Our experience and expertise means that we have much to offer governments and regulators when it comes to helping develop policies around cigarettes and potentially reduced-risk products.
We have always been clear that we support regulation that is based on robust evidence and thorough research, respects legal rights and livelihoods and delivers on the intended policy aims, while recognising unintended consequences.
Along with the industry, governments and the public health community have a key role to play in maximising the potential for potentially reduced-risk products (PRRPs) to contribute to harm reduction. For these products to be a success, they must be supported by effective regulatory and policy regimes that enable responsible growth and promote informed consumer choice. This must then be complemented by responsible practices by the industry.
We want to contribute to the debate, offering information, ideas and practical steps to help regulators address the key issues facing the industry.
That is why, on issues such as the regulation of PRRPs, we have been working with governments and regulators to ensure appropriate frameworks are in place to protect consumers while ensuring proper marketing freedoms exists. This will help us grow the category and meet demand for products that are potentially reduced risk compared with smoking conventional cigarettes.
PRRPs can only meet their tobacco harm reduction potential if the right regulatory conditions are in place. As the science increasingly points to the likely benefit of PRRPs as an alternative to smoking, we are seeing policy and regulatory shifts in several markets globally.
The UK is an example of what can happen with the support of regulators and public health bodies. Driven by influential reports from Public Health England and the Royal College of Physicians on the reduced risk potential of vapour products, the UK Government has implemented a balanced regulatory regime that discourages youth uptake while also encouraging adult smokers to migrate to potentially less harmful products.
It’s essential that these products are not marketed to youth. In markets where there aren’t sufficient standards in place to ensure this is the case, we welcome industry-wide responsible marketing and youth access prevention standards.
We also contribute to the development of international standards, such as ISO’s vaping standard and CEN’s guidance document on vaping aerosol measurements, both published in 2018. Prior to that, we worked with national standards bodies in France and the UK to establish voluntary quality and safety standards for vapour products, and also on the world’s first tobacco heating products standard in Russia.
However, when it comes to plain packaging, we have always believed that this policy is disproportionate, will not deliver its intended results and significantly erodes our intellectual property rights by stripping us of our right to use our trade marks.
Some regulations can also have unwelcome and unexpected consequences. For example, sudden and significant hikes in excise rates can result in price disparities between neighbouring countries, increasing smuggling across borders.
We have long supported the Organisation for Economic Cooperation and Development’s (OECD) Principles for Transparency and Integrity in Lobbying. Our Principles for Engagement provide clear guidance for our external engagement with regulators, politicians and other third parties.
We are transparent about what we think, supporting some new proposals but disagreeing with others. When we do not agree with proposed regulations, we try to be constructive and put forward alternatives that can still achieve governments' aims.