Euromonitor International is a world leader in strategy research for consumer markets, with over 40 years of experience in developed and emerging economies. Through a combination of specialist industry knowledge and in-country research expertise, Euromonitor aims to build a market consensus view of the size, shape and trends in each industry we cover. Tobacco is no different, and both duty paid and illicit sales are researched in the same way as all other consumer products.

As impartial market analysts, our research methodology has been developed over decades and continues to deliver well-respected and widely used data and insights. For a full description please visit http://www.euromonitor.com/research-methodology.

In short our aim is to build an industry consensus view of each market by accessing all relevant public domain material and enhancing this through an in-country trade survey. The volume and strength of published source material behind our global systems will vary depending on the market or category in question and as a result some data sets are more "hard sourced" than others. This is a widely accepted challenge of researching international markets.

For Tobacco, trade surveys are conducted with a representative range of industry stakeholders in each national market, from government bodies to tobacco brand owners, retailers and health groups, reflecting our wide client base as well as varied opinions and agendas. By its very nature, illicit trade in tobacco is a contentious area that is difficult to quantify - there is often dissonance between sources. A key element of the value-add of Euromonitor's work lies in our ability to scrutinise and reconcile differing views by considering illicit trade against local knowledge of the market and its wider context of national economic performance, trends in cigarette taxation, movements in unit prices, duty paid sales (including trends in illicit and duty paid combined) and smoking populations, as well as porosity of national borders, law enforcement efforts, and product availability. The context and drivers behind our figures are explored in accompanying market analysis reports on each country we research.

As such we are confident Euromonitor International presents the most widely accepted and realistic estimate of the illicit market, based on an integrated view of the wider industry context and the factors that contribute towards it - no single source or figure is taken as definitive.

That said, our clients accept and acknowledge that researching challenging markets is part of an iterative process. We are constantly improving our coverage and understanding of consumer products as we access a wider range of sources in each annual revisit of our industries. As a result our data may change from one annual update to the next based on new sources becoming available, key sources resizing markets or an improved understanding of how to interpret local source material. We are transparent in our methods and our sourcing and all clients have access to our analysts and the assumptions that go in to building our data.

Crucially Euromonitor International is an independent company with no agenda other than to reflect markets and trends as accurately as possible. As such we are completely impartial, with no bias or reliance on any single source. Indeed as analysts we welcome all constructive debate and regularly engage with industry stakeholders from across the board to review sources and challenge assumptions with the aim of developing greater understanding of difficult-to-research areas.

Conflict of Interest:

None declared

It is important for tobacco control policymakers to know the advantages and disadvantages of different tax policies. It is quite another thing to move a tax system to optimize tax policy for tobacco control since there are multiple obstacles to systems change. In addition, health advocates often do not invest enough time and effort to understanding the economics of tax systems and the structural impediments in existing laws and policies to improve the tax structure. Consider for a moment the huge amount the tobacco industry invests in the economics of tobacco, and how it gives big money to lobby and influence tax policy. I applaud economists who are willing to study and fight for strong tobacco control tax policies, but in LMIC they are usually far too few. It is time for local/national health professionals to realize they better invest in working with economic leaders if they really wish to influence tax and health investment policies over the long term. Only then will there be health in all policies, including tax policies on tobacco and many other products that are necessary to sustain and promote health.

Conflict of Interest:

None declared

Significant factual inaccuracies relating to KPMG's annual report into the European trade in illicit tobacco were made in a recent article published in Tobacco Control by the BMJ. The report, which KPMG's Strategy Group has been producing since 2005, is recognised by the UK National Audit Office, OLAF and the OECD (and by other numerous national customs authorities and government departments) as the most comprehensive study of its kind. The report has earned its solid, international reputation because it is produced by an independent, professional advisory firm, using a robust and consistently applied methodology.

The central premise of the article was that the KPMG report overstates the illicit tobacco trade. However, KPMG estimates since 2005 have correlated within a range given by other organisations, including the UK National Audit Office, Euromonitor, Joossens and the IARC, amongst many others. For example, in 2007, Joossens estimated total consumption of illicit tobacco within the EU to be 8.5%, while the KPMG report estimated consumption at 8.4%.

Critically, the article misrepresented the methodology KPMG applies in estimating the consumption of illicit tobacco. The research considers a number of factors, including empty pack surveys. It is certainly true that empty pack surveys do not provide the full picture but they do form an important factor in the equation as they rely purely on physical evidence, avoiding the variability of consumer bias in interview based methods. An additional advantage of empty pack surveys is that they provide a statistically robust and comparable volume of data as they are conducted consistently across all European markets. In 2010 approximately 430,000 packs were collected throughout Europe in 1,400 population centres. Additional analysis identifies if the empty pack survey may have over or under-reported the level of non-domestic packs with the samples being re-weighted to correct this.

The KPMG report also factors in consumer surveys (conducted by Ipsos and Nielsen) which drill into the detail of consumers' travel habits, overall consumption, gender and age to assess the level of legal non- domestic purchases. Approximately 10% of the 160,000 survey respondents both travel and purchase cigarettes abroad. These respondents are asked about the country of purchase and brands purchased. This data can also be adjusted where it appears to be under-reporting legal tobacco consumption. For example, correction of under-reporting increased the allocation of legally purchased packs from Spain to France and from Poland and the Czech Republic to Germany.

The article goes on to offer an alternative estimation methodology: the PPACTE study. However, it is prudent to consider the limitations of this study; notably, the reliance on consumer studies which both under- report tobacco consumption overall and, in particular, illicit tobacco consumption. The PPACTE study also uses a substantially smaller sample size e.g. the methodology used to calculate the illicit volumes equates to an average of less than 200 per country.

The consumption of tobacco - illicit or otherwise - is understandably a concerning issue for many people and organisations. While it may be superficially appealing to discount a report funded by a tobacco company, the methodology of the 'Project Star' report is robust and unbiased. This data set is an important source of knowledge for the tobacco industry and health campaigners alike. An issue can only be tackled, whether for commercial or health reasons, if its nature and scale is understood. The Project Star report is widely regarded, by companies and health and government organisations, as the leading source of data on illicit tobacco consumption in the EU.

Conflict of Interest:

Author of the report under examination in the paper published in December 2013, entitled 'Towards a greater understanding of the illicit tobacco trade in Europe: a review of the PMI funded 'Project Star''

NOT PEER REVIEWED To the Editor: The habit of water pipe smoking is rapidly extending in all occidental countries. This rise in popularity appears to be correlated with the advent on store shelves of an array of fruit-flavored tobacco mixtures, which list ''molasses'' as a primary ingredient. Also there is a widespread misperception among smokers that the water through which the smoke bubbles acts as a filter, rendering it considerably less harmful than that of cigarettes [1]. A recent systematic review showed that the main motives for water pipe tobacco smoking were socializing, relaxation, pleasure and entertainment. Peer pressure, fashion, and curiosity were additional motives for university and school students [2]. However, the habit of smoking tobacco in water pipes is an old practice in the Eastern Mediterranean countries like Egypt, Jordan, Syria, Lebanon and Iraq [3]. Recently, Jaboc and collaborators (2013) published a crossover study about biomarkers of toxicant exposure with water pipe compared with cigarettes. The study included 13 volunteers from San Francisco (USA) who smoked both cigarettes and water pipes. The results showed that water pipe was associated with greater exposure to carbon monoxide, polycyclic aromatic hydrocarbons and benzene compared with cigarette smoking. Finally, the authors concluded that water pipe smoking is associated with a high risk of leukemia related to high levels of benzene exposure [4]. If Jaboc and collaborators' (2013) conclusions were right, we would expect higher prevalence of leukemia in the Eastern Mediterranean region compared with the Occidental Countries. Reviewing cancer registries in GLOBOCAN 2008, we can notice that adjusted standardized mortality rates of leukemia in males are comparable in the European Region (5.0 per 100.000) to the Eastern Mediterranean Region (4.7 per 100.000). A similar rate is noticed in the Americas Region (5.0 per 100.000) [5]. Deficient registration systems could not be the explanation. Neoplasms principally attributed to smoking like lung, laryngeal and oro-pharyngeal cancers have similar prevalence in Egypt like many of the occidental countries [5]. Water pipe tobacco brands used in the study of Jacob and collaborators (2013) were Nakhla and Al-Waha. These are the same brands usually consumed in the Eastern Mediterranean countries, like Egypt. On examining the box of Nakhla Double Apple brand, widely consumed in Spain, we can find a clear notice that it contains 0% tar. During the smoking process cigarette tobacco burns directly, whereas water pipe tobacco does not burn in a self-sustaining manner and requires an external heat source such as charcoal. I think that the high level of polycyclic aromatic hydrocarbon and benzene in the urine samples of water pipe smokers in the study of Jaboc and collaborators (2013) could be attributed to the charcoal disks used in many occidental countries. These quick lighting charcoal disks are impregnated in gasoil rich in polycyclic aromatic hydrocarbons and benzene. Smoke from these impregnated charcoal disks is inhaled by water pipe smokers [1]. In Eastern Mediterranean countries like Egypt, natural charcoal is used and is burned slowly in special clay or metallic receptacles [1,3]. This could explain the comparable prevalence of leukemia in Egypt and Occidental Countries. Examining quick lighting charcoal disk tubes available in Spain, we can notice that they lack labeling about the hazards of their use for water pipe smoking. Regulations and control for the use of these impregnated charcoal disks in the European Countries are urgently needed.

REFERENCES 1. Shihadeh A. Investigation of mainstream smoke aerosol of the argileh water pipe. Food Chem Toxicol 2003;41(1):143-52. 2. Akl EA, Jawad M, Lam WY, Co CN, Obeid R, Jihad Irani J. Motives, beliefs and attitudes towards waterpipe tobacco smoking: a systematic review. Harm Reduct J 2013;10:12. 3. Chaouachi K. The medical consequences of narghile (hookah, shisha) use in the world. Rev Epidemiol Sante Publique 2007;55(3):165-170. 4. Jacob P 3rd, Abu Raddaha AH, Dempsey D, Havel C, Peng M, Yu L, Benowitz NL. Comparison of nicotine and carcinogen exposure with water pipe and cigarette smoking. Cancer Epidemiol Biomarkers Prev 2013;22(5):765-72. 5. International Agency for Research on Cancer. GLOBOCAN 2008. Available at: http://globocan.iarc.fr/ (Accessed 31 August 2013).

Conflict of Interest:

None declared