BOTEC Analysis is a research and consultancy firm based in the US, which works on nicotine and tobacco harm reduction, cannabis, drug policy, transportation and community corrections.¹  Its website states that “BOTEC combines the capabilities of a consultancy and a think tank, resulting in service that is nimble and responsive but also grounded in evidence and ethical accountability”.²

BOTEC Analysis has received funding from Philip Morris International (PMI) and the Foundation for a Smoke Free World (FSFW).

People

Samuel Hampsher-Monk has been the Managing Director of BOTEC Analysis since 2017.³⁴ BOTEC Analysis has developed its tobacco harm reduction work since he took on this role.⁵

A list of other current employees can be found on the BOTEC Analysis website.

Relationship with the Tobacco Industry

Funded by the Foundation for a Smoke-Free World

BOTEC Analysis has received funding from the Foundation for a Smoke-Free World (FSFW) since 2019.

In 2019, It received a grant of US$299,767 to “Investigate the drivers of smoking cessation in five countries with alternative nicotine delivery device markets”.⁶

In 2021, it received a further two grants totalling US$401,349 to “Further develop the drivers of smoking cessation in five countries with legalized alternative nicotine delivery systems (ANDS) through a series of additional journal articles, econometric studies, and a full-length book on optimal nicotine regulation” and “Conduct an investigation and analysis and develop recommendations regarding the (i) literature addressing the relationship between COVID-19 and tobacco and nicotine products; (ii) the impact of various tobacco/nicotine related COVID restrictions around the world on smoking and alternative nicotine delivery system (ANDS) use”.⁷

In 2022 BOTEC received its largest grants to date, two grants totalling US$937,023 to “Investigate the drivers for smoking cessation and tobacco harm reduction in five countries with alternative nicotine delivery systems markets” and “Develop journal articles, econometric studies, and a full-length book regarding the drivers of smoking cessation in five countries with legalized alternative nicotine delivery systems”.⁸

PMI IMPACT grant

BOTEC analysis received a grant from PMI through its PMI IMPACT initiative in 2017 to conduct research on the “Impact of e-cigarette regulation on illegal trade in tobacco products in the European Union”.⁹

As part of this project, a paper found that “the more available e-cigarettes become, the less ITTP [illicit trade in tobacco products] market share rises in response to tax-driven price increases for conventional cigarettes”,¹⁰ an argument beneficial to PMI’s business strategy of pushing heated tobacco products, not as an alternative but a supplement to its cigarette business.

For more information see List of Successful PMI IMPACT Applicants.

Other activities

Hampsher-Monk and Jamer Prieger, Senior Researcher at BOTEC Analysis,³ are listed as co-authors of a book due to be published in 2024 titled ‘Clearing the Air on E-Cigarettes and Harm Reduction, Volume I: Tobacco Regulation, Economics, and Public Health’.¹¹ The other co-author is Sudhanshu Patwardhan, Medical Director of the Centre for Health Research and Education (CHRE).

Hampsher-Monk was listed as a speaker at the 2023 ‘New Approaches’ conference, held at the Harvard Club of New York City, in the same week as the United Nations General Assembly.⁵ For more details see Healthy Initiatives (a FSFW grantee).

Relevant Link

• BOTEC Analysis website

TobaccoTactics Pages

• Foundation for a Smoke-Free World
• PMI IMPACT
• List of Successful PMI IMPACT Applicants

References

The post BOTEC Analysis appeared first on TobaccoTactics.

Image source: eltpics/CC BY-NC 2.0

Key Points

• Viet Nam is a country located in South East Asia, part of the World Health Organization’s regional office for the Western Pacific (WPRO).
• It has a population of 98.2 million, with tobacco use prevalence of 24.9%.
• Viet Nam ratified the World Health Organization Framework Convention on Tobacco Control (WHO FCTC) in 2004. It has not joined the Protocol to Eliminate Illicit Trade in Tobacco Products.
• The Vietnam National Tobacco Corporation (Vinataba), a state-owned company, has the largest share of the national cigarette market, at nearly 58% in 2022.
• Of the transnational tobacco companies (TTCs), British American Tobacco (BAT) has by far the largest share of the market in Viet Nam, with Imperial Brands in second place. Philip Morris International (PMI), Japan Tobacco International (JTI) and others have smaller market shares.
• The tobacco industry has deployed a range of tactics to protect its interests in Viet Nam, including lobbying policy makers, use of third parties, complicity in the illicit trade in tobacco products, and spreading misleading information.

Although Viet Nam has made significant progress on tobacco control in recent years, it continues to face major challenges. Tobacco prevalence amongst men remains very high.¹² There is ongoing industry influence on policymaking, particularly on issues such as price and tax of tobacco products.¹³ The state-owned company Vinataba enjoys special privileges from the Vietnamese state, and has long claimed a position as an affected stakeholder on matters of tobacco control.¹⁴¹⁵ There has also been interaction between the transnational tobacco companies (TTCs) and the Vietnamese state, including during the Conference of the Parties (COP) to the WHO FCTC.¹⁶

Tobacco Use in Viet Nam

In 2022, the population of Viet Nam was 98.2 million.¹⁷ According to a WHO age-standardised prevalence estimate, based on all national survey data between 1990 and 2019, overall prevalence of current tobacco use was just over 25%.¹² There is a major gender difference, with current male tobacco use at over 48%, compared to just over 2% for females.¹² Smoking has been an important aspect of social behaviour amongst Vietnamese men for many decades; offering cigarettes is considered to be a show of good manners.¹³

As of 2019, less than 3% of adolescents aged 13 to 17 were current tobacco users (i.e. they had either smoked cigarettes or used waterpipe on at least one day of the 30 days prior to the survey).¹⁸

In the Global Adult Tobacco Survey (GATS) 2015, overall prevalence for traditional bamboo waterpipe was 6.7%. This was higher for people aged between 45-64 (8.9%) and those living in rural areas (8.3%).¹⁹ Smoke from Vietnamese waterpipes tends to have very high nicotine content: the tobacco typically used is Nicotiana rustica, known locally as thuốc lào, which can contain up to 9% nicotine compared to 1-3% in standard tobacco leaves.²⁰

There were an estimated 97,100 deaths attributable to smoking in 2019.²¹ This means that smoking accounted for over 15% of mortality in the country for that year.²¹ In 2011, the last year for which figures are available, the cost of tobacco use to the Vietnamese economy was estimated at nearly US$1.2 billion.²² This was almost 1% of national GDP that year and around US$425 million more than the tax revenue the government received from the industry.²²

A 2022 study suggested that use and awareness of e-cigarettes in Viet Nam is relatively low.²³ However, the Vietnamese market for newer nicotine and tobacco products is expanding. According to market analysis by Statista, in 2022 the e-cigarette market was worth around US$22 million, up from US$7.7 million in 2014, and projected to reach US$24.7 million by 2027.²⁴ Research conducted in June 2020 indicated that e-cigarettes were being sold mainly by speciality retailers and most of the brands available were Chinese imports. Brands popular in Western countries – such as BAT’s Vuse, Imperial Brands’ Blu and JUUL – were rare.²⁵

According to Tobacco Control Laws – an archive of global tobacco control legislation maintained by the Campaign for Tobacco-Free Kids – as of May 2023, there were no restrictions on use; advertising, promotion and sponsorship; or packaging and labelling of e-cigarettes.²⁴²⁶ This lack of regulation, combined with Viet Nam’s relatively large population and high tobacco prevalence, make it an extremely attractive target for transnationals selling e-cigarettes and other newer nicotine and tobacco products.²⁶²⁵

Tobacco in Viet Nam

Market share and leading brands

In 2022, market research company Euromonitor International estimated the Vietnamese tobacco industry to be worth VND₫104,094.9 billion – approximately US$4.4 billion.²⁷ The state-owned Vietnam National Tobacco Corporation (Vinataba) has the largest market share, accounting for nearly 58% of the cigarette market in 2022.²⁸ Vinataba’s range of brands includes Vinataba, Viet Nam’s most popular cigarette.²⁹ Established in 1985, Vinataba has long enjoyed special privileges and recognition from the Vietnamese government.¹⁴ In addition, the government retains the right to appoint Vinataba’s chair and CEO.¹⁵

Transnational tobacco companies (TTCs) producing and distributing tobacco products in Viet Nam are required to establish joint ventures with Vinataba.¹⁵ Amongst the TTCs, British American Tobacco (BAT) has by far the largest market share, accounting for nearly 29% of the cigarette market in 2022.²⁸ BAT has more than doubled its share of the market since 2001, and dominates the mid-range and premium market sectors with brands such as Craven A, White Horse and State Express 555.²⁹³⁰³¹ Imperial Brands has a market share of 7% with one brand, Bastos. Similarly, Philip Morris International (PMI) has a share of 3% with one brand, Marlboro. The remaining companies account for another 3.5% of the market.²⁸²⁹

• For more information on the tobacco industry in Viet Nam, see the Tobacco Supply Chain Database.

Tobacco farming and child labour

From 2000 to 2020, the area of land dedicated to growing tobacco in Viet Nam fell by nearly 49%.³² However, crop yield per hectare has more than doubled, meaning that in 2020 Viet Nam produced over 29,000 tonnes of tobacco leaf – around 200 tonnes more than in 2000.³² Nonetheless, this is a steep drop from 2010, when Viet Nam harvested 56,530 tonnes of tobacco from an area of 31,484 hectares.³²

Viet Nam’s most recent National Child Labour Survey, conducted in 2018, identified more than a million children in a situation of child labour.³³ Of these, more than half were working in the agriculture sector – though the report does not mention tobacco growing specifically.³³ However, Vietnamese tobacco was one of the products identified in 2022 by the U.S. Department of Labor as having been produced by child labour, in violation of international standards.³⁴

• For information on tobacco industry responses to accusations of complicity in child labour, please see the pages on CSR: Child Labour and the Eliminating Child Labour in Tobacco-Growing Foundation (ECLT).

Tobacco and the economy

Viet Nam is a net importer of tobacco leaf. According to UN Comtrade, in 2021, it imported US$242 million in unmanufactured tobacco, compared to just over US$9 million in exports.³⁵³⁶ Comtrade data also states that Viet Nam is a net exporter of cigarettes: US$182 million in 2020, compared to just over US$63,000 in imports.³⁷³⁸

However, these figures differ significantly from customs declarations found on Datamyne, which suggest that Viet Nam is a net importer of cigarettes. According to Datamyne, the value of Vietnamese cigarette imports in 2020 was nearly US$537 million, compared to exports of nearly US$270 million.³⁹ The import and export figures for raw tobacco are also different: according to Datamyne, Viet Nam imported close to US$337 million in raw tobacco in 2021, compared to around US$17.6 million in exports.³⁹

Illicit trade

According to the Vietnamese government, 54.7 million packs of illicit cigarettes were seized between 2013 and 2018.⁴⁰ It estimates that the illicit tobacco trade accounts for 15% of the national market.⁴⁰ This is roughly consistent with research conducted in late 2017 by the Development and Policies Research Center, which concluded that illicit cigarettes accounted for nearly 14% of total cigarette consumption in Viet Nam.⁴¹

By far the most popular illicitly traded cigarettes in Viet Nam are the brands Jet and Hero, which together account for around 85% of the illicit market. Both are manufactured by the Indonesian company Sumatra Tobacco Trading Company and then smuggled to Viet Nam.⁴²¹³ Both Jet and Hero sell for significantly higher prices – between 30% and 60% – than the average legal brand of cigarettes in Viet Nam.¹³

• For more information on the tobacco industry in Viet Nam, please see the Tobacco Supply Chain Database.

Roadmap to Tobacco Control

Viet Nam ratified the World Health Organization Framework Convention on Tobacco Control (WHO FCTC) in 2004.⁴³ However, it has not yet joined the Protocol to Eliminate Illicit Trade in Tobacco Products.

The main tobacco control law in Viet Nam is the Law on Prevention and Control of Tobacco Harm, passed in 2012. It is the country’s first ever comprehensive tobacco control law and a major public health milestone.⁴⁴ It established smokefree spaces; increased the size of graphic health warnings on tobacco products; restricted tobacco advertising, promotion and sponsorship; and set up the Tobacco Control Fund, a sustainable source of funding for tobacco control initiatives paid for by a dedicated tax on tobacco.⁴⁴⁴⁵ More than ten subsequent decisions, decrees and joint circulars have built on this law and further strengthened tobacco control.⁴⁶ This includes the National Strategy on Tobacco Harm Prevention and Control, which set specific targets to reduce tobacco use prevalence from 2013 to 2020.⁴⁷

For more details, please see the following websites:

• Legislation by country – Viet Nam, Tobacco Control Laws, Campaign for Tobacco Free Kids
• Viet Nam, WHO FCTC Implementation Database, WHO FCTC Secretariat
• Country profile – Viet Nam, World Health Organization, WHO report on the global tobacco epidemic 2021

Tobacco Industry Interference in Viet Nam

Tobacco industry tactics used in Viet Nam include lobbying policy makers, use of third parties, complicity in the illicit trade in tobacco products, and spreading misleading information.

Influencing policy

For the Southeast Asia Tobacco Control Alliance (SEATCA), the Vietnamese state’s majority ownership of Vinataba clashes with its duty to regulate the tobacco industry.¹⁵ Vinataba has long claimed a position as an affected stakeholder on tobacco regulation, allowing it a seat at the table in discussions on issues such as taxation and illicit trade.¹⁵

There has also been some exchange of personnel between the government and Vinataba, with high-ranking executives at Vinataba appointed to powerful positions in government – particularly at the Ministry of Industry and Trade (MOIT) – and vice-versa. Several senior officials left government to subsequently assume roles in Vinataba.⁴⁸ Vinataba’s General Director (as of August 2023) was formerly deputy director of the Department of Light Industry, which is controlled by the MOIT.⁴⁹ Vinataba’s Secretary of the Party Committee and Chairman of the Member’s Council is a former vice director of the Industrial Policy and Strategy Institute, a government entity.⁴⁹

Vinataba’s influence is most obvious when it comes to price and tax. Cigarettes in Viet Nam are among the cheapest in the world: as of 2020, the price of a 20-pack – even of a premium brand – was less than one U.S. dollar.¹² In 2021, taxes accounted for under 39% of the retail price of the most popular brand of cigarettes – well short of the 75% recommended by the WHO.¹² Research by the World Bank has concluded that Viet Nam’s tobacco taxation policies have made cigarettes more affordable. Per capita income in Viet Nam has risen considerably in recent decades, outpacing the increase in the price of cigarettes, and increases in tobacco taxes have not been sufficient to close the gap.¹³

In 2017, the Ministry of Finance proposed switching to a mixed excise tax system, with a flat rate of VND₫1,000 – around four U.S. cents – imposed on top of the usual ad valorem tax on the factory price of tobacco products.¹³ This would have made little difference to the affordability of cigarettes; health officials had argued for increase of between VND₫2,000 and VND₫5,000.¹³ Vinataba, along with the Vietnam Tobacco Association, opposed the move, claiming it would lead to difficulties in tobacco production and business operations and increase the risk of smuggling.¹³ At the time of writing, Viet Nam had yet to introduce the mixed tax regime.⁵⁰

The industry has also lobbied for the diversion of funding away from the Tobacco Control Fund – which is supposed to be used for public health purposes – and towards combatting illicit trade. Vinataba has made requests of this nature to various ministries and local governments.¹⁵ In 2017, the International Union Against Tuberculosis and Lung Disease (The Union) sent a letter to the U.S. Ambassador in Viet Nam, urging him to reconsider the Embassy’s facilitation of meetings between Philip Morris International (PMI) and Vietnamese government ministers, on the grounds that PMI would attempt to raise fears over illicit trade and seek diversion of funds away from the Tobacco Control Fund and towards anti-smuggling measures.⁵¹ SEATCA reported the same year that the MOIT had endorsed a recommendation from the tobacco industry to divert half of the Tobacco Control Fund towards enforcement activities against illicit trade.⁵²

The tobacco industry has also interacted with the Vietnamese delegation to the Conference of the Parties to the WHO FCTC.¹⁶ During COP6, held in Moscow in October 2014, PMI executives met with the Vietnamese delegation. Analysis of the delegation’s interventions by tobacco control groups observing the COP showed that they frequently mirrored positions held by PMI.¹⁶ For example, they argued that higher tobacco taxes would fuel the illicit trade and that the FCTC should be excluded from trade disputes, as well as opposing uniform parameters on legal liability for tobacco companies.¹⁶ Likewise, at COP7, held in Delhi in November 2016, PMI held meetings with members of the Vietnamese delegation away from the conference venue.¹⁶

Use of third parties

In June 2020 the R Street Institute, an American public policy thinktank, sent a letter to the Vietnamese prime minister and deputy prime minister urging them “to consider pragmatic regulations that allow Vietnamese citizens broad access to reduced-risk products.”⁵³ It also argued that inserts in cigarette packets should be permitted in order to market such products to current smokers; that it should be possible to place “relative-risk labels” on these products; and that maximum nicotine levels should be high enough “to achieve nicotine delivery similar to combustible cigarettes”.⁵³

Endorsing the use of e-cigarettes and heated tobacco products (HTPs) as cessation tools, the letter refers specifically to IQOS – PMI’s flagship HTP brand (though PMI has also sold e-cigarettes under the IQOS brand).⁵³ From 2014 until at least 2022, R Street received funding from Altria – the primary asset of which is Philip Morris USA, the largest tobacco company in the United States.^5455565758

In the same month, Factasia also sent a similar letter to the Vietnamese prime minister.⁴⁹ Factasia describes itself as “an independent, not-for-profit, consumer-oriented advocate for rational debate about – and sensible regulation of – the rights of adult citizens throughout the Asia-Pacific region to choose to use tobacco or other nicotine related products.”⁵⁹ It acknowledges receiving funding from PMI, as well as the Tobacco Vapor Electronic Cigarette Association (TVECA), an e-cigarette trade association. However, it denies acting as a mouthpiece for the tobacco industry.⁶⁰

Complicity in smuggling

There is evidence that the tobacco industry has smuggled its own products into Viet Nam. Internal British American Tobacco (BAT) documents from the 1990s show how BAT and its subsidiary smuggled State Express 555 (SE555) cigarettes manufactured in the UK into Viet Nam.⁶¹⁶²

BAT had been attempting to establish a presence in Viet Nam since the late 1980s, though with considerable difficulty. Negotiations on the terms of a joint venture with Vinataba were extremely slow, while a ban on foreign imports in 1990 meant that BAT would either have to license a Vietnamese company to manufacture its products locally or purchase equity in a local factory.³⁰

Smuggling facilitated BAT’s entry into the Vietnamese market in two ways.³⁰ Firstly, by circumventing the import ban, BAT managed to create brand awareness amongst Vietnamese smokers and obtain a competitive advantage prior to any opening of the market.³⁰ Secondly, by highlighting loss of tax revenue due to illicit trade, BAT was able to use smuggling as leverage in its negotiations with Vinataba.³⁰ An internal BAT document from 1993 states “We have the high ground [in negotiations with Vinataba] given the excellent quality of distribution, presence, and value of the GT [i.e. smuggled] product.”⁶³

The same BAT document states that “Both versions [i.e. licit and illicit cigarettes] will have a role to play in the further building of the brand and the ‘system’ profitability”.⁶³⁶⁴ Indeed, BAT continued to smuggle its own products into Viet Nam even after signing an agreement in 1994 which licensed Vinataba to manufacture SE555 locally.³⁰ BAT carefully controlled the price of both the licit and illicit SE555, with the smuggled cigarettes fetching higher prices because they were perceived to be of higher quality.⁶¹ BAT finally signed a US$40 million joint venture with Vinataba in 2001, for construction of a brand new leaf-processing plant in Dong Nai province.³⁰⁶⁵ This was followed by a further agreement in 2006, under which 150 million packs per annum of Pall Mall and Viceroy would be manufactured for the domestic market, as well as another 50 million packs per annum for export.³⁰ Even then, illicit BAT products did not disappear from the Vietnamese market. As recently as 2017, illicit SE555 were still selling at 169% of the value of the licit version.⁴¹

Spreading misleading information

Most existing estimates of the illicit tobacco trade in Viet Nam are based on industry data and rely on methods which are opaque, undisclosed or difficult to replicate over time.¹³ While the government estimated in 2020 that illicit trade accounted for 15% of the national market, and independent research from 2017 put that figure at 13.72%, tobacco industry estimates are significantly higher.⁴⁰⁴¹ Japan Tobacco International Vietnam, for example, states that “the rate of smuggled cigarettes is quite high (more than 20%) on the market”.⁶⁶

Oxford Economics (OE) put the share of total illicit consumption at 23.4% in 2017.¹³ An economic advisory agency with links to the tobacco industry going back to the early 2010s, OE produced yearly reports on the illicit trade in Asia between 2012 and 2017 which were funded by PMI and based on PMI-approved terms of reference.^676869707172

These reports have been criticised in the strongest terms by Dr Hana Ross of the University of Cape Town, writing for the Southeast Asia Tobacco Control Alliance (SEATCA):

“The common denominator to all pieces of this study is PMI and its TORs [terms of reference] with all of the multiple parties in the report’s chain of production. This is a way for PMI to control the final results—by controlling the input, the data analysis, as well as publication, distribution, and promotion.”⁷³

This exaggeration of the scale of illicit trade is a well-documented means of fighting tobacco control measures such as graphic health warnings, plain packaging and increased tobacco taxes. However, there is no evidence to show that tax increases have led to an increase in the illicit trade in Viet Nam; on the contrary, the illicit trade declined even after a 5% increase in the ad valorem tax rate in January 2016.⁴¹

• For more information see Illicit Tobacco Trade

Relevant Links

• Global Adult Tobacco Survey (GATS) Viet Nam 2015, GATS Viet Nam Working Group
• Vietnam 2023 Tobacco Industry Interference Index, Global Center for Good Governance in Tobacco Control
• Vietnam 2021 Tobacco Industry Interference Index, Global Center for Good Governance in Tobacco Control
• Asian State-Owned Tobacco Enterprises: Challenges & Opportunities in Implementing WHO FCTC Article 5.3, Southeast Asia Tobacco Control Alliance (SEATCA)
• Vietnam: Overview of tobacco control legislation, use and taxation, World Bank Group
• Evidence Matrix: Vietnam, Tobacconomics
• Inside Philip Morris’ campaign to subvert the global anti-smoking treaty, A. Kalra, P. Bansal, D. Wilson, T. Lasseter, The Philip Morris Files, Reuters

Tobacco Tactics Resources

• Western Pacific Region
• Waterpipe
• Price and Tax
• Tobacco Smuggling
• Oxford Economics
• R Street Institute
• Factasia

TCRG Research

• Developing more detailed taxonomies of tobacco industry political activity in low-income and middle-income countries: qualitative evidence from eight countries, B.K. Matthes, K. Lauber, M. Zatoński, L. Robertson, A.B. Gilmore, BMJ Global Health 2021;6:e004096.
• Gaining access to Vietnam’s cigarette market: British American Tobacco’s strategy to enter ‘a huge market which will become enormous’, K. Lee, H.V. Kinh, R. Mackenzie, A.B. Gilmore, N.T. Minh & J. Collin, 2008, In: Global Public Health. 3, 1, p. 1-25.

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

References

The post Viet Nam Country Profile appeared first on TobaccoTactics.

The Business Association of Georgia (BAG) was established in 2009, with a stated mission of improving the business environment in Georgia by “uniting the members, in close cooperation with the authorities, international and local partners”.⁷⁴

As of 2022, members of BAG include around 100 holding companies, that represent over 600 businesses of varying sizes.⁷⁴

Relationship with the tobacco industry

Membership

Philip Morris Georgia, a subsidy of Philip Morris International (PMI), became a member of BAG in 2017.⁷⁵

Japan Tobacco International (JTI) became a member in 2021.⁷⁵⁷⁶

COVID-19 donation

In 2020, Philip Morris Georgia made a donation of GEL 100,000 (UK£35,500) to a COVID-19 support fund established by BAG.⁷⁷

• See the COVID-19 page for information on tobacco industry corporate social responsibility and targeted donations during the COVID-19 pandemic.

Activities

Lobbying to oppose regulations on heated tobacco products

A ban on tobacco advertising, promotion and sponsorship was introduced in Georgia in May 2018, and an outdoor display ban in September 2018.⁷⁸

In September 2018, BAG submitted a legislative proposal to the Healthcare Committee of the Parliament requesting that heated tobacco products (HTPs) and other newer nicotine and tobacco products be subject to fewer regulations than conventional tobacco products.⁷⁹⁸⁰ BAG also submitted the proposal to the Office of Business Ombudsman of Georgia.⁸⁰⁷⁸ The Ombudsman’s office, which reportedly often has meetings and consultations with tobacco industry representatives,⁷⁸ subsequently wrote a letter to Parliament supporting the proposal.⁸¹ However, the proposal was ultimately dismissed by Parliament.⁷⁸⁷⁹

In January 2020, BAG submitted another legislative proposal requesting fewer regulations for HTPs.⁷⁸⁸²⁸³ During this time, BAG also published media reports which cited PMI’s HTP IQOS, as the reason for the request being made.⁸⁴

The proposal stated:

“The essence of our proposal is that new tobacco products and heating tobacco, devices and accessories intended for their consumption should not be subject to the prohibitions provided by the current legislation relating to Internet and/or mail order retailing, direct personal communications, and informational materials”[translation].⁸⁵

The proposal was again dismissed by Parliament in February 2020.⁷⁸

In July 2020, when the U.S. Food and Drug Administration (FDA) authorised the marketing of IQOS,⁸⁶ Legal Director of BAG, Nika Nanuashvili,⁸⁷ criticised the Parliament of Georgia’s decisions not to accept BAG’s previous legislative proposals.⁸⁸

In 2021, Nanuashvili contributed to a media report in which he echoed previous statements around product regulation. He also commented that smuggling rates of traditional tobacco products are high, citing the high cost of tobacco as the cause.⁸⁹

Plain packaging

Georgia mandated a law to introduce plain packaging to tobacco products, including HTPs, in May 2017. However, its implementation has been postponed on several occasions,⁹⁰ with regulations now due to enter into force in 2024.⁹¹

In 2021 BAG submitted another legislative proposal regarding regulations for newer products.⁹² Adding to previous submissions, this proposal argued against the introduction of plain packaging for HTPs. It also recommended that, for all tobacco products, new packaging regulations be postponed to 2025, and stated “Standardized packaging has failed in all markets where it has been implemented and failed to achieve its intended goals”[translation].⁹³

The proposal also stated:

“since 2017, the reform of the legislation regulating tobacco products began in the country, and on this painful path, the most difficult, radical regulations were selected… Georgia’s legislation, which is significantly stricter than EU countries, especially in terms of marketing and standardized packaging, will inevitably lead to further narrowing of organized businesses in the relevant market and indirect encouragement of illegal imports”[translation].⁹³

However, the proposal was again refused by Parliament.⁹⁴

After rejection of the proposal, Nanuashvili stated in a media report that plain packaging would have a negative impact on the sale of lesser-known brands and argued that plain packaging could result in an increase in illicit trade.⁹⁵

See also Industry Arguments Against Plain Packaging

Relevant Link

• Business Association of Georgia website

TobaccoTactics Resources

• Third party technique
• A list of pages in the Georgia category

References

The post Business Association of Georgia appeared first on TobaccoTactics.

The Influence Foundation was founded in New York in 2017. Its stated aim is “to advocate through journalism for rational and compassionate approaches to drug use, drug policy and human rights”.⁷⁴ It is part-funded by tobacco companies and related third parties.

The Influence Foundation owns and operates Filter magazine, which has published multiple articles criticising tobacco control policies¹⁰⁰¹⁰¹ and arguing against regulations relating to newer nicotine and tobacco products.¹⁰²¹⁰³

Links to the Tobacco Industry

Direct funding from tobacco companies

The Influence Foundation receives funding from tobacco companies including Philip Morris International, Altria, and British American Tobacco subsidiary Reynolds American Inc, as well as from the e-cigarette company JUUL Labs, which was part-owned by Altria between 2018 and 2023.¹⁰⁴

Supported by the Foundation for a Smoke-Free World

It is also a grantee of the Foundation for a Smoke-Free World (FSFW). In 2020, FSFW awarded the Influence Foundation a grant to “expand Filter’s capacity to produce, publish, and promote informative and evidence-based THR [tobacco harm reduction] information and articles with higher volume, quality, and reach”,¹⁰⁵ and in 2022, awarded another with the aim of “Enhancing Filter’s Capacity to Communicate About Tobacco Harm Reduction (THR)”.¹⁰⁶

In July and August 2023, Filter magazine published articles ahead of the 10th Conference of the Parties (COP 10) to the World Health Organization Framework Convention on Tobacco Control (WHO FCTC).  Written by the pro-tobacco blogger and International Fellow at the Taxpayers’ Protection Alliance (TPA), Martin Cullip, they criticised the WHO and its supposed “assault on tobacco harm reduction”. ¹⁰⁷¹⁰⁸ Around the COP 10 meeting in early 2024, Filter published further articles by Lindsey Stroud of the TPA.^109110111 The TPA provided funding to the Influence Foundation “to support travel to Good COP”, a parallel meeting run by the TPA during COP 10.¹¹² For more information see Interference around COP 10 & MOP 3.

FSFW also awarded a grant to the Influence Foundation’s past fiscal sponsor, Law Enforcement Action Partnership (LEAP), to “share stories that present facts about tobacco harm reduction and nicotine” through Filter magazine.¹¹³ LEAP also accepts funding from tobacco companies.¹¹⁴¹¹⁵

The Influence Foundation has received funding from industry third parties, including Knowledge-Action-Change (funded by FSFW) and R-Street Institute (part-funded by Altria).¹⁰⁴

Board Members

Board members include:

• Will Godfrey, President and Executive Director of the Influence Foundation, and editor-in-chief of Filter.⁷⁴ He is a regular attendee and speaker at the Global Forum on Nicotine,¹¹⁶ an annual conference organised by Knowledge-Action-Change, which each year features tobacco industry speakers and panellists.
• Lt. Diane Goldstein (Ret.), the executive director of the Law Enforcement Action Partnership (LEAP), which has received funding from tobacco companies.¹¹⁴¹¹⁵

TobaccoTactics Resources

• Foundation for a Smoke-Free World Grantees
• Global Forum on Nicotine
• Martin Cullip

References

The post The Influence Foundation appeared first on TobaccoTactics.

• In 2012, the Institute of Medicine (IOM) published guidance for assessing tobacco and nicotine products proposed by manufacturers as less harmful alternatives to conventional cigarettes.
• Transnational tobacco companies have developed similar multi-stage approaches to scientifically assess these newer products.
• There is evidence to suggest the industry’s approach does not guarantee good quality research or prevent the industry from using strategies to influence science.
• The Framework Convention on Tobacco Control calls for regulatory decisions on tobacco products and the scientific assessment of tobacco products to be made independent of the tobacco industry

Background

In 2003 and 2004, the World Health Organization’s Scientific Advisory Committee on Tobacco Product Regulation (SACTob) and Study Group on Tobacco Product Regulation (TobReg) issued principles and guidance on the type of evidence required to scientifically assess newer tobacco and nicotine products that were purportedly less harmful than cigarettes.¹²¹¹²² Both emphasised the need for a range of study types and independent verification of industry studies. In 2012, the US Institute of Medicine (IOM, now The National Academy of Medicine), an independent, evidence-based advisor on scientific, medical and health-related matters,¹²³ outlined the types of studies and appropriate designs, which would be necessary to demonstrate whether newer nicotine and tobacco products could reduce the harms associated with smoking. The IOM grouped the evidence required into three categories: health effects, addictive potential, and perceptions of the newer product.¹²⁴

In 2015, the Tobacco Product Assessment Consortium (TobPRAC – an independent body funded by the US National Cancer Institute)¹²⁵ reviewed the WHO’s and IOM’s recommendations for scientific evaluation of purportedly less harmful tobacco products.¹²⁶ In 2011, the consortium had developed a four-staged framework for scientifically evaluating newer tobacco and nicotine products, particularly those claimed by manufacturers to be less harmful.¹²⁷ The four stages proposed were: pre-market evaluation, pre-claims evaluation, post-market activities, and monitoring and re-evaluation (see image 1).¹²⁶¹²⁷

Image 1. Overview of the conceptual framework proposed by the Tobacco Product Assessment Consortium (TobPRAC) to assess newer products.(Source: Shields et al/TobPRAC, 2011, p. 47; Berman, et al, 2015)¹²⁶¹²⁷

Designed to inform tobacco product regulators worldwide, the framework was not based on any particular regulatory structure and, according to the TobPRAC, is therefore applicable to any jurisdiction. In line with Article 5.3 of the World Health Organization Framework Convention on Tobacco Control (WHO FCTC), TobPRAC noted that regulatory decisions on the necessary criteria for scientifically assessing tobacco products should be made independent of the tobacco industry. As the tobacco industry would inevitably fund and conduct its own scientific research on its products, TobPRAC also emphasised the need for accompanying independent research and governance to effectively implement the framework.¹²⁶

The ‘big 4’ transnational tobacco companies¹²⁸ have since developed approaches to scientifically evaluate newer products which align with the recommendations of the WHO, IOM and TobPRAC. These companies publicise their scientific approaches and research via dedicated science websites (see External Links below).

Below is an outline of the approaches each transnational tobacco company states that it takes to scientifically assess its newer products. An overview is also provided showing the quantity of publications across each stage of each company’s scientific assessment approach. In the final section, some criticisms of the industry’s scientific approaches are summarised.

Philip Morris International

Image 2. PMI’s approach to scientifically assessing newer products.(Source: PMI Science website)¹²⁹

Philip Morris International’s (PMI) scientific assessment approach has five stages (see image 2).¹²⁹ The first stage, “product development”, comprises design and aerosol testing of potential newer products. The aerosol analyses aim to determine the physical and chemical properties of product emissions, which indicate the potential risks of the product.

Next, in vitro and in vivo “toxicological assessments” are used to measure the impact of the product emissions on cells and animals.

If this stage indicates that the product has reduced risk potential, the health effects of the products are tested in human users under controlled conditions (“clinical assessment”).

Following this, “perception and behavior” studies investigate consumer’s perceptions of the product, as well as user behaviours and levels of satisfaction.

Finally, in its “long-term assessment”, PMI states it will continue to monitor the biological effects and consumer acceptance of the product via safety surveillance, clinical studies, and epidemiological studies.¹²⁹

PMI catalogues its scientific publications in a library on the PMI Science website.¹³⁰ Publications held in this online library include: journal articles, presentations, posters, books, clinical trial registrations, posters, dossiers, reports, data, and methods and protocol documents. Up until May 2022, PMI assigned each publication in its library a tag relating to the relevant stage of its assessment approach. In addition to the five stages described above, two additional tags were used in PMI’s library: ‘Plant Biology’ and ‘Overview’. The number of publications assigned each tag (as of May 2022)¹³¹ is shown in Figure 1.

Figure 1. Number of publications tagged with each assessment stage in the PMI Science library as of May 2022. N.B. a single publication can have multiple tags.

British American Tobacco

Image 3. BAT’s approach to scientifically assessing newer products.(Source: BAT Science website)¹³²

British American Tobacco’s (BAT) scientific assessment approach consists of four stages (see image 3),¹³² fewer than the other transnationals. The preliminary “emissions” stage consists of studies which investigate whether the newer product functions correctly and whether combustion occurs (combustion studies), the chemical properties of the product emissions (emission studies), and then the effects of the product in vitro (toxicological studies).

Next, the product’s effects in human users are investigated. BAT states that “exposure”-related outcomes are assessed via clinical studies which analyse the behaviours exhibited by users (use behaviour), the short-term pharmacological effects of the nicotine in users (clinical: PK), and the levels of biomarkers of potentially harmful chemicals in users (clinical: exposure). “Risk” is assessed via medium-term clinical trials measuring the levels of biomarkers linked to harm and disease (clinical: individual risk), post marketing surveillance surveys to monitor the use of the product by consumers (population risk: PMS), and epidemiological modelling simulating potential impacts of the product on public health.

Finally, BAT states that it will use “long-term epidemiological data” to determine how the product is being used, as well as impacts on disease prevalence and public health.¹³²

BAT catalogues its scientific publications in a library on the BAT Science website.¹³³ Publications held in this online library include: abstracts, method documents, posters, presentations, journal articles, and ‘other’ publications.

Unlike the other transnationals, BAT does not categorise or tag the publications in this library by assessment stage.

Japan Tobacco International

Image 4. JTI’s approach to scientifically assessing newer products. (Source: JTI Science website)¹³⁴

Japan Tobacco International’s (JTI) scientific assessment approach consists of 6 stages (see image 4),¹³⁴ the highest number of the four companies. JTI start with testing the design of its prototype products (“product design”) and the chemical properties of the product’s emissions (“aerosol chemistry”).

Next, in vitro and in vivo “toxicological assessments”, as well as in silico simulation studies, are used to assess the toxicity of the product.

“Clinical studies” will then investigate the effects of the product on human users, including risk reduction and pharmacokinetic studies.

The users experience, including satisfaction and patterns of use, are assessed through “perception and behavior” studies.

JTI state that it completes its assessment by monitoring the long-term effects of the newer product (“long-term assessment”).¹³⁴

JTI catalogues its scientific publications in a library on the JTI Science website.¹³⁵ Publications held in this online library include: journal articles, reports, posters, presentations, booklets, press releases, leaflets and news items. JTI assigns each publication in its library a tag relating to the relevant stage of its assessment approach. In addition to the six stages described above, two additional tags were used in JTI’s library: ‘Indoor Air Quality’ and ‘Other’. The number of publications (as of January 2023)¹³⁶ assigned each tag is shown in Figure 2.

Figure 2. Number of publications tagged with each assessment stage in the JTI Science library as of January 2023. N.B. a single publication can have multiple tags.

Imperial Brands

Image 5. Imperial Brand’s approach to scientifically assessing newer products.(Source: Imperial Brands Science website)¹³⁷

Imperial Brands’ scientific assessment approach consists of 6 stages (see image 5).¹³⁷ It begins with assessing the product’s design and emissions via chemical analyses and preliminary toxicological studies (“product characterisation science”).

Once this has been completed, Imperial Brands moves onto further “biological science”, including in vitro assessments to test the product’s toxicity to human cells.

Then, clinical studies are used to confirm that the reduced risk potential observed in the laboratory-based studies are also observed in actual human users of newer products (“clinical science”).

The “behavioural science” stage comprise studies to investigate the use, perceptions and addictiveness of newer products, both pre- and post-commercialisation.

In the next stage, “computational science”, comprise mathematical and computational modelling to estimate population-level use and health impacts.

Finally, Imperial Brands states that it conducts post-market studies measuring product use, user attitudes, adverse events, health-related outcomes and sales data (“population health science”).¹³⁷

Imperial Brands catalogues its scientific publications in a library on the Imperial Brands Science website.¹³⁸ Publications held in this online library include: journal articles, infographics, posters, presentations and videos. Rather than using tags that describe each stage of its assessment approach, Imperial Brands assigns each publication in its library one or more of the following tags: ‘pre-clinical’, ‘clinical’ and ‘post-market’. The number of publications assigned each tag (as of January 2023)¹³⁹ is shown in Figure 3.

Figure 3. Number of publications tagged with each assessment stage in the Imperial Brands Science library as of January 2023. N.B. a single publication can have multiple tags.

Criticisms of the Industry’s Approaches

The tactics the tobacco industry uses to influence scientific research in order to further its economic interests are well documented.^140141142

• For more details see Influencing Science

There is evidence that the industry continues to employ strategies to influence research and its approaches do not prevent bias. For example, the tobacco industry, including PMI and BAT, has used external scientific consultants¹⁴³ and publishes its research in journals with which it has ties.¹⁴⁴ Such strategies help to influence the volume, credibility, reach and use of science.¹⁴⁵

The industry has a history of designing clinical research to substantiate and develop harm reduction claims, especially those around reduced exposure to harmful chemicals compared to cigarettes.¹⁴⁶ A 2022 systematic review critically assessing clinical trials on HTPs, most of which have been conducted by tobacco companies, fall short of what is needed to adequately investigate whether HTPs were beneficial to public health.¹⁴⁷ The same review found most of the industry’s clinical trials on HTPs were at high risk of bias, particularly due to inadequate blinding of participants (concealing information from participants that might influence results)¹⁴⁸ and selectively reporting results.¹⁴⁷ A systematic review of the e-cigarette literature found studies by independent authors were more likely to report potentially harmful effects of e-cigarettes, while the majority of studies by tobacco, e-cigarette and pharmaceutical companies reported no harmful effects.¹⁴⁹

All the transnational companies include epidemiological or long-term studies in their assessment approaches. However, according to each company’s Science webpages,^134150151152 their own publication library tags (see Figures 1-3), and reviews of both the HTP^153154155 and e-cigarette literature,¹⁵⁶¹⁵⁷ it appears that, to date, the industry has conducted few epidemiological or long-term studies.

As noted by TobPRAC, Article 5.3 of the WHO FCTC calls for regulatory decisions on tobacco products and scientific assessment of tobacco products to be made independent of the tobacco industry.¹²⁶

For more details see FCTC Regulations on the Need to Protect Public Health Policies from Tobacco Industry Interference

Relevant links

• PMI Science
• BAT Science
• JT Science
• Imperial Brands Science

Tobacco Tactics Resources

Newer Nicotine and Tobacco Products

Influencing Science

References

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