***STOP PRESS*** The deadline has now been extended to the 10th of August

The Department of Health are consulting about the Standardisation of Tobacco Packaging and the closing date is 10th August 2012.  You can respond by:

Completing the online form at http://consultations.dh.gov.uk

Emailing your response to: tobaccopacks@dh.gsi.gov.uk

Filling in the response form by downloading it at: http://consultations.dh.gov.uk and posting  it to: Tobacco Packs Consultation Department of Health, 7th Floor, Wellington House, 133–155 Waterloo Road, London. SE1 8UG

Here’s the text of the email that I have sent to the Department of Health in response to the consultation that I have also sent to my MP.

‘I believe that leaving tobacco packaging in its current form is the correct thing to do. The evidence of the long term research, Smoking, drinking and drug use among young people in England shows a clear decline in smoking within the age group covered. The tobacco display ban has not yet been fully implemented, but the Impact Assessment projects that the measure will reduce the prevalence of smoking in 11 to 15 year olds by a fifth to 4.2%. Standardised packaging, a strategy that has no actual evidence to support it, will have disproportionate costs to the limited effect that it would deliver.

The science used to support the policy is to say the least weak. In real academic science to achieve a paper of value there has to be rigour and a tough peer review process before publication. Having read many tobacco control papers it is apparent that the standards that apply in Science, Nature or Cell do not apply to the publication that these article appear in.

Branded goods from legitimate retailers enable consumers to know the product they bought previously will be the same as their next purchase. Destroying brand recognition will make the consumers task more difficult.  Destroying brand equity will play into the hands of the unbranded operators and the illicit trade. The investment by community retailers have made in selling responsibly will be further challenged.

The unintended consequences of standardised packaging of tobacco include:

• The huge opportunity that this tobacco control measure would offer to the illicit tobacco suppliers. Stripped of the need to make their products look like known brands they may well follow the example of the contraband trade in Canada and introduce a large range, around 200, of their own brands. There is already evidence of illicit brands being sold in the UK.
• Community based independently owned stores are by their very nature fragile. Changes to their product mix and profitability is likely to cause the closure of many. These stores offer significant amenity value to the communities they serve and will be substantially missed if they are lost.
• Underage access to cigarettes from tobacco retailers has been greatly reduced over the past decade, particularly since the 2007 when 18 years became the minimum age for legal sales. Any move that will grow the illicit supply channel will severely damage this progress. Criminals will not care who they sell to.
• Any growth in the illicit supply of tobacco will further damage the tax take by Government.

The Department of Health’s own research states that ‘regular smoking among 11 to 15 year olds was related too the risk-taking behaviours (drinking alcohol, drug taking, truancy and exclusion). Living with other smokers or having friends who smoke also increased the odds of smoking, as did a relatively lenient attitude to smoking by pupils’ families. Pupils who received free school meals, an indicator of family deprivation, also had increased odds of being regular smokers.’ This surely indicates where the challenge and solution to youth smoking is to be found.

Cutting down on youth smoking is a good thing, but this unproven, unmanageable tactic is not the way to go about it.’

You can find the details for your MP at www.theyworkforyou.com