ethiopia, Japan, South Africa, South Korea and Ukraine is also given in PMI’s charitable donations disclosure for 2014-2018.375

In the United States, the Altria Group has funded various environmental sustainability organisations. Donations disclosed in 2018 and 2019 appear in the table below.

Table detailing the contributions made to environmental non-governmental organisations (NGOs) by the Altria Group in 2018 and 2019.
Table 1. Altria Group charitable donations to environmental/sustainability organisations in 2018 and 2019.376
*Total giving US$5.6 million in “Environment” category. 
**Amount not disclosed.

Co-option of “sustainability”

In sustainability reports, tobacco companies use “sustainability” as a rhetorical strategy to align themselves with both environmental sustainability and sustainable development. All major TTCs are at least rhetorically supportive of the UN Sustainable Development Goals (SDGs); examples from 2018 and 2019 tobacco company sustainability reports can be seen in Image 4.

Four images show pages from tobacco company reports that include information on how company strategy aligns with United Nations Sustainable Development Goals (UN SDGs). Clockwise from top left: JT Group 2019, Imperial Brands 2019, BAT 2019, PMI 2019.
Image 4: Tobacco companies use sustainability reports to attempt to align themselves with Sustainable Development Goals.263280379380

For example, in the company’s 2016 sustainability report, BAT CEO (at the time) Nicandro Durante said there was a “clear alignment between the SDGs and our own sustainability priorities”.287 However, since 2017, WHO’s Framework Convention on Tobacco Control, which prevents the tobacco industry from having influence on health policy, has been explicitly included in SDG 3 (Human Health) through Target 3A: “Strengthen the implementation of the World Health Organization Framework Convention on Tobacco Control in all countries, as appropriate”.381 Notably, none of these reports mention the incorporation of the WHO FCTC into the SDGs as part of Target 3.

In Highjacking the SDGs? The Private Sector and the Sustainable Development Goals, German tobacco control expert Laura Graen argued that references to the SDGs form “part of a broader, multi-layered strategy with the aim of stopping tobacco control measures such as taxation, advertising bans or plain packaging”.281 An internal Philip Morris International (PMI) document, leaked to Reuters in 2017, revealed that the potential inclusion of additional tobacco control measures in the SDGs were seen by PMI as an “alarming development” because the company feared “that it could lead to the creation of another international body at the UN that would deal specifically with tobacco issues”.382

Tobacco companies take advantage of conflicting goals (e.g. economy and health) within SDGs. In particular, tobacco companies point to SDG 17 (on Public-Private Engagement) to justify and advocate for tobacco industry involvement in government, which is prohibited by Article 5.3 of the FCTC.276263280265 The industry has formed relationships with other government departments after being excluded from health through “sustainable development” partnerships and programmes: BAT Bangladesh has partnered with the Bangladeshi Department for Agricultural Extension to implement sustainability CSR projects.383 The industry uses SDGs to further circumvent regulation and perpetuate its harmful business practices, undermining sustainable development rather than helping it.281

  • For more detail on how the tobacco industry aligns itself with sustainable development in smallholder farmer communities, read our page on Tobacco Farming.

Impact on regulation

On one hand, encouraging companies to disclose more information on the environmental impact of their products (through their life cycle and supply chains) can be seen as increasing transparency and supporting improvement of inefficient and harmful practices. On the other hand, increasing disclosure can also be seen as a form of CSR self-promotion. Academic research on governance suggests that these “proactive moves by the industry to stave off regulation that would require them to adhere to externally wrought environmental standards and practices”.384

Voluntary disclosure and other “ethical and green business” practices have been criticised as CSR and public relations campaigns designed to rehabilitate corporate image and increase product sales without addressing the fundamental changes necessary to core business practices.273385386 An additional challenge is that regulations differ by location. Tobacco companies have also historically taken advantage of differing regulation to avoid bearing the weight of corporate responsibility for their products. This includes avoiding and evading tax as well as environmental regulations.387388

For example, in March 2016, BAT announced it would close a cigarette manufacturing plant in Malaysia due to the government’s implementation of an increased excise tax and consideration of plain packaging.389 However, it had really made plans to open up another manufacturing plant in southern Vietnam, well before the excise taxes or discussions on plain packaging commenced.390

The tactic of moving production facilities has been used by tobacco companies around the world, often when governments have sought to introduce tobacco control regulations. For example, when faced with the prospect of increased taxes and government’ support for tobacco control, Philip Morris International has closed, or threatened to close, manufacturing plants in Argentina.391392 and Colombia.393 BAT used the same tactic in Chile in 2015.394

Industry-funded sustainability programmes pre-empt criticism and make it difficult to advocate for external regulation. When commenting on the efficacy and intent of tobacco industry reforestation schemes, prominent tobacco control researchers Dr Marty Otañez and Dr Stanton Glantz said that industry-funded programmes facilitate an environment where government officials LMICs who lack revenues to fund their own initiatives are hesitant to criticise tobacco industry schemes or refuse funding. Additionally, “association with social and environmental responsibility may weaken opposition from public health and civil society groups to industry interference in tobacco control policy by making it politically more difficult to criticize tobacco companies”.273

The tobacco industry has also moved to distance itself from tobacco cultivation through establishing “leaf partnerships” with third-party companies. Instead of direct contracts with farmers, this has had the effect of transferring responsibility for monitoring and addressing problems from tobacco companies to leaf companies, while continuing to reap the benefits of cheap leaf products and escaping culpability for harmful practices. Especially in LMICs, where there may be less infrastructure to support monitoring and corporate financial contributions may have a greater impact, tobacco companies can use these kinds of initiatives to increase political support and weaken opposition.302

The WHO’s 2017 report on the environmental harms of tobacco says that this practice of evading tax and regulation “epitomizes how, in many instances, when citizens petition for better environmental practices or more socially responsible business conduct, transnational tobacco companies simply uproot their operations and ignore the long-term environmental damage that they have caused, and take them to a new location where they can repeat the environmental damage”.345 When companies relocate away from taxation and regulation, they impoverish already cash-strapped central governments. The current and historical tax evasion and anti-tax lobbying of tobacco companies makes it all the more difficult for LMICs with developing economies to devise and implement effective environmental regulatory regimes.

It its 2017 report, WHO recommended that steps to limit greenwashing include legislating at international and local levels to require companies meet specific disclosure requirements for material emissions, water usage, waste disposal, chemical use, child labour and other targets. It is particularly important that these regulations apply equally across countries; tobacco companies have a history of moving their operations to avoid scrutiny and environmental regulations.345 The evaluation of disclosed data should be performed by independent evaluators, such as government, who do not require or accept payment from companies for this service.275 The WHO also recommends that countries ban tobacco advertising, promotion and sponsorship (TAPS) that include bans on advertising CSR programmes, in accordance with the FCTC.

Researchers and international non-governmental organisations, including the Organisation for Economic Co-operation and Development (OECD) and European Union (EU), have suggested that implementing and strengthening existing Extended Producer Responsibility (EPR) schemes to make producers responsible for the physical and financial costs of disposing of waste of post-consumer products.395396 EPR will be implemented in the EU, with increasing targets for recycling, prevention and use from 2025 to 2035.397 The “Single Use Plastics Directive” will include cellulose acetate products, including cigarette filters, which do not biodegrade.291

Tobacco Tactics Resources

Relevant Links

TCRG Research

References

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