'It will harm business and increase illicit trade': an evaluation of the relevance, quality and transparency of evidence submitted by transnational tobacco companies to the UK consultation on standardised packaging 2012

Abstract

IntroductionTransnational tobacco companies (TTCs) submitted evidence to the 2012 UK Consultation on standardised packaging (SP) to argue the policy will have detrimental economic impacts and increase illicit tobacco trade.MethodsA content analysis of the four TTC submissions to the consultation assessed the relevance and quality of evidence TTCs cited to support their arguments. Investigative research was used to determine whether the cited evidence was industry connected. Fisher's exact tests were used to compare the relevance and quality of industry-connected and independent from the industry evidence. The extent to which TTCs disclosed financial conflicts of interest (COI) when citing evidence was examined.ResultsWe obtained 74 pieces of TTC-cited evidence. The quality of the evidence was poor. TTCs cited no independent, peer-reviewed evidence that supported their arguments. Nearly half of the evidence was industry-connected (47%, 35/74). None of this industry-connected evidence was published in peer-reviewed journals (0/35) and 66% (23/35) of it was opinion only. Industry-connected evidence was of significantly poorer quality than independent evidence (p<0.001). COIs were not disclosed by TTCs in 91% (32/35) of cases.ConclusionsIn the absence of peer-reviewed research to support their arguments, TTCs relied on evidence they commissioned and the opinions of TTC-connected third-parties. Such connections were not disclosed by TTCs when citing this evidence and were time consuming to uncover. In line with Article 5.3 of the Framework Convention on Tobacco Control and broader transparency initiatives, TTCs should be required to disclose their funding of all third-parties and any COIs when citing evidence.

Standardized packaging and illicit tobacco use: A systematic review

“…Searches generated ten relevant empirical studies 21,30,[32][33][34][35][36][37][38][39] : three were qualitative studies (two reporting focus group research with young adult smokers in Scotland 30,32 , and in-depth interviews with retailers in New Zealand 39 ); three were content analyses (of online commentary on tobacco packaging in Australia 33 , UK press coverage of the illicit tobacco trade 34 and the four TTC submissions to the consultation in the UK 35 ); two were cross sectional surveys (of illicit tobacco use following introduction of standardized packaging in Australia) 36,37 ; and two were before and after studies (one of availability of illicit tobacco in small retail outlets 38 and one empty-pack survey before and after the introduction of standardized packaging in Australia) 21 . See Table 2 for a summary of included studies.…”

“…There were few studies examining tobacco standardized packaging and illicit trade and those that were available were generally not of high quality. We identified ten relevant empirical studies which examined standardized packaging and illicit tobacco 21,30,[32][33][34][35][36][37][38][39] . Five studies reported smokers did not intend to 30,32 or actually 21,36,37 purchase more illicit tobacco following standardized packaging although one 33 suggested a small number of responders to online news felt smokers In 179 (59%) of the shops the secret shopper then asked the retailer about the availability of unbranded, i.e.…”

“…In addition the intent of the TTCs could not be measured and the independent data that were used for comparison of industry data were provided by one organisation only. EvansReeves and colleagues 35 , analysis of the four TTCs submission to the consultation on standardized packaging failed to report results separately for evidence relating to economic and illicit trade consequences and they were not able to identify industry connections to three of the organisations who co-authored with other TTC linked organisations. Evans-Reeves and colleagues 35 also did not assess the accuracy of the TTCs' interpretation of the evidence reported and only counted unique pieces of evidence (although several were reported by more than one company and often by all four).…”

“…In addition, Evans-Reeves and colleagues 35 carried out a content analysis of the four TTCs submission to the consultation on standardized packaging for relevance and quality of evidence that TTCs cited to support their arguments that "it will harm business and increase illicit trade". They found 74 pieces of TTC cited evidence; 45% opinion (from TTC connected third parties), 25% research, 15% strategy documents and 15% facts and figures, all of which were of poor quality.…”

“…Finally, two studies 34,35 examined the nature and quality of industry data on illicit tobacco and the potential effect of standardized packaging. Rowell and colleagues 34 quantified the volume, nature and quality of UK newspaper articles citing tobacco industry data on illicit tobacco between March 2008 and March 2013.…”