Analysis of submissions to the EU's public consultation on tobacco traceability and security features

The Protocol to Eliminate Illicit Trade in Tobacco Products requires all parties to establish a tobacco track and trace (T&T) system. In 2016, the European Commission held a public consultation on T&T implementation where parties were asked to respond online to 22 multiple-choice questions and were given additional opportunities to leave comments. In May 2019, the European Union's (EU) T&T system became operational. This paper explores tobacco industry influence over and policy positions within the consultation process.

We identified consultation respondents and investigated any financial links with the tobacco industry and if these were transparent. Respondent's answers to the consultation's multiple-choice questions were collated to explore whether industry-linked respondents held the same policy positions as transnational tobacco companies (TTCs). Associations between policy positions and respondent's financial link status were tested using χ² and Cranmer's V tests.

Of the 197 consultation respondents identified, 131 (66.4%) had financial links to the industry; 29 (22.1%) were not transparent about these links. A large number of trade associations responded (87), the majority of which (74/87) had financial links to the industry. There was a clear divide in the policy preferences of respondents with and without a financial link. Collectively, respondents with a financial link supported an industry-operated T&T solution.

There was an extensive lobbying effort by the tobacco industry over the EU's T&T system, with TTCs' interests being represented repeatedly through multiple trade associations. The transparency requirements regarding consultation respondents' affiliations with relevant stakeholders (eg, tobacco manufacturers) should be improved for future consultations.