Submission by Imperial Tobacco Australia Limited (PDF 600 KB)

8 CONCLUSION
Imperial Tobacco strongly supports all efforts to evaluate regulation against evidencebased
data and believe such assessment should be conducted by an independent body.
We continue to seek constructive dialogue with regulatory authorities in order to support
reasonable, proportionate and evidence-based regulations. We seek to be involved in
these processes and can offer specialist commercial and technical knowledge about the
industry.
Government policy aimed at addressing the health risks associated with tobacco should be
geared towards eliminating illicit trade in tobacco and we submit that combating illicit trade
should be a separate stand-alone priority action area. These measures would be in line
with the Framework Convention on Tobacco Control and would „increase tax revenue and
save lives.‟ ITA is concerned that many of the policies proposed by the consultation
paper may be counterproductive to the goal of reducing illicit trade in tobacco. For
example, increased prices or the imposition of minimum pricing will inevitably encourage
consumers to substitute legal tobacco products with cheaper illegal alternatives.
Smoking is a legitimate choice for informed adults to make for themselves. ITA is strongly
opposed to youth smoking and again expresses its interest in working with government
towards reasonable and practical steps to prevent minors from accessing tobacco
products.
However, as long as tobacco products remain legal, ordinary principles of free market
competition should apply to businesses who sell tobacco products to adults: players in the
tobacco industry should be encouraged to provide competitive products to consumers at a
competitive price. Measures aimed at prevent manufacturers and retailers from engaging
in healthy competition pose inappropriate restrictions on consumer choice and damage
legitimate, responsible retailers.
The best way to improve public health in this area, besides curbing illicit trade in tobacco
products, is to educate consumers and retailers about the risks associated with tobacco
use and of the penalties for supplying illegal tobacco or for supplying tobacco products to
minors. Education programs should be supportive and respectful, and must avoid
stigmatising or harassing smokers. ITA has engaged successfully in these types of
education programs in the past and looks forward to working with government in the future
on similarly successful projects.
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