Analysis of submissions to the EU’s public consultation on tobacco traceability and security features

Abstract

Abstract Background The Illicit Trade Protocol (ITP) requires all Parties to establish a tobacco track and trace (T&T) system. In 2016, the European Commission held a public consultation on T&T implementation in which interested parties were asked to respond online to 22 multiple-choice questions and were given additional opportunities to leave comments if desired. In May 2019, the EU's T&T system became operational. This paper explores tobacco industry influence over and policy positions within the consultation process. Methods The Illicit Trade Protocol (ITP) requires all Parties to establish a tobacco track and trace (T&T) system. In 2016, the European Commission held a public consultation on T&T implementation in which interested parties were asked to respond online to 22 multiple-choice questions and were given additional opportunities to leave comments if desired. In May 2019, the EU's T&T system became operational. This paper explores tobacco industry influence over and policy positions within the consultation process. Results Of the 197 consultation responses analysed, 131 (66.4%) had financial links to the tobacco industry. 89 respondents were trade associations, 74 of which were financially linked (33 had TTC members). 29 (22.1%) of the financially-linked respondents were not transparent about their links. There was a clear divide in the policy preferences of respondents with and without a financial link. Collectively, respondents with a financial link supported an industry-operated solution. Conclusions There was an extensive lobbying effort by the tobacco industry over the EU's T&T system, with TTCs' interests being represented repeatedly through multiple trade associations. The transparency requirements regarding consultation respondents' affiliations with relevant stakeholders (such as tobacco manufacturers) should be improved for future tobacco-related consultations. Key messages There was an extensive lobbying effort on the part of the tobacco industry Several respondents with financial links to the tobacco industry did not disclose these. Collectively, respondents with a financial link to the tobacco industry supported an industry-operated solution which would not have met the requirements of the ITP.