Gerard Hastings, Lynn MacFadyen and Lisa Palleson-Stallan
Gerard Hastings, Lynn MacFadyen and Lisa Palleson-Stallan
Gerard Hastings, Lynn MacFadyen and Lisa Palleson-Stallan
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The Need to Control Tobacco Promotion<br />
<strong>Gerard</strong> <strong>Hastings</strong>, <strong>Lynn</strong> <strong>MacFadyen</strong> <strong>and</strong> <strong>Lisa</strong> <strong>Palleson</strong>-<strong>Stallan</strong><br />
Centre for Tobacco Control Research<br />
M<strong>and</strong>ate: Academic research unit, at the University of Strathclyde in Glasgow<br />
Funding: The Centre is core funded by The Cancer Research Campaign<br />
THE CENTRE FOR TOBACCO CONTROL RESEARCH<br />
UNIVERSITY OF STRATHCLYDE<br />
STENHOUSE BUILDING<br />
173 CATHEDRAL STREET, GLASGOW G4 0RQ<br />
The Centre for Tobacco Control Research is part of the Centre for Social Marketing<br />
The Centre for<br />
Tobacco Control Research<br />
Core funded by<br />
Tel: (44) 141-548 3192<br />
Fax: (44) 141-553 4118<br />
http://www.ctcr.strath.ac.uk<br />
Director: Professor <strong>Gerard</strong> B <strong>Hastings</strong>
Summary <strong>and</strong> Recommendations<br />
Tobacco control research has now established that:<br />
Tobacco promotion increases overall consumption, as well as br<strong>and</strong> share.<br />
Promotion comprises many forms of communication as well as advertising.<br />
Creative <strong>and</strong> marketing skills are used to minimise the impact of regulation.<br />
Targeting is crucial, <strong>and</strong> the poor, the young <strong>and</strong> women are key sub-groups.<br />
The industry operates internationally.<br />
It is driven by a commercial imperative that completely disables any attempts at voluntary regulation.<br />
The recent release of internal documents by the UK House of Commons Select Committee [1,2] confirms that the<br />
industry itself accepts these facts, <strong>and</strong> behaves accordingly.<br />
The implications for tobacco control are clear:<br />
1. Controls on tobacco promotion will reduce the prevalence of smoking <strong>and</strong> therefore save lives.<br />
2. These controls need to cover all forms of marketing communications, not just advertising; sponsorship<br />
<strong>and</strong> packaging are particularly important.<br />
3. They also need to be continually renewed <strong>and</strong> updated to respond to the industry’s ingenuity.<br />
4. Vulnerable groups, including the young, the poor <strong>and</strong> women, need special protection.<br />
5. Regulation needs to be international.<br />
6. It also has to be statutory, well policed <strong>and</strong> include penalties that will deter transgression.<br />
The Framework Convention provides an ideal opportunity to meet these criteria.<br />
In the Industry’s Own Words<br />
During its recent inquiry into the tobacco industry, the House of Commons Health Select Committee on Health<br />
identified the five UK advertising agencies with tobacco industry clients <strong>and</strong>, using its statutory powers,<br />
formally requested internal documents concerning their previous five years of tobacco business. In response the<br />
agencies sent, between them, 16 large boxes containing several thous<strong>and</strong> pages of material. These documents<br />
cover all matters to do with tobacco marketing, <strong>and</strong> therefore shed a unique light on the methods <strong>and</strong> tactics<br />
used to promote tobacco. In the process they also reveal much about the motivations <strong>and</strong> mindset of the tobacco<br />
industry.<br />
The documents confirm six key points about tobacco promotion:<br />
1) It increases overall consumption as well as br<strong>and</strong> share. Research has long demonstrated that advertising<br />
has an effect on overall levels of tobacco consumption, <strong>and</strong> not just the relative share of particular br<strong>and</strong>s.<br />
Studies have modelled: fluctuations in tobacco spend with changes in smoking prevalence [3,4,5] ; differences in<br />
smoking prevalence in countries with varying levels of advertising controls [6,7] <strong>and</strong> changes in smoking<br />
prevalence after the introduction of an advertising ban [8,9] . A review of these studies undertaken by the<br />
Economics & Operational Research Division (EORD) of the UK Department of Health concluded that<br />
advertising encourages consumption as well as br<strong>and</strong> switching among current smokers, <strong>and</strong> may assist in<br />
recruiting young people to the habit [9] .<br />
Despite this evidence, the industry continues to make public denials of any link between advertising <strong>and</strong> tobacco<br />
consumption. However, the documents show that in private they work on the assumption advertising does<br />
increase consumption, <strong>and</strong> use all their creativity to maximise the effect. They underst<strong>and</strong> that people smoke for<br />
emotional reasons, <strong>and</strong> br<strong>and</strong>ing is used to cater for these needs. For example it provides reassurance to the<br />
health conscious feeling guilty about their smoking; or the poor, anxious about having to trade down to a cheap<br />
br<strong>and</strong>. Above all, it adds positive associations to tobacco that are particularly attractive to the young. As the<br />
documents state, smoking is a ‘rite of passage’ behaviour, taken up by young people ‘searching for an identity’.<br />
Br<strong>and</strong>ing provides it.<br />
In each of these instances the effect is not just to increase the appeal of a particular br<strong>and</strong>, but of smoking per se.<br />
It provides the smoker - <strong>and</strong> would be smoker - with palpable benefits for taking up or continuing with the habit.<br />
Put simply, br<strong>and</strong>ing increases consumption.
The industry also makes direct efforts to promote tobacco consumption. For example, one company regretted<br />
the fact that “The smoker is under siege” <strong>and</strong> suggested a campaign that would promote the idea that: “Smoking<br />
can be a delight for everyone if it is done right.” [10]<br />
Similarly careful consideration is given to exp<strong>and</strong>ing particular sectors of the market. A consultant’s report<br />
emphasises the need for “...reinvigoration of the cigar market” It goes on to state that<br />
“There needs to be an attitudinal shift towards cigars, from a target group who are otherwise<br />
put off by 1. a product that is too difficult to trial <strong>and</strong> 2. the image baggage that the market<br />
has to date.” [11]<br />
Finally, efforts are made to recruit new smokers <strong>and</strong> retain potential quitters.<br />
“Ultra has yet to demonstrate a consistent ability to attract new smokers. The key question is<br />
“can we expect the br<strong>and</strong> to appeal to new entrants - or is there a positioning that we can<br />
adopt that makes the br<strong>and</strong> more attractive to entrants?” [12]<br />
“In conclusion, the ‘threat’ to the existing smoker base for the br<strong>and</strong> seems more likely to<br />
come from a desire to give up smoking (which is more strongly held by the SCUL [Silk Cut<br />
Ultra Light] smokers than the SCEM [Silk Cut Extra Mild] smokers), rather than from<br />
competitor br<strong>and</strong>s.” [13]<br />
2) Marketing communications, not just advertising. Main stream advertising is undoubtedly the most potent<br />
weapon in the industry’s arsenal, <strong>and</strong> needs immediate removal. However, even though the documents come<br />
from advertising agencies – <strong>and</strong> therefore one would expect them to emphasise the role of advertising - it is very<br />
apparent that all types of marketing communication play a crucial role in the effort to increase sales. Sports<br />
sponsorship, the pack, point of sale promotional material, direct mail, <strong>and</strong> the internet are all emphasised in the<br />
documents. The first two of these are particularly important.<br />
Sponsorship provides an ideal vehicle for enhancing br<strong>and</strong> image. For example, Formula 1 has been<br />
carefully selected because it is “international, glamorous, challenging, fast, furious, dangerous, living<br />
life to the full <strong>and</strong> living life on the edge” <strong>and</strong> therefore has the “potential to create a more dynamic,<br />
exciting br<strong>and</strong> image”. Sponsorship provides an ideal vehicle for approaching the young, image<br />
conscious consumer, not least because it’s potential to be “subliminal” means that it get through to a<br />
discriminating audience that is:<br />
“…very advertising literate, <strong>and</strong> consequently very wary of big br<strong>and</strong>s latching on to<br />
aspects of their lifestyle <strong>and</strong> exploiting them.” [14]<br />
The pack carries br<strong>and</strong> imagery directly to the smoker, <strong>and</strong>, as the documents make clear, is a great<br />
reinforcer of the habit:<br />
“...the easiest way to communicate with current smokers is through the pack <strong>and</strong><br />
through our extensive direct communications activities...” [15]<br />
“Remember this campaign has its origins in a very simple truth, the smokers of B&H<br />
when they put their pack on the pub table, will always have it noticed by their friends.<br />
It is their badge <strong>and</strong> all we are trying to do is celebrate it.” [16]<br />
The industry’s own consultants emphasise the range of communication options that are available, even<br />
in the event of an adban:<br />
“Even in the presence of an advertising ban it is possible, through intensive point of sale<br />
efforts, price discounting <strong>and</strong> use of new communications media (see Appendix), to reinforce<br />
the image of existing br<strong>and</strong>s with the consumer <strong>and</strong> to launch new br<strong>and</strong>s, eg. Price, L&M,<br />
Horizon.” [17]
3) Continuous efforts are made to undermine regulation. Government public health policy is directly<br />
challenged: serious consideration is given to attacking Tessa Jowell, the then UK Minister of Public Health <strong>and</strong><br />
other out-spoken critics; ideas for resisting <strong>and</strong> circumventing an adban are explored <strong>and</strong> campaigns that will<br />
undermine budget price rises are developed <strong>and</strong> run.<br />
“Possible Routes<br />
1. Undermine Jowell, position her as the Minister of Bans, undemocratic <strong>and</strong> rash/ hasty<br />
decisions. Undermine other supporters eg. Branson (cite connections with<br />
Rizla/Virgin)” [18]<br />
“The role of the mailing is to ‘disguise’ the duty increase (15p) on a packet of fags.” [19]<br />
Not surprisingly, given this rather cavalier attitude to government policy, the voluntary codes also come in for<br />
some cynical treatment. Various references are made to “stepping close the legal rulings”, “pushing the ASA 1 ”<br />
<strong>and</strong> “sailing very close to the wind”, <strong>and</strong> the strategies proposed clearly deserve these labels. For example,<br />
suggestions for Formula 1 include sneaking parts of the ‘B&H Special Filter’ name <strong>and</strong> logo into camera shot<br />
<strong>and</strong> corrupting the Jordan logo.<br />
“As you will see we have a couple of thoughts:<br />
1) We feel if we can legally say the words “A Special F1” [as in Special Filter]then we could<br />
utilise the area behind the driver’s head – as you see – to attempt to get a little closer to<br />
more “overtly” implying the br<strong>and</strong> on the car. Do you think we could get this past the<br />
various legal bodies? If Rothman’s can get away with “racing” in the br<strong>and</strong> typeface, I<br />
think we may have a case.<br />
2) We wonder if you could slightly corrupt the Jordan logo to include a large “ampers<strong>and</strong>”<br />
[from B&H]. I think this will be sailing very close to the wind. Our reasoning for<br />
suggesting it is that the ampers<strong>and</strong> is not actually part of your logo though if it were to<br />
appear I believe people would recognise it as being so.” [20]<br />
4) Vulnerable groups are targeted. The documents show that the industry has a text book approach to<br />
marketing: the population as a whole is divided into smaller, more homogenous segments; the viability of each<br />
group is then analysed to determine if they are worth targeting; finally, customised marketing strategies are<br />
devised for those groups that hold most promise.<br />
However, unlike text book marketing, no reference is made anywhere to the ethics of targeting particular groups<br />
or using particular strategies. This is of particular concern, as the young, the poor, women <strong>and</strong> students all<br />
emerge as front runners. The young are susceptible to evocative br<strong>and</strong> imagery, as noted above, <strong>and</strong> the poor<br />
can be reached by a combination of price offerings, gift schemes <strong>and</strong> reassuring br<strong>and</strong>ing to make inferior<br />
products feel better. A specifically female br<strong>and</strong> is also felt to have potential:<br />
“Smoking remains marginally female in profile, a bias which is slightly increasing ... Women<br />
are heavier smokers of certain niche br<strong>and</strong>s, but there are none which are overtly female in<br />
attitude <strong>and</strong> approach .... Opportunity possibly exists for overtly female targeted cigarette,<br />
(perhaps tapping into female cigar smoking trend?)” [21]<br />
5) This marketing activity is increasingly international. The documents disclosed by the committee<br />
specifically related to the UK, but even here the international nature of the industry’s marketing is made clear: a<br />
new br<strong>and</strong> of h<strong>and</strong> rolling tobacco is launched onto the UK market through campaigns targeting bootleggers in<br />
Belgium; British tourists are targeted at overseas holiday destinations where promotional regulation is less strict<br />
<strong>and</strong> Formula 1 presents global marketing opportunities.<br />
These clues are backed by market trends, which show that major tobacco br<strong>and</strong>s are crossing boarders.<br />
Research by the international advertising agency BBDO [22] , for example, makes it clear that br<strong>and</strong>s are a crucial<br />
element of tobacco marketing <strong>and</strong> can be used to prise open developing <strong>and</strong> transition economies. Marques<br />
such as Marlboro have now become global entities with almost iconic status.<br />
1<br />
The ASA is the Advertising St<strong>and</strong>ards Authority which oversees the voluntary code on tobacco advertising through its<br />
Committee on Advertising Practice.
6) The tobacco industry is driven by a commercial imperative. The marketing practices discussed in this<br />
submission are underpinned by powerful commercial forces. In a competitive market companies will always do<br />
their utmost to survive <strong>and</strong> succeed. Arguably, they have no choice - the commercial pressures are an<br />
imperative. The problem is that this imperative runs directly contrary to public health. It also makes voluntary<br />
regulation completely unworkable. The UK experience puts this beyond doubt.<br />
The only solution is statutory control: the FCTC, as Martin Khor [23] suggests, must be given real teeth <strong>and</strong><br />
energy. This requires three steps. First, confirmation is needed that article 8 of TRIPS, which outlaws any<br />
WTO rule that threatens public health, applies to tobacco. This will ensure that the tobacco companies cannot<br />
hide behind WTO. Second, there needs to be a transparent <strong>and</strong> effective dispute resolution mechanism, much as<br />
with WTO, where individual member states can force tobacco firms to comply with the FCTC or face serious<br />
financial penalties. Finally, these measures need to be backed by capacity building on a micro <strong>and</strong> macro level.<br />
Individuals, NGO’s <strong>and</strong> civil society need to informed <strong>and</strong> empowered to stimulate action by their<br />
Governments.<br />
References<br />
1. <strong>Hastings</strong> GB (2000). Keep smiling. No one’s going to die. Appendix 26 in The tobacco industry <strong>and</strong> the<br />
health risks of smoking, Second Report, Volume II. London: Health Committee, House of Commons.<br />
2. <strong>Hastings</strong> GB <strong>and</strong> <strong>MacFadyen</strong> L (2000). A day in the life of an advertising man: Review of internal<br />
documents from the UK tobacco industry’s principal advertising agencies. British Medical Journal, 321(5<br />
August): 366-371.<br />
3. McGuiness T <strong>and</strong> Cowling K (1975). Advertising <strong>and</strong> the aggregate dem<strong>and</strong> for cigarettes. Eur Eco Rev,<br />
6: 311-328.<br />
4. Witt SP <strong>and</strong> Pass CL (1981). The effects of health warnings <strong>and</strong> advertising on the dem<strong>and</strong> for cigarettes.<br />
Scot J Pol Econ, 28: 86-91.<br />
5. Radfar M (1985). The effect of advertising on the total consumption of cigarettes in the UK. Eur Econ<br />
Rev, 29: 225-231.<br />
6. Cox H <strong>and</strong> Smith R (1984). Political approaches to smoking control: a comparative analysis. Appl Econ,<br />
16: 569-582.<br />
7. Laugensen M <strong>and</strong> Meads SC (1991). Tobacco advertising restrictions, price, income <strong>and</strong> tobacco<br />
consumption in OECD countries, 1960-1986. British Journal of Addiction, 86: 1343-1354.<br />
8. Perkurinen M (1989). The dem<strong>and</strong> for tobacco products in Finl<strong>and</strong>. British Journal of Addiction, 84: 1183-<br />
1192.<br />
9. Economics <strong>and</strong> Operational Research Division (EORD) (1992). Effect of tobacco advertising on tobacco<br />
consumption: a discussion document reviewing the evidence. London: Department of Health.<br />
10. Submission from CDP to the Health Committee House of Commons - Gallaher Briefs 1996.<br />
11. Submission from CDP to the Health Committee House of Commons - Gallaher Memo’s 1998.<br />
12. Silk Cut 1998 Planning Day: Report, 1998.<br />
13. Market Trends Ltd. Silk Cut Research: Prepared for Gallaher Ltd, November 1995.<br />
14. M&C Saatchi. Renaissance/Silk Cut: Creative Brief for Gallaher, 7 May 1996.<br />
15. Advertising Support For Gratis II Catalogue Agency Recommendation. Submission from CDP to the<br />
Health Committee House of Commons - Gallaher Strategic Analysis Papers 1995.<br />
16. Benson <strong>and</strong> Hedges Special Filter: Creative Brief, 22 May 1997. Submission from CDP to the Health<br />
Committee House of Commons - Gallaher Briefs 1997.<br />
17. The Impact of Advertising Bans on Product Promotion, Memo from General Manager, Corporate Affairs,<br />
Gallaher Ltd, 14 July 1997.<br />
18. Gallaher/TMA. Awareness of Communications Ban Campaign.<br />
19. Benson <strong>and</strong> Hedges Special Filter Mailshot: Creative Brief, 1 September 1997. Submission from CDP to<br />
the Health Committee House of Commons - Gallaher Briefs 1996.<br />
20. Memo from Simon North to Barry Jenner, 22 April 1996. Submission from CDP to the Health Committee<br />
House of Commons - Gallaher Internal Memos 1996.<br />
21. Potential Areas for Research: Slides, 2 October 1997, Gallaher NPD.<br />
22. Paliwoda SJ <strong>and</strong> Ryan JK (1995). International Marketing. Routledge.<br />
23. http.//tobacco.who.int