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Submission on the Smoke-free Environments

(Tobacco Plain Packaging) Amendment Bill

March 2014

Professor Janet Hoek (lead author and contact person for oral submissions)

Emeritus Professor Philip Gendall

Professor Richard Edwards

Professor Julian Crane

Professor Chris Cunningham

Associate Professor George Thomson

Associate Professor Nick Wilson

Dr Ninya Maubach

Dr El-Shadan Tautolo

Dr Richard Jaine

Dr Heather Gifford

Rebecca Gray

Anaru Waa

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Contents

Executive Summary ................................................................................................................................. 1

Submitter Background ............................................................................................................................ 3

Introduction ............................................................................................................................................ 4

Tobacco Packaging as a Marketing Medium .......................................................................................... 6

Symbolic Consumption and “Badge” Products ................................................................................... 7

Primary and Secondary Demand ........................................................................................................ 8

Summary of Research into Tobacco Packaging .................................................................................. 9

Reducing the Appeal of Tobacco and the Acceptability of Smoking .................................................... 10

Communicating Aspirational Imagery to Young People ................................................................... 10

Awareness of Tobacco Brands among Children ............................................................................... 11

Branding and the Development of Attractive Attributes ................................................................. 12

Specific Attribute Connotations ........................................................................................................ 13

Perceived Attractiveness .............................................................................................................. 13

Perceived Quality .......................................................................................................................... 15

Summary: Reducing the Appeal of Tobacco ..................................................................................... 15

Salience of Health Warnings Featured on Tobacco Packaging ............................................................. 17

Effect of Plain Packaging on Warning Label Recall ........................................................................... 17

Effect of Plain Packaging on Warning Label Attributes .................................................................... 18

Potential Benefits of Larger Warning Labels..................................................................................... 18

Tobacco Industry Responses to Pictorial Warning Labels ................................................................ 18

Summary of Plain Packaging and Warning Labels ............................................................................ 19

Reducing Misleading Perceptions of Tobacco Products ....................................................................... 20

Tar and Nicotine Delivery .................................................................................................................. 20

Perceived Harm ................................................................................................................................. 20

Tobacco Company Responses ........................................................................................................... 20

Summary of Plain Packaging and Misleading Perceptions ............................................................... 20

Likely Effects of Plain Packaging ........................................................................................................... 22

Effects of Plain Packaging on the Appeal of Tobacco Products and Smoking .................................. 22

Public Support for Plain Packaging ................................................................................................... 22

Effects of Plain Packaging on Behaviour ........................................................................................... 23

Australian Experience ....................................................................................................................... 23

New Zealand’s International Obligations .............................................................................................. 26

Do Recent or Alternative Policy Changes Obviate the Need for Plain Packaging? ........................... 27

Areas for Further Investigation ............................................................................................................. 28

Dissuasive Sticks ................................................................................................................................ 28

Limiting Variant Names ..................................................................................................................... 28

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More Diverse Warning Messages ..................................................................................................... 29

Salience of Quitline Information ....................................................................................................... 29

Additional Suggestions ...................................................................................................................... 30

References ............................................................................................................................................ 31

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Submission to the Health Select Committee

Smoke-free Environments (Tobacco Plain Packaging) Amendment Bill

Executive Summary

Plain packaging is a scientifically well-supported, logical, proportionate, and important step in

preventing children and young people from experimenting with smoking and becoming

addicted to nicotine. Adoption of this policy would help shift New Zealand closer to the

forefront of tobacco control worldwide. The research evidence on likely impact, tobacco

industry documents, marketing theory, and findings from Australia suggest that plain

packaging will help protect the health of New Zealanders. We consider there are at least five

key reasons why plain packaging should be introduced as soon as possible.

First, evidence that tobacco companies have used on-pack branding to promote smoking as

attractive and aspirational comes from their own internal documents. Packaging’s relative

importance as a marketing medium has increased since traditional mass media

communications have been restricted. Smokers often display packaging conspicuously, by

placing their packs where these can be seen by others, thus non-smokers, including children,

are often exposed to tobacco branding. Allowing this exposure to continue effectively

breaches New Zealand’s obligations under the Framework Convention on Tobacco Control

(FCTC), under which we agreed to introduce a comprehensive ban on all tobacco advertising,

promotion and sponsorship.

Second, experimental studies, branding theory and the tobacco industry’s own documents

provide strong evidence that plain packaging will reduce the appeal of tobacco products and

smoking and increase the noticeability and effectiveness of on-pack pictorial warnings. Plain

packaging is not simply the removal of brand imagery, but the replacement of on-pack livery

with dissuasive colours and larger health warnings. Rather than actively appeal to children and

young people, as is currently the case, dissuasive packaging deters experimentation and the

subsequent addiction and misery that almost invariably results.

Third, plain packaging allows cigarette packs to feature larger pictorial warnings with stronger

visual impact, because distracting brand imagery does not divert attention away from them.

Experimental studies have shown that pictorial warnings have greater salience and impact

when featured on packs from which brand paraphernalia has been removed.

Fourth, plain packaging has the potential to reduce the misleading perceptions of reduced

harm created by some brand variants. The use of colours such as white and silver to connote

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“light” and blue to connote “mild” perpetuates a well-documented deception that has led

some smokers to believe variants packaged in these colours are less harmful than others.

Fifth, despite tobacco companies’ claims that plain packaging would lead to extended

transaction times, the demise of small retailers, and the proliferation of black markets,

Australian experience suggests none of these arguments has any substance. Emerging

evidence from Australia suggests plain packaging has diminished the experience of smoking

and stimulated a large increase in Quitline calls. Both outcomes suggest that plain packaging’s

effects are in the health protecting direction that researchers predicted.

Although the tobacco industry claims that plain packaging should not be introduced because

its effects have not yet been proven, this claim lacks any face validity as it is logically

impossible to evaluate the effects of a policy that has not yet been introduced. Tobacco

companies have consistently opposed other proportionate and effective tobacco control

measures, arguing that these lack an appropriate evidence base. Evaluations of measures they

have opposed, such as pictorial health warnings, reveal they have promoted awareness of

smoking’s harms, stimulated quit-related thoughts, and increased actual quit attempts.

Tobacco companies have a dismal track record in predicting the effectiveness of tobacco

control measures and their assertions about plain packaging should be regarded with

considerable scepticism.

Our conclusions are straightforward:

Research evidence supporting the immediate introduction and implementation of plain

packaging is clear. We do not consider that New Zealand should wait for the outcome of

international litigation over plain packaging, as the tobacco industry have used this tactic

deliberately, to delay adoption of the policy.

Plain packaging is the logical next step in achieving the New Zealand Government’s

objective of achieving a Smokefree Aotearoa /New Zealand by 2025 and meeting its FCTC

obligation to remove all forms of tobacco advertising.

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Submitter Background

The ASPIRE2025 collaboration is a University of Otago Research Theme, recognised for its

research excellence in tobacco control. ASPIRE2025 includes researchers from the University

of Otago, Massey University, AUT University, and Whakauae Research for Māori Health and

Development. Team members represent multiple disciplines, including marketing, public

health, clinical medicine, Māori and Pacific health, and public policy. We have an extensive and

longstanding interest in tobacco control research; within the last five years, we have published

more than 100 peer-reviewed journal articles on tobacco control. Members have given invited

keynote and plenary speeches on tobacco control to national and international audiences.

Our collaboration is the leading New Zealand source of research examining limits on tobacco

marketing and we have undertaken numerous studies evaluating tobacco control policy

options. We have published five refereed journal articles on plain packaging, presented several

papers at international conferences, organised a seminar about plain packaging with a leading

international speaker, and received HRC funding to investigate plain packaging. Team

members have attracted further funding to support tobacco control research from the Royal

Society of New Zealand’s Marsden Fund, the Health Research Council, Heart Foundation,

Asthma Foundation and Cancer Society. We have provided expert advice on tobacco control to

New Zealand Government Select Committees, international governments, and NGOs. Copies

of team members’ curriculum vita are available on request.

We note that this submission draws on knowledge we have gained through research we

undertake in our roles as academics and community researchers and representatives. The

arguments we advance do not necessarily represent official views held by the University of

Otago, Massey University, AUT University, or Whakauae Research for Māori Health and

Development.

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Introduction

The Smoke-free Environments (Tobacco Plain Packaging) Amendment Bill sets out four

objectives that plain packaging is expected to address. These are:

Reducing the appeal of tobacco products and smoking, particularly for young people;

Reducing further any wider social acceptance and approval of smoking and tobacco

products;

Increasing the noticeability and effectiveness of mandated health warning messages and

images, and

Reducing the likelihood that consumers might acquire false perceptions about the harms

caused by tobacco products.

More generally, the government aims to improve public health by:

Discouraging people from taking up smoking or using tobacco products;

Encouraging people to give up smoking and stop using tobacco products;

Discouraging people who have given up smoking, or who have stopped using tobacco

products, from relapsing;

Reducing people’s exposure to smoke from tobacco products, and

Supporting New Zealand to meet its international commitments and obligations under the

WHO Framework Convention on Tobacco Control (the FCTC), particularly in relation to the

guidelines developed to support implementation of Articles 11 and 13 of the FCTC.

Members of the ASPIRE2025 collaboration unanimously support the plain packaging of

tobacco products. Tobacco is a uniquely harmful consumer product responsible for the

premature death of half its long-term users.[1] No other legal consumer product causes such

widespread harm; the research evidence shows smoking harms nearly all body organs and

remains a leading cause of cancer, heart disease and respiratory illnesses.[2] As Hecht notes,

this harm arises because of the unique combination of nicotine and the more than 4000

chemicals contained within tobacco; he writes:

The devastating link between tobacco products and human cancers results from a

powerful alliance of two factors — nicotine and carcinogens. Without either one of

these, tobacco would be just another commodity, instead of being the single

greatest cause of death due to preventable cancer. (p 733).[3]

Of these chemicals, 60 are known or suspected carcinogens, including cadmium and hydrogen

cyanide.[3]

Smoking remains the leading cause of avoidable morbidity and mortality, and of health

inequalities, in New Zealand and is estimated to cause (directly and indirectly) between 4500

and 5000 deaths every year.[4 5] Globally, tobacco use causes more than five million deaths

each year.[6]

New Zealand governments have introduced several evidence-based measures to reduce

smoking prevalence and the harm caused by smoking. Measures introduced in the last 25

years include the Smoke-free Environments Act 1990, which banned tobacco advertising and

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sponsorship and began introducing smoke-free workplaces. Amendments to this legislation

introduced additional workplace smoking bans in 2004; pictorial health warnings in 2007, and

required the removal of tobacco retail displays in 2011. Despite claims by tobacco companies

that each of these measures was unnecessary, lacked supporting evidence, and would be

ineffective, smoking prevalence has reduced significantly over the last two decades.[7]

Tobacco use causes enormous harm to New Zealanders’ health and undermines New

Zealand’s economy; achieving the 2025 goal is crucial to our social, economic and physical

well-being and will require bold interventions. Plain packaging is a logical and evidence-based

extension of existing marketing control policies, which include excise tax increases, enhanced

on-pack warnings, and the expansion of smoke-free places. We consider that the existing

scientific evidence around plain packaging and its likely effects show it is both proportionate

and practical, and very likely to contribute to further reductions in smoking prevalence.

We begin by explaining how on-pack brand imagery functions as marketing and briefly review

the research evidence. We then examine the evidence in relation to each of the four

objectives noted earlier. Finally, we outline New Zealand’s obligations under the FCTC, identify

additional factors that could be included in the Bill and offer conclusions.

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Tobacco Packaging as a Marketing Medium

Marketers have long recognised the power of packaging to influence consumers’ behaviour;

packaging’s soubriquet “the silent salesperson” gives an insight into the effect it can have at

the point-of-purchase.[8] This moniker recognises how packaging functions to capture

attention, both in highly competitive retail environments and in all other settings where

products could appeal to users and potential users.

For products like tobacco, which no longer have traditional broadcast and print media

available, packaging is a pivotal medium that retains tobacco companies’ ability to

communicate directly with existing and future users.[9] In jurisdictions such as New Zealand,

packaging is the only major means tobacco companies have to advertise their products and

encourage experimentation with smoking. Examination of tobacco industry documents shows

that, irrespective of policies that limit traditional media, such as advertising and sponsorship,

packaging enables tobacco companies to promote brand attributes and appeal to potential

new users.[10-12]

Packaging not only maintains communication channels, but promotes a crucial point of

difference that enables consumers to recognise, and affiliate themselves with, different

brands. A Philip Morris document illustrates the tobacco industry’s understanding of

packaging’s role:

“Our final communication vehicle with our smoker is the pack itself. In the absence

of any other Marketing messages, our packaging -- comprised of the trademark,

our design, color and information -- is the sole communicator of our brand essence.

Put another way -- when you don't have anything else -- our packaging is our

Marketing.”[13]

Evidence from industry documents also reveals the meticulous care tobacco companies have

taken to research their brands’ packaging.[11 14] The colours, imagery, logos, fonts, sheen and

texture that constitute tobacco packages are carefully tested to maximise the appeal of

packaging to specific audiences.[15] The resulting brands exemplify aspirational attributes,

such as glamour and sophistication, or ruggedness and masculinity.[15 16]

Brand imagery creates rich symbolic meanings and then links these aspirations, attributes and

values to functional products and services; these relationships mean consumers buy branded

products as much for their symbolic value as for their utility.[17 18] This process is evident

from tobacco brand names such as Holiday – an evocative name for a lower price point brand

that represents the time out that smoking breaks provide for lower income smokers. Similarly,

Horizon connotes the realisation of dreams that might seem beyond a lower income smoker

who has fewer qualifications or career prospects.

Brand names, and the on-pack livery that reinforce these, offer opportunities and provide

important and valued distractions that offer respite from the banality of everyday life.

Consuming a given brand therefore provides users with a conduit to its specific attributes and

explains why tobacco brands are regarded as “badge” products that smokers use to construct

and project a social identity.[14] Packaging is pivotal in conveying these desirable attributes,

enhancing the appeal of smoking, and encouraging experimentation.

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Symbolic Consumption and “Badge” Products

Theories of symbolic consumption explain how brands exert a powerful influence on

consumers’ behaviour. The associations and images that physical brand insignia give rise to

have become critical points of differentiation for tobacco products, which are functionally

similar and so rely on emotional and symbolic attributes for their appeal.[16] More specifically,

consumers use physical brand attributes to construct imagery that they draw on and

personalise, and use to co-create an identity they project to others.[19] Consumers actively

construe brand insignia using a reflexive process in which they simultaneously define the

imagery, and then use it to define themselves.[20]

This identity creation process enables tobacco manufacturers to sell status, social acceptance,

glamour, and adventure, rather than a mere nicotine delivery device.[15 16 21] Young people

place particular value on brands’ symbolic properties and use them to construct social persona

that they then communicate to their peers. [22-24]

Internal tobacco industry documents reflect a deep understanding of symbolic consumption

and reveal detailed research into pack designs, brand insignia, and images, and consumers’

responses to these marketing stimuli.[11 16 25 26] Furthermore, these documents highlight

the importance the tobacco industry places on young adult smokers and the need for brands

that appeal to this group’s uncertainties and aspirations.[27]

Industry documents also make it clear that packaging functions as a powerful and persistent

form of advertising to smokers and others in their vicinity. A Brown and Williamson employee

stated:

“… if you smoke, a cigarette pack is one of the few things you use regularly that

makes a statement about you. A cigarette pack is the only thing you take out of

your pocket 20 times a day and lay out for everyone to see. That’s a lot different

than buying your soap powder in generic packaging.”[28]

What Effect Does Tobacco Branding Have?

Branding, now communicated via packaging alone in New Zealand, continues to perform

important roles for tobacco companies. Attractive imagery and aspirational brand names, such

as those discussed above, create the impression that smoking is less harmful and more normal

than is the case. There are striking and anomalous differences between tobacco branding and

marketing and the branding and marketing of other toxic products such as poisonous

chemicals. The latter have a distinct lack of brand imagery so the potential harm of the

product is clearly communicated while warning labels are highly visible and undiluted by

competing pack imagery. The fact that tobacco, a product responsible for around 5000 New

Zealanders’ deaths every year, continues to use evocative imagery is illogical and inconsistent

when compared to other harmful products.

There is strong evidence that exposure to tobacco branding stimulates cravings among those

smokers who are attempting to become smoke free.[29] In New Zealand research, a former

smoker described the experience of seeing “his” brand thus:

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There’s a connection made, you know, between observing, seeing the packet, and

then knowing what the packet feels like. And then you can start by getting

warmed up about opening the packet and smelling the cigarettes and lighting one

up and what that means for you. And, you know, there’s whole number of

connections that are made. It’s advertising. (p.336).[30]

These reflections are not unique to New Zealand smokers; a participant in a recent Norwegian

study of tobacco branding and plain packaging summed up the role branding plays in smoking

initiation:

“It’s like, if I see someone smoking white Kent, and another smoking Teddys, then I

see the difference. It says something about the person. I’m thinking, you start

using a brand because you feel you belong to it, that you’re connecting with it. It

has something to do with the logo, I think.”[31]

Many smokers report their first experience of smoking as distasteful and even unpleasant.

They continue to experiment, at least in part, because of the “coolness” they associate with

smoking, a perception that is directly linked to the appeal of the package and the social

prestige and status this confers on them. Specific design features resonate with smokers and

enable them to construct and communicate the social identities they value, following the

process outlined above. Innovations in pack design, such as “lipstick” packs (targeted

specifically at young women), wallets and slide-opening packs reinforce these positive brand

impressions and provide additional reasons for smokers to draw on “their” brand when

representing themselves to others.

Primary and Secondary Demand

Tobacco companies reject much of this evidence, at least in their public proclamations, and

hold to the view that on-pack imagery fosters brand recognition, enables smokers to

differentiate between brands and promotes brand switching among adult smokers. However,

research evidence, as well as the industry’s own internal documents, question the claim that

branding simply stimulates brand switching and alters secondary, not primary, demand.

First, research shows that brand switching is rare, as smokers show unusually high levels of

brand loyalty; indeed, despite being exposed to numerous brands, many consume only one

brand (that is, they are sole brand loyal)[32] and any brand switching that does occur is at

much lower levels than other fast-moving consumer goods.[33] Second, because smoking kills

half its long term users, the tobacco industry’s long term survival requires on-going

replenishment of its customer base. That is, to maintain business as usual, tobacco companies

must replace those smokers who die prematurely of their addiction (i.e., before they deliver

maximum profit). To grow the overall market size, tobacco companies must recruit new users

at a faster rate than existing users die.

Tobacco companies must therefore generate primary demand (i.e., recruit new users) or face

the prospect that their market will steadily decline. Evidence from tobacco industry

documents reveals two crucial points. First, how acutely aware tobacco companies are of this

reality. Second, their dependence on packaging to attract new users, especially in markets

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where other promotion options have been curtailed.[34] Industry documents reveal the

crucial importance of attracting new smokers; a document from RJ Reynolds adduced in the

Mangini case states:

“Younger adult smokers have been the critical factor in the growth and decline of

every major brand and company of the last 50 years. They will continue to be just

as important to brands/companies in the next 50 years for two simple reasons:

The renewal of the market stems almost entirely from 18-year-old smokers. No

more than 5% of smokers start after age 24;

The brand loyalty of 18-year old smokers far outweighs any tendency to switch

with age.”[35]

Quotes such as these, which are evident in other documents housed in the Legacy Collection

(a repository of over 70 million formerly secret tobacco industry documents), confirm that

tobacco packages are designed to appeal to potential purchasers, including young people who

may not yet be smoking, but who could become attracted to it, and seriously question the

tobacco industry’s proclaimed focus on brand-switching.

Summary of Research into Tobacco Packaging

Evidence from industry documents, marketing theory, and empirical studies, clearly

demonstrate that tobacco packaging functions as a marketing medium and communicates

aspirational and attractive brand attributes. On-pack branding works in many ways; it reduces

the perceived risk of smoking by making tobacco appear just like any other product, it deflects

attention from warning labels, conveys desired imagery, and induces lapsing among smokers

trying to quit.

Attractive on-pack attributes help tobacco companies recruit the new users they require to

survive as commercial businesses. Tobacco industry claims that on-pack branding does

nomore than stimulate brand-switching lack empirical support and overlook the imperative all

tobacco companies have to attract new smokers.

In an environment where other marketing media are no longer available, the tobacco

industry’s own documents reveal the pivotal importance tobacco packaging has assumed.

Plain packaging would remove this last bastion of tobacco marketing.

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Reducing the Appeal of Tobacco and the Acceptability of Smoking

In this section, we examine in more detail how tobacco companies have used the marketing

tools at their disposal to promote tobacco and smoking to young people, a crucial market they

must access to ensure their long-term survival. We focus in particular on packaging, which is

the only mainstream medium still available to tobacco companies operating in New Zealand,

and explain how introducing plain packaging would contribute to reducing the appeal of

tobacco, and approval of smoking, particularly with respect to young people.

Communicating Aspirational Imagery to Young People

Tobacco companies have long recognised the importance of focussing on young people as the

next generation of smokers. New recruits are vital to replace those smokers who die

prematurely from smoking and thus ensure the on-going profitability of tobacco companies’

business. Evidence from modelling studies demonstrate that, in order to reduce and maintain

very low levels of smoking prevalence long term, reductions in smoking uptake must occur as

well as substantial increases in quitting among current smokers. [36]

Very marked declines in regular smoking among New Zealand children have occurred; 2013

data show smoking prevalence is less than 4% among 14-15 year olds. However, smoking

among young adults has declined only very slowly, suggesting that substantial uptake of

smoking is continuing at a later age. Thus in the New Zealand Health Survey daily smoking

prevalence among 18-24 year olds in 2006/7 and 2011/12 was virtually unchanged at 24.6%

and 24.3% respectively. This finding is further supported by longitudinal data that shows

smoking uptake is common among young adults up to 25 years, and thereafter rare. [37]

Analysis of industry documents has revealed how sophisticated the marketing strategies used

to target youth and young adults are. Following an analysis of formerly secret industry

documents, Ling et al. wrote:

We analyzed the documents to find why and how the tobacco industry markets to

young adults and drew three conclusions. First, the industry views the transition

from smoking the first cigarette to becoming a confirmed pack-a-day smoker as a

series of stages (28–30) that may extend to age 25, (31) and it has developed

marketing strategies not only to encourage initial experimentation (often by teens)

but also to carry new smokers through each stage of this process. (28, 32–36)

Second, industry marketers encourage solidification of smoking habits and

increases in cigarette consumption by focusing on key transition periods when

young adults adopt new behaviors—such as entering a new workplace, school, or

the military–and, especially, by focusing on leisure and social activities. (33,37,38)

Third, tobacco companies study young adults' attitudes, social groups, values,

aspirations, role models, and activities and then infiltrate both their physical and

their social environments. (37,39–43).[27]

Tobacco companies have ensured they are intimately acquainted with young people’s

uncertainties, concerns, transition times and goals. They have used this knowledge to create

brands that target each of these life phases, provide reassurance about anxieties, and ease

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transition times. A chart taken from RJ Reynold’s planning documents reveals how tobacco

brands targeted each life stage, from recruiting new smokers to deterring long-term smokers

from quitting:

Figure 1: Chart from RJ Reynolds Documenting Brand-Life Phase Relationships

Source: Ling et al.[27]

Awareness of Tobacco Brands among Children

Analysis of a 2004 Health Sponsorship Council national survey of 10 and 11 year old children

currently being undertaken at the University of Otago also illustrates the impact of tobacco

packaging on children and lends further support to plain packaging. Top line results indicate

that for three tobacco brand names 25%, 40% and 54% of 10-11 year old children already

recognised that these brands were related to smoking. This finding was likely due to tobacco

product packaging exposure, as, by 2004, all tobacco advertising and sponsorship had been

banned for around a decade. The proportions of children correctly identifying specific tobacco

brands were mostly aligned to the market share of those brands in 2004, supporting the

inference that exposure to packs was a key cause of the high awareness for tobacco brands

levels observed. For example, the most commonly identified brand (Holiday, 54% correctly

identified) was also the brand with the highest market share. In addition, those children who

had parents or caregivers who smoked were more likely to correctly identify five out of six of

the tobacco brands as related to smoking (e.g. 62% vs 44% for Holiday).

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While part of the impact of tobacco product packaging in 2004 was likely to be through point

of sale tobacco displays (still present at the time), the finding of greater awareness among

children where one or more parent smoked suggests that exposure to packs outside of the

retail setting was a major influence on levels of tobacco brand awareness. Plain packaging

would minimise exposure to tobacco pack imagery and brand names that occurs despite retail

display restrictions, thereby reducing development of the positive attribute associations that

make tobacco products appear appealing and encourage smoking.

Branding and the Development of Attractive Attributes

On-pack tobacco imagery positions tobacco brands and smoking as attractive, normal and

desirable. Branding also creates and promotes desirable attributes that young adults draw on

when developing and communicating their own social identity. [20] Young people’s use of

brand imagery to construct their public persona first stimulated interest in plain packaging

nearly two decades ago when Canadian and New Zealand researchers independently

examined how young people perceived plain packaging.[38] Researchers reported that young

people had consistently more negative impressions of plain packs relative to branded cigarette

packs.[39] These findings are consistent with international research, which concluded that

adolescent and young adult respondents regarded plain packages as old fashioned and boring,

and thought fewer people would smoke if cigarettes were sold in plain packages.[40-42] Since

these initial studies, several projects, using different methods and different samples, and

conducted in different countries, have concluded that reducing on-pack brand insignia would

diminish the physical and social attractiveness of tobacco products and smoking, promote

cessation among some smokers, and reduce initiation among those experimenting with

tobacco.[43-46]

Our recent New Zealand studies confirm these findings and lend further support to the

conclusion that packaging functions as advertising in developing positive brand attributes that

facilitate smoking initiation and foster continued smoking. Using in-depth interviews and focus

groups conducted with young adult smokers and non-smokers, we found that tobacco brand

imagery appealed to young adults while plain packaging rendered tobacco products dull and

unattractive.[20 47 48] In a study examining brand-attribute associations, we found

participants associated distinctive attributes with tobacco brands on the basis of packaging

alone, and irrespective of their past exposure to the brand. That is, even with no smoking

history and no knowledge of the brand shown, participants could easily construct an identity

for the type of person to whom the brand would appeal.[21] [48] Indeed, and contrary to our

expectations, we found non-smokers made more favourable brand-attribute associations than

smokers. However, both groups described Basic, a near generic brand, as ‘plain’ or ‘budget’,

with no attractive features.[48] These studies provide further evidence of packaging’s role in

communicating attributes that enhance the appeal of tobacco brands and illustrate how

removal of these attributes elicits negative associations. Figure 2 below illustrates the diverse

attributes young adult smokers and non-smokers associate with tobacco brands on the basis

of their packaging alone. Figure 2 also shows the location of the near generic brand (Basic)

located in the bottom right quadrant, away from other brands and linked to the “plain” and

“budget” attributes.

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Figure 2: Smokers’ and Non-smokers’ Brand Attribute Associations Following Exposure to

Tobacco Packaging

Source: Gendall et al.[47]

Specific Attribute Connotations

Several studies have examined the attributes connoted by packaging and explored the

influence these may have. These attributes include perceived attractiveness and product

quality.

Perceived Attractiveness

Researchers have examined the effect progressive removal of branding components has on

perceptions of the packs featured, the experience of smoking a cigarette from those packs,

and assumptions about the individuals who would purchase those packs. Australian studies

with adults and adolescents found that as packs became plainer (i.e., had progressively fewer

brand elements), participants were significantly less likely to rate these as attractive relative to

a fully branded pack.[45 46] A study of adolescent and young adult women in Brazil reached

similar conclusions and found that pack appeal declined as branding elements reduced; plain

packs were significantly less appealing and cigarettes from these were less desirable to be

seen smoking relative to sticks from branded packs.[49] Recent studies using EU,[50-53]

UK,[54] NZ,[20 47 48] and US,[43 55] samples have all consistently found that plain packages

are seen as less attractive and less appealing than branded packs.

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Many of the studies cited above have explored how participants perceive packs, either using

criteria provided by the researchers or by exploring perceptions using unstructured interviews.

These studies have been criticised for failing to provide insights into behavioural outcomes.

New Zealand research we conducted therefore used a different method to estimate young

adult smokers’ choice behaviours.[56] Like the other studies, we manipulated the level of

branding present; we also manipulated the size of the health warning shown on each pack.

Participants viewed cards containing four pack options and selected the one they would be

most likely to choose and the one they would be least likely to choose, if they were purchasing

tobacco. Plain packs with large health warnings were significantly less likely to be chosen than

fully branded packs with smaller warnings.

A novel UK line of research has also taken a more behaviourally-oriented approach and used

naturalistic methods to examine smokers’ experiences of smoking cigarettes from a plain

pack.[57 58] Moodie and colleagues found that the young adult smokers who participated in

their study rated plain packages significantly more negatively than their own brand on the

following dimensions: stylishness, fashionability, coolness, attractiveness and appeal. Another

behavioural study used an experimental auction to estimate the likely price respondents

would pay for packs featuring different levels of branding and found fully-branded packs were

more highly valued (i.e., attracted a higher price) than plain packs.[55]

Studies that did not involve comparisons of plain and branded packaging have found that plain

packs are regarded as unattractive, uncool, and likely to be smoked by unpopular people.[54]

Research focussing on specific populations groups, such as young women, also concluded that

plain packs were significantly less appealing than branded packs.[44 59]

Qualitative studies have consistently concluded that plain packaging is less appealing than

branded packaging. Negative feelings generated by plain packaging lead smokers to feel less

attached to their brand; as one participant in a UK study noted:

Everybody has a cigarette they smoke, a brand they like in their own packet. It [plain

packaging] takes away the identity of it and makes it a little bit less appealing. [60]

Not only does plain packaging take away the identity created through branding, it replaces

that identity with negative connotations. Our research found that plain packaging removed

the glamorous connotations that disguised the harm caused by smoking, and exposed tobacco

as the toxic and pernicious product it is:

“It looks so boring and…you sort of see the cigarette for what it is…They just look

kind of very plain and filthy sorts of things”.[20]

Smokers lost the cultural cachet they gleaned from branding:

“It loses that whole alternative explanation for being, like looking trendy or cool. . .

. It just presents you as, ‘I’m smoking because I’m addicted.’”[20]

As well as the general finding that plain packaging is consistently seen as less attractive and

less appealing than branded packaging, research also shows that the attributes associated

15

with plain packages are repeatedly more negative than those associated with branded

packaging. Importantly, smokers of plain packages are regarded as less sociable, less trendy

and less mature, perceptions that became consistently more negative as the packaging shown

had fewer branding elements.[46] Several other studies report similar findings: plain packaging

elicits fewer positive attribute associations and more negative attribute associations than fully

branded packaging.[44 45 61]

Those studies that examined the perceived effects of plain packaging on smokers and non-

smokers found that non-smokers and intermittent smokers were more likely to find plain

packaging dissuasive than regular smokers. Although all groups found plain packaging less

appealing than branded packs, regular smokers generally reported that their addiction would

lead them to continue purchasing tobacco, though plain packaging would diminish their

experience of smoking. By contrast, intermittent smokers thought plain packaging would lead

them to quit smoking and non-smokers felt they would be even less likely to experiment with

smoking. This evidence suggests plain packaging will decrease smoking initiation,

experimentation, and subsequent addiction among young people. It will increase the

dissonance many addicted smokers already feel and, for some, may be a trigger to quit.

However, its primary benefit will be in reducing youth initiation.

Perceived Quality

Researchers have also examined how pack appearance generates connotations regarding

product quality. Qualitative research examining dark brown pack colours found these elicited

strong negative perceptions; participants associated the packs with excrement and dirt,

among other things.[60] Even studies conducted prior to the Australian legislation, where the

stimuli used were often other than a dissuasive dark brown or green colour, found packages

that had no branding present elicited negative quality connotations and were associated with

cigarettes regarded as less satisfying, of lower quality, and likely to have a reduced flavour.[45

46 49] Other studies exploring taste perceptions in more detail reported that cigarettes in

plain packs were perceived as “worse tasting” than those in branded packs.[59] Evidence from

a naturalistic study found cigarettes from plain packages were regarded as of poorer quality

than those from branded packs.[60]

Summary: Reducing the Appeal of Tobacco

Our considered view is that there are three key reasons why young people require protection

from tobacco marketing, including the marketing messages conveyed via on-pack branding.

First, there is now a detailed body of research that illustrates the attractive attributes brand

imagery communicates and the fact young people find these attributes highly desirable.

Second, there is clear evidence from the tobacco industry’s own documents that tobacco

companies have deliberately and systematically used marketing to recruit new smokers. Third,

removing brand imagery from tobacco packaging not only eliminates this source of social

cachet but diminishes the experience of smoking.

Several studies have now examined the effect plain packaging would have on the overall

appeal of smoking and perceptions of smokers. Irrespective of the methods used, the research

findings are highly consistent: plain packaging sharply reduces the appeal of tobacco brands.

16

Studies undertaken with young people conclude they associate plain packaging with negative

connotations, which they are unwilling to draw on when creating their own social identities.

Instead of providing young people with access to aspirational attributes, plain packaging

actively detracts from their identity and reduces their perceived experience of smoking.

In summary, the evidence to date strongly supports the proposition that plain packaging will

reduce the appeal of tobacco products and approval of smoking; these effects are likely to

be particularly evident among young people.[62]

17

Salience of Warnings Featured on Tobacco Packaging

The second key argument supporting plain packaging is that it will enhance the visual impact

and effect of on-pack warnings. There is clear evidence that pictorial warnings elicit stronger

responses than text-only warnings.[63] Research has shown pictorial warnings promote

awareness of smoking’s harms, stimulate quit-related thoughts, and increase actual quit

attempts.[64-68] Given the evidence that pictorial warning labels are more effective than text-

only warnings, it is logical to assume that removing visual clutter, such as branding, that

competes for attention would further improve the impact of warning labels.

Early studies into plain packaging and warnings, including New Zealand research, supported

this proposition and concluded that removing brand imagery would increase the impact of

health warnings.[39 41] Since this early work, several studies have compared text-only and

pictorial health warnings (see Hammond for a review of this work).[63] Plain packaging’s

relative recency means fewer studies have examined how it would affect the recall and

salience of pictorial warnings. We summarise and discuss some key findings below and

examine attributes of pictorial warnings and the effect plain packaging has on warning recall

and other responses.

Hammond’s comprehensive review of tobacco warning labels reported several findings

relevant to plain packaging.[63] He concluded that the salience of pictorial warnings depends

on their size and position and found:

“Youth and adults are more likely to recall larger warnings, rate larger warnings as

having greater impact, and often equate the size of the warning with the

magnitude of the risk.” (p. 3 online version).

Importantly, Hammond noted graphical features that differentiated the warning message

from the pack design increased the impact of the warning. He examined techniques such as

using boxes around the warning to create a visual demarcation between the warning and

brand elements. These findings can be logically applied to plain packaging, where perimeters

will no longer be required to distinguish the warning from the brand. Further, plain packaging

provides a natural opportunity to introduce much larger warning labels so that these, rather

than alluring branding, dominate pack surfaces.

Effect of Plain Packaging on Warning Label Recall

Studies examining the salience of warning labels on plain packages have used varied

approaches. One that varied pack colour and branding (white, grey, brown or branded pack)

and found that the warning label was significantly more prominent in the plain pack

conditions, while the brand name was significantly less prominent.[69] A cross-sectional study

conducted in Australia compared warning recall after participants had viewed one of four

packs that varied in its branding level and warning size.[45] Although this study did not report

differences between the branded and plain packs, the use of an existing, and high impact,

warning is likely to have confounded the study and inflated recall across all conditions (thus

reducing the likelihood of differences emerging between conditions).

18

Effect of Plain Packaging on Warning Label Attributes

The debriefing of participants in a naturalistic study explored the seriousness, salience and

believability of warning labels.[57] Although this phase of the study had a low response rate,

of those respondents who did participate (approximately a third of the original 140), most

reported that the warnings shown on plain packages were more salient and they viewed these

as more serious, than when the same warnings were shown on branded packs. However, the

perceived believability of the warnings did not differ across pack conditions.

Qualitative studies examining warning labels generally report that the removal of branding

paraphernalia from packaging reduces the visual clutter present, thus making warning labels

more salient. Further, the reported dullness of plain packaging also generally enhances the

seriousness and believability of the warnings.[53]

Potential Benefits of Larger Warning Labels

Recent evidence shows that warning labels help prevent relapse among smokers who have

become smokefree[70] (this effect is likely to be enhanced when warning labels are supported

by strong mass media campaigns[71]). Because pack warnings will be visible in situations when

smokers might be tempted to resume smoking (such as social settings where alcohol is being

consumed),[72] it is important that they are as visually impactful and salient as possible to

reduce the risk of relapse. As plain packaging enhances the visual impact of warnings, it is

logical to infer that it will also help prevent relapse among smokers who might otherwise

resume smoking.

Tobacco Industry Responses to Pictorial Warning Labels

International evidence suggests tobacco companies are using pack innovations to attract

attention and interest, and prompt experimentation. A recent Australian study found bevelled

and rounded pack shapes were seen as most attractive (more attractive than standard square

cornered packs).[73] The bevelled shape was also seen as more distracting to pictorial

warnings, particularly relative to the square shaped packs. UK research has also highlighted

the specific appeal particular pack designs have, notably the “perfume” shaped packages

designed to attract young women.[60]

Comments on packaging websites also provide insights into how tobacco companies are using

pack designs to reduce the impact and effect of pictorial warnings. One commentator

compared:

“Plain white cartons with horrendous graphics popping off the packs [with] high-

technology printed beautiful cartons, which without doubt will soften the impact

of the same horrendous graphics.”[74]

Evidence presented in a recent ASPIRE2025 seminar showed how pack designs extended into

health warnings so these were less obvious and appeared to merge into the brand design.

Figure 3 below illustrates this phenomenon.

19

Figure 3: Example of Reduced Impact Health Warnings

Source: Wakefield, M. ASPIRE2025 presentation, 18 September, 2012.

Evidence that tobacco companies are using brand imagery to reduce the visual impact of on-

pack warnings provides further justification for plain packaging and much larger health

warnings. Dissuasive backgrounds could not visually merge with health warnings and larger

warnings would dominate the pack surface, thus maximising the attention paid to the

messages featured, and the potential influence these could exert.

Summary of Plain Packaging and Warning Labels

Logically, the more warnings stand out, the higher the recall levels they will generate. The

relative recency of pictorial warning policies and plain packaging proposals means the body of

research examining how plain packaging will affect warning label salience is more limited.

There is very strong evidence that pictorial elements increase the salience and impact of

warning labels.[64 75] Studies conducted thus far suggest removing competing visual elements

in the form of brand imagery and logos will further enhance the impact of pictorial warnings.

Evidence that the tobacco industry has deliberately introduced pack designs using similar

colours to those shown in some warnings suggests an attempt to dilute warning label

effectiveness. Plain packaging would eliminate this opportunity to dilute warning labels’

effectiveness by providing a non-distracting canvas on which larger warnings could be

displayed.

20

Reducing Misleading Perceptions of Tobacco Products

Since regulations restricting the use of misleading descriptors such as “light” and “mild”,

tobacco companies have turned to colour to evoke erroneous “reduced harm”

connotations.[76-78] Red is widely used to suggest a “full strength” variant, blue indicates a

“mild” option, while white and silver connote “light” and “extra light”, respectively.

Several studies have examined how tobacco branding has created misleading perceptions

about the harms caused by tobacco products. This deception has occurred in two ways: first,

through the use of misleading variant names, particularly “light” and “mild” and, second, by

exploring perceptions of colours used on packaging. Studies have typically shown participants

different pack images and asked them to estimate the tar and nicotine a cigarette from these

packs would deliver; in addition, they have explored the relative perceived harm respondents

associate with cigarettes from plain and branded packs. Again, because interest in plain

packaging has re-emerged comparatively recently, fewer studies examining harm perceptions

have thus far been reported.

Tar and Nicotine Delivery

Darker coloured packs were typically associated with increased tar and nicotine delivery, [59]

although white plain packs did not differ significantly from fully branded packs in this

respect.[43 44] This is an important finding because it illustrates the importance of replacing

branding with a dissuasive colour. Replacing branding with a colour, such as white or grey,

which tobacco companies have already conditioned smokers to associate with reduced harm

products, risks perpetuating the incorrect belief that lighter coloured packs are less harmful

than those featuring darker colours.

Perceived Harm

As noted earlier, the varied pack colours used in plain packaging studies appears very likely to

have influenced study outcomes, particularly given tobacco companies’ use of colour to create

specific variant connotations. In general, studies using darker pack colours elicited stronger

perceptions of harm while lighter coloured packs were seen as less harmful.[43 46 59 69 78]

Tobacco Company Responses

Since the introduction of plain packaging in Australia, some tobacco companies have

introduced more detailed and evocative variant names.[79] These have the potential to re-

create the connotations formerly generated by on-pack branding and merit further analysis

since they represent a potential loop-hole (see section on Additional Measures below).

Summary of Plain Packaging and Misleading Perceptions

Evidence tobacco companies have obfuscated information that might reveal the nature and

extent of harm caused by smoking is well documented.[80] Several studies have examined the

effects coloured packaging and variant descriptors have on perceptions of harm and

consistently report that variant names, and the use of colours to connote variants, have

generated and supported mistaken beliefs about the relative harms of different tobacco brand

21

variants. Plain packaging would eliminate the explicit use of colour to create misleading

perceptions, while stricter regulations regarding the use of variant descriptors would eliminate

another strategy used to promulgate deceptive beliefs about harm.

22

Likely Effects of Plain Packaging

The research evidence suggests plain packaging will reduce the appeal of tobacco products

and smoking, impede smokers’ ability to draw on brand attributes as they construct their own

social personae; influence their smoking and cessation behaviour, and be important in

addressing health inequalities. We examine each of these factors below.

Effects of Plain Packaging on the Appeal of Tobacco Products and Smoking

Research examining the attractiveness of tobacco branding and the effect plain packaging has

on perceptions of pack attractiveness has consistently found that progressive removal of

brand elements results in predictable declines in perceived pack attractiveness.[45 46 56 81]

Irrespective of whether studies measure attribute associations, choices or evaluations of

actual experiences, the conclusions reached have been identical: plain packaging reduces the

appeal of tobacco products and diminishes the experience of smoking.

Public Support for Plain Packaging

In a 2012 study, we found strong public support for plain packaging:

“Although tobacco companies question the benefits of plain packaging, New

Zealanders strongly support this measure and believe attractive packaging

encourages smoking experimentation among young people. Respondents

supported suggestions that tobacco products should feature large warnings and

were not persuaded by industry arguments that plain packaging misappropriated

their intellectual property” (p.406).[82]

The 2012 Health and Lifestyle Survey found 72% of New Zealanders supported plain packaging

and only 17% opposed it (including 49% support even among smokers). [83]

Research examining adolescents’ (aged 14-15 years) support for plain packaging using ASH

Year 10 data found support had increased over time and by 2012, there was majority support

for plain packaging among all ethnicities. Figure 4 below outlines the trends in support over

time.

23

Figure 4: Adolescents’ Support for Plain Packaging 2009-2012

Plain packaging is a well-supported measure and we expect support to increase post-

implementation, as has been the case with other tobacco control measures (such as the

implementation of smoke-free bars and restaurants). Importantly, support comes not only

from adults, but from the young people who will be the primary beneficiaries of the smoke-

free 2025 goal.

Effects of Plain Packaging on Behaviour

New Zealand research has used a choice-based methodology to estimate the effects of

progressive reductions in brand elements and employed a probability scale to estimate the

likely effects on cessation related behaviours.[56] The findings suggest plain packaging would

significantly increase the likelihood that smokers will seek support to quit, reduce the number

of cigarettes they smoke, and make a quit attempt. A European study supports these

conclusions and found that plain packages were seen as most likely to promote cessation

among smokers who intended to quit.[84]

Naturalistic research assessing smokers’ responses to plain packaging reported that plain

packaging increased the likelihood smokers would avoid displaying tobacco packaging (either

by hiding or covering the pack). [85] In addition, plain packaging stimulated other cessation-

linked behaviours, such as forgoing cigarettes and smoking less around others, and increased

thoughts about quitting. In reporting on the longitudinal International Tobacco Control (ITC)

study, Borland had earlier found these latter behaviours predictive of quit attempts and

subsequent cessation.[86]

Australian Experience

Plain packaging was implemented in Australia in December 2012; initial evidence allows

preliminary conclusions with respect to its effects on the appeal of smoking, retailing,

cessation and illicit trade.

24

A study conducted during the phase-in of plain packaging found the policy detracted from the

experience of smoking. Smokers who were using tobacco from plain packs were more likely

than those still using branded packs to perceive their cigarettes as of lower quality and

delivering less satisfaction. Smokers using plain packs were also more likely to be thinking

about quitting and they were more supportive of the plain packaging policy.[87] A second

study, also conducted prior to the full implementation of plain packaging, examined lower

income smokers’ perceptions of this policy. Those exposed to a plain pack treatment gave

significantly lower ratings when assessing positive pack, smoker, and taste characteristics,

though there were no significant differences for negative smoker characteristics or harm

perceptions. However, those exposed to branded packaging had significantly higher odds of

purchasing than those who viewed a plain package.[88] The authors concluded that plain

packaging could reduce positive perceptions of tobacco packages among a group of very socio-

economically disadvantaged smokers.

Philip Morris International commissioned a report by a UK consultancy that administered:

“online questionnaires through a number of local suppliers in possession of Australian panels of

potential respondents at various points before and after the introduction of plain packaging”

(p. 1) [sic].[89] The report concluded that smoking prevalence had not declined, despite plain

packaging and the “increase in the noticeability of the new health warnings” (p.1). However, a

review undertaken by the Cancer Council Victoria documents several deficiencies in the PMI-

commissioned study, not least of which was the assumption that plain packaging should result

in rapid declines in smoking prevalence among heavily addicted smokers.[90]

Tobacco companies and retailers’ associations have claimed that plain packaging would

increase the transaction time of tobacco purchases. Studies examining this proposition have

reported quite different conclusions. An experimental study concluded prior to the

implementation of plain packaging tested the time taken to retrieve either plain or branded

cigarette packages from a display stand containing 50 different brands.[91] Contrary to

industry arguments, the authors reported that the average transaction time was significantly

faster when participants were required to retrieve plain, rather than branded, packs. Further,

those selecting from plain packs made significantly fewer selection errors than those choosing

from branded packs. Research undertaken prior to, during and post- plain pack

implementation time recorded and then compared pack retrieval times.[92] Retrieval times

during the phase-in did not vary from the first baseline period, though were slower than the

second baseline period. However, these differences disappeared by the second week of

implementation and remained at pre-implementation levels three months post-

implementation. The authors concluded there was no evidence that transaction times had

increased as predicted by tobacco companies and retailer groups.

One study has reported on a time-series analysis examining calls to the Quitline prior to and

following the introduction of plain packaging. [93] The authors reported a 78% increase in calls

to the Quitline following implementation of plain packaging; the analyses were adjusted for

seasonal trends, smoke-free and cessation advertising campaigns, price and smoking numbers.

This increase paralleled that observed following the introduction of pictorial warning labels,

although the study found that plain packaging has had a more sustained effect.

25

Tobacco companies have frequently claimed that plain packaging will increase illicit trade in

tobacco, leading to a loss in legitimate government revenue.[94 95] A UK analysis found

industry claims of increased illicit trade were inconsistent with both historical trends and

recent data, and questioned the validity of the surveys presented by tobacco companies.[95]

In October 2013, BAT Australia released a report commissioned from KPMG that used a

consumer survey and analysis of empty packs to assess the size of the illicit tobacco market.

The study concluded that illicit consumption had increased from 11.8 percent to 13.3 percent

in the year up to June 2013.[96] Quit Victoria and Cancer Council Victoria prepared a detailed

analysis of the KPMG report and outlined several limitations including the survey

representativeness, accuracy of response categories provided to respondents, and the

calculations presented.[97] In addition, the review queried the pack analysis methodology and

noted several factors that limited the approach taken in the KPMG report. Overall, the review

concluded that the total market for illicit tobacco was likely to be substantially smaller than

that estimated by KPMG.

The multi-national tobacco industry’s record of deceiving governments and citizens is evident

from industry documents and has been documented in several academic studies.[98 99] More

recently, Judge Gladys Kessler, who presided over the case taken by the US Department of

Justice against tobacco companies, found these companies had: “violated the civil provisions

of the Racketeer Influenced and Corrupt Organizations Act (“RICO”) by engaging in a massive

conspiracy to defraud the public by knowingly producing dangerous and addictive products

and misleading the public about the risks associated with these products” (reported, p.1)

[100].

The comprehensive examples of deceptive conduct outlined in Judge Kessler’s findings suggest

tobacco companies’ assertions cannot be relied upon. A recent study by Ulucanlar et al.

analysed tobacco companies’ submissions on UK proposals to introduce plain packaging; the

research reviewed critiques of the scientific public health evidence contained within industry

submissions. The authors found that:

“The companies submitted a very large volume of evidence, reported studies in an

inaccurate and misleading fashion, and sought to diminish the value and

exaggerate the shortcomings of studies by using mimicked scientific critique.”

(p.11)[101]

They went on to state:

“In formulating their response to the stakeholder consultation on SP, the tobacco

companies reframed prevailing scientific norms and practices as somehow

substandard and corrupt, seeking to impress on policy makers their own—

distorted—interpretation of science and the scientific method.” (p.11)[101]

We urge the Health Select Committee to assess tobacco industry submissions in the context of

the RICO findings and in the light of Ulucanlar et al.’s conclusions.

26

New Zealand’s International Obligations

New Zealand is a signatory to the Framework Convention on Tobacco Control (FCTC), which

defines tobacco advertising and promotion and states:

Article 1 (c): “tobacco advertising and promotion” means any form of commercial

communication, recommendation or action with the aim, effect or likely effect of promoting a

tobacco product or tobacco use either directly or indirectly.”

New Zealand has further agreed to provisions set out in Articles 11 and 13:

Article 11 (extract)

Adopt and implement, in accordance with its national law, effective measures to ensure that:

(a) tobacco product packaging and labelling do not promote a tobacco product by any

means that are false, misleading, deceptive or likely to create an erroneous impression

about its characteristics, health effects, hazards or emissions, including any term,

descriptor, trademark, figurative or any other sign that directly or indirectly creates the

false impression that a particular tobacco product is less harmful than other tobacco

products. These may include terms such as “low tar”, “light”, “ultra-light”, or “mild”;

and

(b) each unit packet and package of tobacco products and any outside packaging and

labelling of such products also carry health warnings describing the harmful effects of

tobacco use, and may include other appropriate messages. These warnings and messages:

i) shall be approved by the competent national authority,

(ii) shall be rotating,

(iii) shall be large, clear, visible and legible,

iv) should be 50% or more of the principal display areas but shall be no less than 30% of

the principal display areas,

(v) may be in the form of or include pictures or pictograms.

Article 13 (extract)

As a minimum, and in accordance with its constitution or constitutional principles, each Party

shall:

(a) prohibit all forms of tobacco advertising, promotion and sponsorship that promote a

tobacco product by any means that are false, misleading or deceptive or likely to create an

erroneous impression about its characteristics, health effects, hazards or emissions.

By functioning in the same way as advertising, on-pack branding breaches Article 13 of the

FCTC and refutes tobacco companies’ claims that pack livery serves only as an identifying

device that simplifies existing smokers’ decision-making or stimulates brand-switching. Given

this evidence, there is a strong case for New Zealand to mandate the plain packaging of all

tobacco products immediately; this policy would be consistent with our FCTC obligations to

eliminate all tobacco advertising and promotion.[102]

27

Do Recent or Alternative Policy Changes Obviate the Need for Plain Packaging?

The Smoke-free Environments (Controls and Enforcement) Amendment Act 2011 has reduced,

but not eliminated, children’s and non-smokers’ exposure to tobacco products. This Act, which

requires tobacco products to be stored in closed display units, greatly diminished the

pervasive presence tobacco brands formerly had in retail stores and was strongly opposed by

the tobacco industry in New Zealand and internationally. Covering “power-walls” means the

large tobacco retail displays formerly positioned behind store counters are no longer able to

communicate directly with smokers and quitters,[30] or with children and young people.[103]

However, while this important measure has reduced exposure to tobacco products, children,

non-smokers and quitters continue to see tobacco packs in numerous other settings, including

public spaces, their homes, and as litter.[72 104] A recent Australian study that observed

smoking and pack display in al fresco dining areas reported that, of the nearly 19,000

individuals observed, 8.3% were actively smoking and 11.4% were displaying tobacco

packages.[72] This on-going exposure means on-pack branding can still communicate desirable

connotations to users and non-users and constitutes an important reason why plain packaging

is required as an additional measure to reduce exposure to tobacco packs that occurs outside

the retail environment. A study from Australia after the implementation of plain packs

reported that pack display had declined significantly (by 15%) and smoking in outdoor al fresco

dining areas had also declined.[104] Both outcomes are important in firstly reducing exposure

to tobacco marketing and, secondly, reducing exposure to second-hand smoke.

Suggestions that plain packaging would be unnecessary if larger on-pack warnings were

introduced are also not supported by the research evidence. Even residual branding in the

context of larger health warnings increases the appeal of a pack relative to a completely plain

pack that features no branding at all.[81]

The research evidence supporting the immediate introduction and implementation of plain

packaging is clear. Plain packaging is the logical next step in achieving the New Zealand

Government’s objective of achieving a Smokefree Aotearoa /New Zealand by 2025. Plain

packaging will complement and extend existing measures and is urgently needed to eliminate

the on-going tobacco marketing that still occurs, despite existing laws, and hence will enable

us to fulfil our international commitments under the Framework Convention on Tobacco

Control. Because the evidence base is strong and well-developed with respect to the first

objective of the Bill, which we regard as the primary benefit the legislation will bring, we

strongly recommend that the Bill is passed and implemented without delay. We do not

consider that New Zealand should await the outcome of international litigation over plain

packaging, as these cases are being pursued deliberately by the tobacco industry to delay

adoption of the policy. Ironically, commitments by governments to await the outcome of this

litigation creates an incentive to postpone the resolution of these cases and a means by which

the industry can delay implementation almost indefinitely.

28

Areas for Further Investigation

Our informed view is that there are at least four areas where New Zealand could improve on

the plain packaging policy implemented in Australia:

Requiring dissuasive cigarette sticks;

Specifying the brand and variant names that may be used and restricting these to those

currently in use (i.e., avoiding the ‘poetry on a package’ that appears likely to occur in

Australia);

Introducing a wider and frequently replaced array of well-researched pictorial warnings

(including up to 95% of the front of pack), and

Reformatting the Quitline information so this is more visually salient and more effectively

stimulates access of Quit services, and exploring other ways by which the pack can be

made a vehicle for promoting and supporting quitting (such as mandating quit advice

inserts).

In addition, we strongly recommend that the Ministry of Health put in place a multi-faceted

evaluation to gauge plain packaging’s effects on perceptions of smoking, impact of warnings,

understanding of smoking’s harms, and smoking behaviour. We recommend discussion with

Australian researchers, who have a very detailed evaluation programme underway.

Dissuasive Sticks A small scale qualitative study revealed that dissuasively coloured cigarette sticks further

reduced the appeal of smoking and would be likely to deter smoking initiation.[105] Further

work is underway to test these findings among a wider sample of smokers. Given the strong

reactions against dissuasively coloured sticks, which social smokers found particularly

unattractive, we recommend consideration be given to this potential measure.

Limiting Variant Names

As noted above, evidence from Australia suggests tobacco companies have responded to plain

packaging by extending the variant names they associate with tobacco brands. The effect of

this will be to incorporate evocative descriptions on tobacco packages. Figure 5 provides an

example of variant name changes tobacco companies made in Australia in anticipation of the

introduction of plain packaging there.

Figure 5: Extension of Cigarette Brand Variant Names in Australia

Source: Wakefield, M. ASPIRE2025 presentation, 18 September, 2012.

29

Preliminary work we have undertaken suggests variant names enhance pack appeal and could

potentially undermine the intention of plain packaging.[106] We believe there is no public

health justification for allowing the introduction of any new variant names, as new variants are

designed to function as marketing tools and hence can only undermine public health measures

aimed at discouraging smoking uptake and encouraging quitting.

More Diverse Warning Messages

The most cost-effective messages are clearly those that have a wide population effect and

resonate with and influence smokers from different demographic groups. However, recent

research indicates that warning messages do ‘wear out’ and require refreshment;[63]

furthermore, emerging findings suggest the health themes that have dominated pictorial

warning labels (PWLs) may resonate less effectively with younger smokers, who use self-

exempting strategies to distance themselves from the effects depicted.[107] We are leading

an HRC funded project that is addressing this question.

Salience of Quitline Information

When PWLs were introduced in 2008, the Quitline number and a cessation support message

were included on packs. Evidence from Quitline suggests this policy led to an increase in the

number of callers citing the tobacco package as the source of Quitline information.[108]

However, the information provided lacks visual salience and two recent studies we have

undertaken suggest reformatted information could be more easily understood and more likely

to stimulate calls to the Quitline.[109] Figure 6 contrasts the current and a potential format.

Figure 6: Current and Re-formatted Quitline Information

Opportunities may also exist to make tobacco packages quit portals. Just as the tobacco

industry have used cigarette pack design to promote smoking, plain packs could be used to

promote quitting; for example, they could contain supportive messages about quitting , and

provide tips to maximise the chances of successful quitting.

30

We recommend that plain pack implementation be accompanied by a review of how Quit

information is presented in on-pack warnings and the potential for inclusion of smart-phone

readable QR codes that would provide a direct connection to the Quitline website ; as well as

investigation of other approaches by which the pack can be used as a vehicle to encourage and

support smokers to quit.

Additional Suggestions

The Ministry of Health should be able to require new warnings on packs through a simple

and straightforward regulatory process (with minimal need for consultation and no

requirement for additional legal amendments).

Given that, for decades, the multi-national tobacco industry has provided misleading

information to the public and to governments, there is a strong case for the Government

to have full access to all tobacco industry internal documents on marketing and other

activities. The current Bill provides an important opportunity for building these powers of

document access into New Zealand law.

31

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