October 14, 2014

Open Letter to Michael Moore, CEO, Public Health Association of Australia

Dear Mr. Moore,

In an 18 June 2014 Public Health Association of Australia press release, you were quoted as saying, "if the tobacco industry has nothing to hide, why would it refuse to release reports on which it bases claims about trends in Australia?"

Exactly which reports are you referring to? Did you mean the analysis by renowned consulting firm London Economics - publicly available here - which found no evidence of a change in smoking prevalence following the implementation of plain packaging?

Was it the KPMG analysis of the Australian tobacco black market – publicly available here – which found that not only did illicit trade increase following the implementation of plain packaging, but so did total tobacco consumption. Was it the industry sales volume data for the past five years – publicly available here - which shows an increase in legal tobacco sales volumes after the implementation of plain packaging?

Was it the South Australian Government data showing that smoking prevalence increased more than 16% following the implementation of plain packaging – at least that’s what Health Minister Jack Snelling said, here.

Perhaps, because as you say, plain packaging is "aimed especially at children and young people," you were referring to the analysis of adolescent smoking prevalence by experts from the Universities of Saarland and Zurich which "failed to find any evidence for an actual plain packaging effect on minors". Perhaps you missed that paper when it was published in the prestigious University of Zurich Department of Economics Working Paper Series – if so, you can find it here . Had you seen this publicly available report, you would know that despite conducting multiple analyses of publicly available youth smoking prevalence data and structuring them in a way that was most likely to find that plain packaging reduced smoking, the experts could find no evidence of a plain packaging effect.

We also noted with some concern your accusation that the tobacco industry is lying about the impacts of plain packaging. This accusation is completely false. The real question is whether relying on the Australian Bureau of Statistics (ABS) household expenditure data to support claims that plain packaging is a "winner" is completely honest.

The data you rely on shows that, in December 2013, one year after the implementation of plain packaging, household spending on tobacco had actually increased by 2.5%. In fact, in the three quarters before the December 2013 excise hike of 12.5% impacted the market, household spending on tobacco went in one direction – up.  This was the first time it had increased since March 2010.

In addition, even the ABS admits  that its data measures household expenditures only, not the actual amount of tobacco consumed. It doesn’t account for consumers switching to less expensive legal or even black market tobacco, which would allow them to spend the same amount, or even less, but buy just as much or more tobacco.

In the future, instead of accusing companies of "lying", we’d hope that the public discourse moves beyond accusatory rhetoric that prevents sensible debate about tobacco policy and rather focuses on the facts, even when they are inconvenient.


Chris Argent 
Director Corporate Affairs
Philip Morris Limited