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Analysis of submissions to the EU’s public consultation on tobacco traceability and security features
  1. Allen William Andrew Gallagher1,
  2. Karen Evans-Reeves1,
  3. Ayush Joshi1,
  4. Jenny Hatchard2,
  5. Anna B Gilmore1
  1. 1Tobacco Control Research Group, Department for Health, University of Bath, Bath, UK
  2. 2Bristol Medical School, University of Bristol, Bristol, United Kingdom
  1. Correspondence to Allen William Andrew Gallagher, Department for Health, University of Bath, Bath, UK; a.a.gallagher{at}


Background 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.

Methods 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.

Findings 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.

Conclusions 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.

  • Illegal tobacco products
  • public policy
  • packaging and labelling

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  • Contributors AWAG conceived the idea for the study, which was then developed in conjunction with the other authors. AWAG developed the methodology, which was then refined after discussions with the other authors. AWAG collected the data and AWAG and AJ undertook the analysis. AWAG created a draft of the paper, which all authors then contributed to.

  • Funding AWAG, KE-R, AJ and ABG acknowledge the support of Bloomberg Philanthropies Stopping Tobacco Organizations and Products project funding ( KE-R and AJ also acknowledge the support of Cancer Research UK (grant A25745). JH acknowledges the support of Cancer Research UK (Tobacco Advisory Group Award C58487/A22731). AWAG, KE-R, AJ and ABG are part of the Tobacco Control Research Group, which is a member of the SPECTRUM consortium (Shaping Public Health Policies to Reduce inequalities and harm) funded by the UK Prevention Partnership led by the Medical Research Council (Grant Ref: MR/S037519/1).

  • Disclaimer The opinions expressed are those of the authors alone.

  • Competing interests None declared.

  • Patient consent for publication Not required.

  • Provenance and peer review Not commissioned; externally peer reviewed.

  • Data availability statement Data are available on reasonable request. Please contact the lead author ( to access underlying data for this research.

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