Article 13 of the Framework Convention on Tobacco Control (FCTC) requires signatories to ‘undertake a comprehensive ban of all tobacco advertising, promotion and sponsorship’.1 The FCTC defines advertising and promotion very broadly, as 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.1

The Implementation Guidelines for the FCTC specify that: …a comprehensive ban…applies to all forms of commercial communication, recommendation or action and all forms of contribution to any event, activity or individual with the aim, effect, or likely effect of promoting a tobacco product or tobacco use either directly or indirectly.2 (Italics as per original.)

It is therefore of concern to see that Imperial Tobacco has launched a social media campaign around the ‘Smoke Spots’ website in the UK (http://www.smoke-spots.co.uk). The site's launch was announced on Imperial Tobacco's Twitter account in July 2013, describing Smoke Spots as a ‘website for smokers’ which enables consumers to ‘find bars, restaurants and clubs with smoking facilities as well as locate outlets selling tobacco’.3 Imperial Tobacco's Head of Consumer Marketing was quoted in a company press release to support the launch as saying: ‘With this great new initiative, we are giving our consumers the chance to interact and form an online community where they can share great smoking experiences with each other.’4

The goal of creating an online community where consumers can ‘share great smoking experiences’ would appear to be inconsistent with the FCTC's ban on directly or indirectly promoting tobacco use. In the same press release, Imperial Tobacco's Head of Digital and Marketing Communications implied the purpose …