Well, that went down to the wire. I can't tell you how busy we've been these past couple of weeks (or how many Christmas parties I've been to) but we finally submitted Forest's response to the EC Tobacco Products Directive consultation this afternoon, an hour or so before the deadline.
And the petition? Well, the online petition we launched ten days ago attracted a total of 1655 names (and addresses) of whom 1610 were EU citizens. Others came from America, mostly, but also Australia, Thailand, Japan, Mexico, Norway and Switzerland, but we had to exclude them because the consultation was targeted at EU citizens only. (Perhaps I didn't make that clear.)
Anyway, given that the petition didn't get much promotion beyond Forest's mailing lists, Iain Dale's Diary (which helped add 150-200 names earlier in the week), Taking Liberties and two or three other blogs (Dick Puddlecote, Pat Nurse and the ASI blog), I'm not unhappy with the result.
Interesting to note the location of respondents, by country. I've had a quick glance at the documentation and the numbers seem to break down as follows:
United Kingdom, 1300
PS. The EC has previously tried, and failed, to exclude Forest from stakeholder meetings in Brussels on the grounds that we are not an EU-wide organisation. Now, perhaps, they will believe me when I say that we have supporters in a number of EU countries.
H/T to Wiel Maessen for the Dutch contingent.
Here are some excerpts from Forest's online submission:
Scope of the directive
The [consultation document] not only ignores the very important issue of consumer choice, it is also looking for problems that do not exist ... The EC should not be proposing further regulations and/or restrictions that are not based on clear scientific evidence.
Smokeless tobacco products
Europe is supposed to be a single market. It is therefore wrong to deny consumers in all EU member states the opportunity to purchase a product [snus] that is freely available and widely used in another member state ...
Forest rejects the suggestion that packaging is used as an “advertising tool”. Packaging allows the consumer to differentiate between different brands. There is no credible evidence that packaging is a significant reason why anyone, let alone “vulnerable groups”, start or even continue to smoke ...
Increasing the size of the picture warning will have little or no long-term impact other than adding to the unnecessary “uglification” of our surroundings and the unacceptable “denormalisation” of a legal consumer product ...
The [consultation document] talks of “current package design … generating evocative images such as luxury, freedom and glamour”. Tobacco control campaigners often refer to “glitzy” packaging. We are not aware of ANY tobacco packaging that falls into these categories ...
A much bigger problem, not addressed by the [consultation document], is the exaggerated “quit or die” message implicitly promoted by most health warnings, supported by pictorial warnings that are not only ugly and offensive but exaggerate the risks to most consumers. We do not question the health risks associated with smoking but we do question the way those risks are communicated to the general public. In our experience the health messages are now so gruesome (and run counter to most people’s personal experience) that the opportunity to educate consumers in a sensible way is being lost.
Access to tobacco products
Forest supports proof of age card schemes but we do not support further controls on the display of tobacco products. There is insufficient evidence to support the claim that such a move would reduce smoking rates among children or adults.
Likewise we do not believe that a ban on tobacco vending machines will reduce youth smoking rates. Instead it will restrict choice for adult consumers. Use of tokens, credit cards or radio-controlled vending machines would all but eliminate underage access without the need for a ban.
We are concerned that increasing restrictions on tobacco displays and vending machines are designed to artificially “denormalise” smoking and stigmatise adult consumers who choose to purchase a legal product in full knowledge of the health risks of smoking.
Banning tobacco display and vending machines will encourage illicit trade and the sale of counterfeit tobacco in pubs and bars. Not only will the governments lose revenue, consumers (including children) could be put at greater risk.
A ban on tobacco displays is an act of commercial censorship that will eventually reduce choice for adult consumers because tobacco companies are less likely to develop new brands and products if their ability to communicate with their customers is severely restricted.
As long as tobacco remains a legal product, manufacturers must have the right to differentiate between their products by means of graphic design and consumers should be allowed to differentiate easily between brands.
Plain packaging will also make it substantially easier for criminals to supply counterfeit cigarettes that may have been manufactured and sold contrary to current regulations.
And so on.
The Freedom Association has also submitted a response. I'm delighted because it shows that tobacco control is finally being taken seriously by non-tobacco related groups.
Ten years ago, had I invited the then chairman of The Freedom Association to speak out against tobacco control, I know exactly what he would have said. I was editing The Freedom Association magazine Freedom Today at the time and I didn't even bother to ask. I know what the reply would have been.
So credit to The Freedom Association and the author of the submission Stephen Hoffman. Click HERE.