Plain packs, e-cig bans and the triumph of ignorance

Today marks the publication of the Chantler Review into standardised packaging for cigarettes, which follows the proposal from the Welsh government to ban the use of electronic cigarettes in enclosed public spaces. I haven't read the whole of Chantler's review but it's summary contains the observation that:

There is very strong evidence that exposure to tobacco advertising and promotion increases the likelihood of children taking up smoking. 

We know that advertising does not act to raise demand both generally and specifically for products such as cigarettes. So I have to assume that the 'evidence' relied on by Chantler is primarily the qualitative studies undertaken by tobacco control researchers that essentially show how children prefer pretty colours to drab colours. This may be true but there's a leap from 'I like pink' to 'I'll start smoking because I like the pink pack' that simply doesn't have evidential support.

Chris Snowden points out that Chantler finds only a 'moderate' impact on uptake - something that would be very difficult to prove one way or another especially since advertising (even where it is still permitted) has only a marginal impact on the decision of a person to experiment with smoking. More importantly Chantler says that this impact will only be realised 'over time' creating more vagueness and imprecision. I remain unconvinced that this is the best option for public intervention if our aim is either (or both) to reduce levels of smoking adoption or increase rates of smoking cessation.

Indeed, if the evidence is right that it is the person's environment (do parents, other family members and peers smoke) that plays the dominant role in the decision to experiment with smoking then the emphasis should be on smoking cessation rather than smoking adoption. And this brings us to the proposal in Wales to apply the same restrictions to using electronic cigarettes as apply to smoking tobacco.

The Welsh health minister, Mark Drakeford, said officials were considering a ban amid concerns that the products could "re-normalise" the use of conventional cigarettes.

He said there were also concerns that their spread could undermine the ban on tobacco smoking in enclosed public spaces, making it more difficult to enforce.

This is a truly egregious proposal since we know that electronic cigarettes are widely adopted by smokers to either quit or reduce their use of tobacco and that they eliminate nearly all the personal as well as all the environmental risks associated with smoking tobacco. Worse still, the argument made here contradicts the rationale for the smoking ban - protecting the health of others in the smoking environment.

Since we want fewer smokers then we should be supporting the adoption of electronic cigarettes by current smokers. Not just to benefit the health of those smokers but to reduce the probability of their children, brothers, sisters and friends taking up the habit. By seeking to denormalise electronic cigarettes, the Welsh government is describing the devices as no different from tobacco with the result that children are as likely to adopt the latter as the former. Plus, of course, increasing the likelihood that the vaper will switch back to tobacco - a point succinctly put by Tim Stanley:

Force me to stand outside and I’ll calculate that I may as well go back to the Marlboro Lights.

Although these proposals are filled with analysis and wrapped up in stuff that looks like science, they are at best selective and at worst simply ignorant. In the case of packaging, the review relies on studies by non-marketers working in tobacco control research and completely ignores the substantial body of research evidence on the role and effectiveness of brand advertising. And for electronic cigarettes, the assumption is that they will act as some sort of gateway for tobacco rather than (as the evidence suggests) quite the reverse.

It does seem that what we have here isn't an example of good evidence-based policy but rather a victory for anti-smoking obsession and a triumph of ignorance.

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Consultation on plain packaging for cigarettes - what you need to tell the government

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The government has launched a consultation on the introduction of plain packaging for tobacco products - be warned the questions are loaded and partisan. However, you do get the chance to make your comments. My advice - be moderate in your comments, provide evidence where you can and stick to the core objections:

1. The proposals fail to understand the role of brands:

"Branding fulfils many significant and positive functions for both consumers and markets. Take it away and consumers lose out and markets become commoditised, with price rather than quality being the influencing factor. As well as calling on Government to consider carefully whether plain packaging will yield any positive impact in practice, we will also encourage it to look at all the possible negative impacts."

2. Plain packaging makes counterfeiting and illicit sale of cigarettes more likely:

BASCAP (Business Action to Stop Counterfeiting and Piracy) is concerned that plain packaging requirements would increase the prevalence of counterfeit goods in the market and reduce brand owners' ability to take action against such activity, besides undermining the ability of consumers to make informed purchasing decisions. Trademarks serve these important functions in the market for all branded goods. Plain packaging [is] likely to increase rather than decrease burdens on already overstretched public agencies working to enforce intellectual property protections in the face of escalating counterfeiting and piracy in the United Kingdom and worldwide."

3. Plain packaging threatens jobs:

Mr Barber said: “These proposals could have serious implications for our business as tobacco packaging is vital to our turnover. It could cost up to 50 per cent of the jobs here."

4. The proposals will damage businesses:

...a report from Deloitte titled “Potential impact on retailers from the introduction of plain tobacco packaging”, February 2011, states that the operator of a service station can expect to incur additional staff costs of between A$9,000 and A$34,000 due to the extra work that would be required to handle plain packaged tobacco products.

I'll leave you to add your comments on how the proposals are illiberal, anti-business and based on the flimsiest of evidence. I would also urge - as well as responding to the consultation - for you to write to your MP making the above points - this is an unjustified idea without evidence that will destroy jobs, promote crime and damage personal liberty.

The consultation is here - be prepared to give an hour of your time.

http://consultations.dh.gov.uk/tobacco/standardised-packaging-of-tobacco-products/consult_view


And just for the record, I am a non-smoker.
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Plain packaging for tobacco will mean hundreds of job losses in Bradford

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The packaging industry is important to Bradford and much of it is geared to supply the tobacco industry. Introducing plain packaging is a big threat to these jobs. Here's Paul Barber from Weidenhammer:
 

“These proposals could have serious implications for our business as tobacco packaging is vital to our turnover. It could cost up to 50 per cent of the jobs here."

And the same goes for Chesapeake which produces packaging for Philip Morris and BAT.

Plus these businesses recognise the agenda of the New Puritans - plain packaging for fags will be followed by plain packaging for booze and crisps.

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Plain packaging...

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Chris Snowdon has - via the good offices of the Adam Smith Institute - published a paper on the lunatic idea of introducing plain packaging for cigarettes. It is an excellent read filled with real facts, references to real research and a commitment to liberty.

In addition Conservative Home have given Chris some space to set out his argument - it's certainly worth reading the comments thread. No sign of much support for the idea.

For my part I wrote about this - from the perspective of a professional and experienced marketer:

Firstly, brands do not act to recruit customers to a given product – we choose to buy the product and then we select the brand. Nobody starts buying bread because they saw a Warburton’s ad – they buy bread because, well, they want bread! What the brand provides is a heuristic – a short cut, if you will – allowing the consumer to make a choice quickly and confidently. What we do know is that it is the search for a benefit that makes consumers choose to buy a product rather than the shininess of the brand presentation.  Or is you prefer: we buy bread because we want to eat it not because the advert featured a brass band playing chunks from the New World Symphony!

Secondly, packaging serves two purposes – identification and appeals to impulse. In the first instance we put our product into easily identified packaging as part of that heuristic, as a quick means of identifying our particular version of a given product. And, where purchase is often impulse driven, we use packaging to make the product stand out from other similar products. So yes packaging can assist purchase – but only where it isn’t a considered purchase.

The rest of this piece can be read here - suffice it to say that the scale of ignorance about the purpose of brands and the point of packaging beggar's belief. Anyone would think they had an agenda!

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Plain packaging won't affect tobacco use or the numbers taking up smoking

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The Department of Health under its supposedly Conservative minister, Andrew Lansley, is proposing to require cigarettes to be sold in plain packages and probably for displays of cigarettes to be outlawed. The purpose of this we’re told is:

"The evidence is clear that packaging helps to recruit smokers, so it makes sense to consider having less attractive packaging. It's wrong that children are being attracted to smoke by glitzy designs on packets.

"We would prefer it if people did not smoke and adults will still be able to buy cigarettes, but children should be protected from the start.

"The levels of poor health and deaths from smoking are still far too high, and the cost to the NHS and the economy is vast. That money could be used to educate our children and treat cancer," Mr Lansley said.

Now I’m not sure quite what all this is about or, indeed, whether the so-called evidence actually exists – I certainly couldn’t find it. However, unlike the doctors and bureaucrats crawling over the airwaves frothing with excitement about these proposals, I do know a thing or two about marketing and branding (having been Account Planning Director of a leading direct marketing agency and having spent six years writing management implications pieces in the Journals of Consumer Marketing and Product & Brand Management).

Firstly, brands do not act to recruit customers to a given product – we choose to buy the product and then we select the brand. Nobody starts buying bread because they saw a Warburton’s ad – they buy bread because, well, they want bread! What the brand provides is a heuristic – a short cut, if you will – allowing the consumer to make a choice quickly and confidently. What we do know is that it is the search for a benefit that makes consumers choose to buy a product rather than the shininess of the brand presentation.  Or is you prefer: we buy bread because we want to eat it not because the advert featured a brass band playing chunks from the New World Symphony!

Secondly, packaging serves two purposes – identification and appeals to impulse. In the first instance we put our product into easily identified packaging as part of that heuristic, as a quick means of identifying our particular version of a given product. And, where purchase is often impulse driven, we use packaging to make the product stand out from other similar products. So yes packaging can assist purchase – but only where it isn’t a considered purchase. Sadly for Mr Lansley and his pals, tobacco isn’t an impulse purchase – we have to make a choice to buy and ask someone for the product. We can’t just grab 20 Regal from the countline display! Thus the only impact of plain packaging will be to increase confusion and error (they all look the same) and slow down the purchase process by making selection by the shop assistant more difficult.

And thirdly, smokers are going to buy tobacco. Put it in plain packets or wrap it in shiny gold tissue paper, it doesn’t make a difference – the smoker will go to the counter and ask for the product she wants. And the smoker will still ask for a brand – Benson & hedges, Marlboro’ or whatever – as that is the heuristic, the short cut allowing the person serving to meet that customers requirements. What will change – which suits big tobacco fine – is that levels of switching between brands will reduce. In fact the same effect that banning advertising had on consumption (and why it was the media and advertising industry that opposed the ban far more vigorously than did the tobacco manufacturers).

My main concerns in all this – leaving aside the issue of personal rights – is that, if the aims are twofold: first to increase rates of smoking cessation and second to reduce rates of smoking adoption, then we are barking up the wrong tree. By way of illustration, between 2003 and 2005 all forms of tobacco advertising in the UK were banned. If the arguments for a ban were correct – less tobacco use and fewer tobacco users – we would have expected the rate of tobacco consumption to accelerate. However, the ban (like the smoking ban in public spaces) had no discernible impact on the long-standing decline in use.  In fact, as this chart shows the reduction has slowed almost to a stop – the ban did not do what its advocates claimed.

 And we should remember that tobacco consumption figures get more and more inaccurate with each passing year and with every duty increase.

In 2004, it was widely accepted that around 25 per cent of all cigarettes and as much as 75 per cent of hand-rolling tobacco consumed in the UK were non-UK duty paid. Independent retailers put the cost to them of this trade at £1.2 billion per annum in sales. In 1999, a study showed that smuggling cost the Treasury £2.5 billion in lost revenue. 

That is pretty much a guess and today's situation has got worse and the tobacco business is become less and less legal, less protected and more dangerous. And plain packaging make counterfeiting more likely, smuggling easier and, coupled with ever more draconian controls on normal retail sales, will result in yet more of the trade shifting from supermarket and corner shop to white van and sixth floor council flat. Where of course, the sale jostles for position with stolen goods, counterfeits and illegal drugs!



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