HOUSE

OF COMMONS
SWIA OAA

LONDON
Department of Health Richmond House 79 Whitehall London SW1A2NS

Dear Secretary of State,

We wish to express our serious concerns with the Department standardised or 'plain' packaging for tobacco products.

of Health's proposal to introduce

There is no reliable evidence that plain packaging will have any public health benefit; no country in the world has yet to introduce it However, such a measure could have extremely negative consequences elsewhere. This proposal will be a smuggler's charter. Latest estimates from HM Revenue and Customs show that up to 16% of cigarettes and 50% of handrolling tobacco in the UK is smuggled, losing revenue of up to £3.1 billion. We are worried that standardised packaging would make smuggling simpler and exacerbate this already critical problem as criminal organisations would only be required to master one pack design. Secondly, this policy threatens more than 5,500 jobs directly employed by the UK tobacco sector, and over 65,000 valued jobs in the associated supply chain. Jobs in design and branding as well as those in manufacturing and printing are all at risk over the proposals and the resulting business failures could decimate employment in some communities. Given the continued difficult economic climate, businesses should not be subjected to further red tape and regulation that may have a serious impact on future investment, expansion and jobs in other sectors. Thirdly, we believe products must be afforded certain basic commercial freedoms. The forcible removal of branding would infringe fundamental legal rights, severely damage principles around intellectual property and set a dangerous precedent for the future of commercial free speech. Indeed, if the Department of Health were to introduce standardised packaging for tobacco products, would it also do the same for alcohol, fast food, chocolate and all other products deemed unhealthy for us? There are other more effective and practical measures which do not damage UK businesses that should continue to be taken to discourage, educate and prevent children from taking up smoking these include guiding and supporting retailers to help ensure those under the legal age of 18 are not able to purchase tobacco products. With the display ban, which will remove the visibility of tobacco products in shops currently being phased in across the UK, we urge the Government to reserve judgement and to cancel proposals for standardised packaging after considering fully the host of unintended damaging consequences that will result in its introduction.

Yours Sincerely,

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