Standardised tobacco packaging

Transcription

1 May 2016 Standardised tobacco packaging Purpose of the briefing This briefing sets out the public health case for standardised tobacco packaging. It defines standardised packaging, explains the legal and political context, summarises the research to support the measure, and addresses the counter arguments put forward by the tobacco industry and their allies in opposition to the measure. Introduction Australia was the first country in the world to require cigarettes to be sold in plain, standardised packaging. The United Kingdom became the first country in the European Union to pass similar legislation with Ireland and France following suit. From 20th May 2016 the UK and France will begin to introduce standardised packs, with Ireland following at a later date. This is in addition to the requirements of the EU Tobacco Products Directive which covers packaging and labelling. Following a legal challenge by the tobacco industry the European Court of Justice ruled that the Tobacco Products Directive, which permits Member States to implement standardised packaging, was lawful. On 19th May 2016, the UK High Court rejected a separate legal challenge of the UK law on standardised packaging by the tobacco industry, allowing the measure to proceed as planned. What is standardised packaging? Standardised packaging, also known as plain, generic or homogenous packaging, refers to packaging that has had the attractive promotional aspects of tobacco products removed and the appearance of all tobacco packs is standardised including the colour of the pack. ASH Briefing: Standardised tobacco packaging

2 This means that there is no branding other than the product name in a standard font, size and colour, and no other trademarks, logos, colour schemes or graphics are permitted. 1 In the UK, Ireland and France the introduction of standardised packaging coincides with the implementation of the EU Tobacco Products Directive which sets out new rules on tobacco packaging such as the increased size and positioning of health warnings. See section on tobacco advertising below. The UK law on standardised packaging requires the following: No branding other than the product name in a standard font, size and colour Prohibition of all other trademarks, logos, colour schemes and graphics The only colour permitted on the external surface (excluding the pictorial health warning and written text) is Pantone 448C with matt finish Cigarette packets must be cuboid in shape and contain a minimum of 20 cigarettes Packaging of hand-rolled tobacco must also be in same Pantone 448C colour and contain a minimum of 30g of tobacco. Public Opinion There is widespread public support for tobacco to be sold in plain, standardised packaging. A YouGov survey conducted in March 2016 found that overall 61% of adults in Great Britain supported requiring tobacco to be sold in plain standardised packaging with the product name in standard lettering, while only 10% opposed it. 2 In Australia, a study found that since standardised packaging was introduced, smokers support for the measure rose sharply from 28.2% prior to its introduction to 49% after implementation. 3 The case for standardised packaging Packaging as advertising While the tobacco products display ban will help to reduce children s exposure to tobacco promotion this measure alone is not sufficient to protect children. Tobacco packaging is now the most ubiquitous form of tobacco advertising. Smokers display the branding every time they take out their pack to smoke. In doing so they are making a statement about how they want to be seen by others as they display and endorse the brand they have chosen. The importance of the pack as a communication tool is acknowledged by the tobacco industry as this response from Philip Morris Limited to the Government s consultation on the future of tobacco control illustrates:.. as an integral part of the product, packaging is an important means of differentiating brands and in that sense is a means of communicating to consumers about what brands are on sale and in particular the goodwill associated with our trademarks, indicating brand value and quality. Placing trademarks on packaged goods is, thus, at the heart of commercial expression. 4 Similarly, legal representatives of Japan Tobacco International, in proceedings in the Australian High Court, asserted that the Commonwealth is acquiring our billboard, your Honour, in effect. 5 Branding recruits children and young people to a life-time of addiction Currently approximately 100,000 people die prematurely from smoking-related diseases every year in the UK. Tobacco companies therefore need to recruit new smokers to stay in business. New customers are nearly always children and young people. Two thirds (66%) of regular smokers start before the age of eighteen the legal minimum age for the purchase of tobacco - and two fifths (39%) start before the age of sixteen. 6 Of those who take up smoking, only about half will manage to stop before they die. 7 The UK Tobacco Advertising and Promotion Act has been effective in removing overt promotional activity and has brought about a consequent reduction in awareness of tobacco marketing amongst 2 - ASH Briefing: Standardised tobacco packaging

3 the young.8 However, branding continues to drive teen smoking, and awareness of packaging and new pack design is a key element of this ongoing marketing.9,10 Research shows that this has already had an effect: between 2002 and 2006 there was an increase in the proportion of young people aware of new pack design from 11% in 2002 to 18% in Lambert & Butler case study In a presentation to an industry conference in 2006, Imperial Tobacco s Global Brand Director, Geoff Good, acknowledged that the tobacco advertising ban in the UK had effectively banned us from promoting all tobacco products and noted that In this challenging environment, the marketing team have to become more creative adding: We therefore decided to look at pack design. Focusing on the UK s most popular cigarette brand, Lambert & Butler, Imperial developed a new version of the Lambert & Butler brand to mark its 25th anniversary in the UK market. The Celebration packs were launched in November 2004 as a 4-month special edition, replacing the original pack until February According to Good: The effect was very positive. Already the no.1 brand, our share grew by over 0.4% during this period that might not sound a lot but it was worth over 60 million in additional turnover and a significant profit improvement. Good concludes: Often in marketing, it is difficult to isolate the effects of individual parts of the mix. But in this case, because the UK had become a dark market, the pack design was the only part of the mix that was changed, and therefore we knew the cause and effect. Good, G. Global Brand Director, Imperial Tobacco Group plc. Presentation at UBS Tobacco Conference, 01 December 2006 Established adult smokers tend to be brand loyal and the majority know which brand they will ask for before they walk into a shop.11 Therefore, new, young smokers are the primary target of industry marketing. Brand imagery is much more important to younger age groups and they respond more effectively to it than older groups.12 Moving to standardised packaging will therefore reduce brand appeal and reduce smoking initiation. Evidence reviews on standardised packaging There is a growing body of research evidence in support of standardised packaging. Peer reviewed studies have found that, compared to branded cigarettes, plain standard packaging is less attractive to young people, improves the effectiveness of health warnings, reduces mistaken beliefs that some brands are safer than others and is likely to reduce smoking uptake amongst children and young people.13,14, ASH Briefing: Standardised tobacco packaging

4 Public Health Research Consortium review A Government-commissioned systematic review of 37 studies providing evidence of the impacts of plain, standardised tobacco packaging was conducted by the Public Health Research Consortium (PHRC). 16 Nineteen studies examined perceptions or ratings of attractiveness of plain, standardised packs. All of these studies found that standard packs were rated as less attractive than branded equivalent packs, or were rated as unattractive, by both adults and children. In addition, those studies that tested a range of branded and unbranded packs found that this difference increased progressively as more branding elements and descriptors were removed. With regard to health warnings, the studies reviewed found that plain packs were perceived as being less cluttered and therefore less likely to detract from the health warning, and that the dullness or seriousness of the packs enhanced the seriousness and credibility of the warnings. Studies which examined the impact of plain packs on perceptions of harm and strength found that results were mixed as perceptions varied according to the colour of the packs. However, studies which examined perceptions of which pack was more effective in terms of raising awareness of health risk tended to find that plain standardised packs were perceived as more effective than branded packs. Sixteen studies in the PHRC review examined whether and how plain packs impact on smokingrelated attitudes and beliefs. Although the findings were mixed, the overall pattern tends to be supportive of standard packaging being perceived to have a likely deterrent effect on smoking. Studies that looked at differences by age found that younger respondents were more likely than older respondents to perceive that standard packs would discourage take-up of smoking, encourage cessation or reduce consumption. An update of the review examined a further 17 studies which have added to the evidence suggesting that standardised packaging would: reduce the appeal of cigarettes and smoking; enhance the salience of health warnings on packs; and address the use of packaging elements that mislead smokers about product harm. 17 Chantler review In November 2013, Sir Cyril Chantler was commissioned by the Government to examine whether the introduction of standardised packaging would have an effect on public health, in particular in relation to the health of children. 18 Chantler reviewed evidence from both public health bodies and that provided by the tobacco industry. He concluded by saying that he was: persuaded that branded packaging plays an important role in encouraging young people to smoke and in consolidating the habit irrespective of the intentions of the [tobacco] industry. And added: I am satisfied that the body of evidence shows that standardised packaging, in conjunction with the current tobacco control regime, is very likely to lead to a modest but important reduction over time on the uptake and prevalence of smoking and thus have a positive impact on public health. Australian Government Post-Implementation review In February 2016, the Australian government published its Post-Implementation Review of the impact of standardised tobacco packaging. 19 The review concluded that while the full effect is expected to be realised over time, the evidence to date suggests that the measure is achieving its aims. Specifically, the review found that the measure accounted for approximately one quarter of the decline in smoking prevalence over the 3 year post-implementation period, during which time smoking fell from 19.4% to 17.2%. In addition, the Australian Government has released figures showing a significant fall in consumption as measured by estimated expenditure on tobacco products. 20 Calls to smoking quitlines increased significantly after standardised packaging was implemented. One study found a 78% increase in the number of calls to the Quitline in NSW following the introduction of tobacco plain packaging and enlarged graphic health warnings. Furthermore, the increase was sustained for a significantly longer period of time than the increase experienced following the introduction of graphic health warnings in ASH Briefing: Standardised tobacco packaging

5 Further evidence published as part of a collection of articles in the journal Tobacco Control 22 revealed that the introduction of standardised packaging has reduced the appeal of cigarette packs to adolescents. 23 Another study found that, contrary to tobacco industry claims, there has been no evidence in Australia of increased use of illicit tobacco. 24 Research has also revealed that smokers are now less likely to openly display their cigarette packs following the introduction of standardised packaging. The authors conclude that this is likely to reduce smoking-related social norms, thereby weakening an important influence on smoking uptake and better supporting quit attempts. 25 UK legislative context Tobacco Advertising & Promotion: UK and EU law EU law defines tobacco advertising as any form of commercial communication with the aim or direct or indirect effect of promoting a tobacco product. 26 In 2003, the Tobacco Advertising and Promotion Act came into effect in the UK. 27 The Act prohibited virtually all forms of tobacco advertising and promotion, i.e. advertising in print media, on billboards and in the form of direct marketing. By July 2005, sponsorship of sport by tobacco companies was also prohibited. As part of the Health Act 2009, regulations to prohibit the display of tobacco products at the point of sale were implemented. The regulations entered into force in April 2012 for large shops such as supermarkets and remaining shops were required to comply with the display ban by April For further details see the ASH Briefing on Tobacco Displays at the Point of Sale. While this measure protects children from tobacco promotion in retail settings, standardised packaging is also needed to prevent exposure to tobacco imagery elsewhere. Since implementation of the 2001 EU Tobacco Products Directive 28 it has been illegal to include any text or symbols on tobacco packaging to suggest that a particular tobacco product is less harmful than others. The revised 2014 Directive requires the following: Cigarette and hand-rolling tobacco packaging to include a combined picture and text health warning covering 65% of the front and the back of the package, placed at the top of the pack Standardised cuboid shape of cigarette packs to ensure clear visibility of health warnings Ban on the sale of packs containing fewer than 20 cigarettes Removal of misleading information on tar, nicotine and carbon monoxide Ban on use of any promotional descriptors such as references to flavours Since implementation of the EU Directive in 2003, the tobacco industry was required to remove misleading descriptors such as light or mild. However, the legacy of low-tar advertising resulted in certain colours such as white and silver being associated with lighter or lower-tar products giving the impression that they were less harmful than regular brands. The road to standardised packaging legislation in the UK In April 2012, the UK Government launched a public consultation which sought people s views on whether or not standardised packaging should be adopted, or whether a different option should be considered. 29 Coinciding with the consultation launch, the Public Health Research Consortium published a systematic evidence review. 16 The consultation closed in August In July 2013, a summary report on the consultation was published together with a written Ministerial Statement in which the Secretary of State for Health said that the Government has decided to wait until the emerging impact of the decision in Australia can be measured before we make a final decision on this policy in England. 30 In September 2013, the Public Health Research Consortium published an update of its systematic review. 17 In November, a cross-party group of peers tabled an amendment to the Children and Families Bill to introduce standardised tobacco packaging. 31 Facing possible defeat in the House of Lords over the matter, on 28 November 2013 the Government announced that it would introduce its own amendment to the Children and Families Bill to give the Secretary of State for Health the power to introduce standardised packaging through regulations. 5 - ASH Briefing: Standardised tobacco packaging

6 However, the Government also announced that before the introduction of any regulations there would be a review of the public health evidence to be conducted by a paediatrician, Sir Cyril Chantler. Sir Cyril published his report on 3rd April 2014 in which he concluded that standardised packaging would have a positive impact on public health. 18 Responding to the Chantler report, the Minister for Public Health said that she was minded to proceed with introducing regulations to provide for standardised packaging, subject to a further short consultation to take into account any evidence that had arisen since the end of the 2012 consultation. 32 The 3-month consultation was launched in June along with publication of the draft regulations. Following the consultation, the Government notified the European Commission of the draft regulations. The EU s consideration of the proposals can take up to six months. In January 2015 the Government announced that it would bring forward legislation and that regulations would be laid and voted on before the end of the parliamentary session on 30th March. 33 The regulations were tabled in February. 34 On 11th March MPs voted by a clear majority in favour of the measure (367 for versus 113 against). 35 The following week the regulations were debated and approved in the House of Lords without a vote. 36 Other Countries Australia became the first country in the world to require all tobacco products to be sold in plain, standardised packaging. The law came into effect on 1 December In addition to Australia and the UK, Ireland 38 and France 39 have passed legislation to introduce standardised packaging. The measure is also under formal consideration in Finland, New Zealand and Norway. 40 Standard packaging is supported by a range of experts and international bodies. 41 Furthermore, under the terms of the revised EU Tobacco Products Directive, and reinforced by the European Court of Justice ruling dismissing legal challenges to the law, 42 Member States will be permitted to introduce standardised tobacco packaging. 43 Tobacco Industry fears about standardised packaging The tobacco industry has sustained a long campaign against standardised packaging since the idea was first proposed in Canada in the 1990s. 44 According to Philip Morris International the world s major manufacturers have agreed to fight the introduction of standard packaging stating that they do not want to see plain packaging introduced anywhere regardless of the size and importance of the market. 40 In 2008 Tobacco Journal International reported that according to analysts Morgan Stanley, if generic packaging becomes a legal requirement in the UK it could result in considerably reduced profits. 41 Tobacco Industry response to standardised packaging The tobacco industry has sustained a long campaign against standardised packaging since the idea was first proposed in Canada in the 1990s. 44 According to Philip Morris International the world s major manufacturers have agreed to fight the introduction of standard packaging stating that they do not want to see plain packaging introduced anywhere regardless of the size and importance of the market. 45 In 2008 tobacco analysts Morgan Stanley predicted that generic packaging could result in considerably reduced profits ASH Briefing: Standardised tobacco packaging

7 What industry analysts say about plain packaging: regulations have to date neither undermined industry profitability nor led to commoditization of the cigarette category. However, a ban on conventional packaging graphics could prove to be a very different matter. 47 Plain packaging would significantly reduce the power of tobacco brands. The industry is so profitable only because consumers are willing to pay a premium of 1.50 for certain brands. We think this measure would cause a rapid worsening of the downtrading trend. Over time this would hurt profitability significantly. 48 Clearly, smokers won t like it. However, I suspect that the majority of the population that does not smoke will be in favour of the proposal. Anything which boosts the public health is good. 49 Tobacco Industry arguments against standardised packaging Trade agreements and trade marks Where standard packaging has been suggested, the tobacco industry has responded with vigorous campaigning, claiming that it would contravene national and international legal obligations on free trade and the protection of trade marks. On the day that the Australian government passed legislation to introduce plain packaging Philip Morris immediately launched a lawsuit to challenge the law. 50 despite the fact that the tobacco companies are aware that all these trade agreements contain important exceptions for health-related issues which have been defended successfully. 51 In response to the Australian government s proposed legislation, the tobacco industry claimed that standardised packaging laws would involve the acquisition of trademarks and be in breach of article 16 of The Agreement on Trade-Related Aspects of International Property Rights (TRIPS). However, Article 16 does not create a right to use a trade mark, it simply prevents third parties from using trade marks and this right would not be affected by plain packaging. 52 The industry challenge was rejected by the Australian High Court in August Despite the tobacco industry s public protestations, its own internal documentation has revealed that it does not believe it has a case under the TRIPS agreement, that current conventions and treaties afford little protection, and that there is little joy in GATT/TRIPS. 54 Impact on illicit trade Contrary to industry claims, there is no evidence that standardised packaging will lead to an increase in the illicit trade in tobacco. 55 In his examination of the Australian experience, Sir Cyril Chantler reported that he had found no convincing evidence to suggest that standardised packaging would increase the illicit market 18 Tobacco packs are already easily counterfeited which is why the industry is required to add covert markings to distinguish legitimate products from counterfeit. 56 Standardised packs will have all the health warnings and other markings required on current packs so they will be no easier to counterfeit than branded packs. Impact on retailers The tobacco industry argues that standardised packs will lead to an increase in tobacco smuggling so reducing legal sales and cause confusion and additional costs to retailers which will disproportionately affect small retailers. As noted above, there is no convincing evidence that standardised packs would result in a rise in illicit sales. The industry has claimed that selling standardised packs would incur extra staff time, taking up to 45 seconds longer per sale compared to selling branded packs. This was based on a small sample of only six tobacco retailers who were asked to estimate what the impact would be. 57 However, evidence-based research measuring over 5,000 transactions found that standardised packs if anything reduced transaction times and selection errors. 58 The findings of this simulation exercise 7 - ASH Briefing: Standardised tobacco packaging

8 have subsequently been confirmed in actual retail settings in Australia. Following implementation of standard tobacco packaging in December 2012, researchers found overall improvements in retailer efficiency. 59 Tobacco sales will decline gradually but not overnight as the main impact will be on reducing uptake amongst young people not on current smokers, so shops will have time to adapt. Small retailers will still be located far more conveniently to smokers than will large retailers so there is no reason why they should be disproportionately affected by any change in sales due to standardised packaging. Impact on price The tobacco industry has argued that standardised packaging would lead to a reduction in the price of tobacco products and, consequently, smoking would increase. 60 A review of this analysis commissioned by ASH 61 found the research overstated the extent to which prices would fall. A similar conclusion was reached by Sir Cyril Chantler who, after commissioning further research, concluded that the risk of such effects undermining the objective of standardised packaging were small and that the impact could be mitigated by raising the tax on tobacco. 18 For further analysis of the tobacco industry arguments see: For information on the campaign for standardised packaging see: ASH Briefing: Standardised tobacco packaging

9 References 1. The Standardised Packaging of Tobacco Product Regulations Opinion research from YouGov. Total sample size was 12,157. Fieldwork was undertaken between 2nd and 23rd March The survey was carried out online. The figures have been weighted and are representative of all GB adults (aged 18+). 3. Borland, R., et al. (2014) Australian smokers support for plain or standardised packs before and after implementation: findings from the ITC Four Country Survey Tobacco Control 4. Philip Morris Limited. Response to the Department of Health consultation on the future of tobacco control, September High Court of Australia Transcripts. Japan Tobacco International SA v Commonwealth of Australia; British American Tobacco Australasia Limited & Ors v The Commonwealth of Australia [2012] HCATrans 91, 17 April Smoking and drinking among adults. General Household Survey ONS, Aveyard P & West R. Managing smoking cessation. BMJ 2007; 335: Centre for Tobacco Control Research (CTCR). Point of sale display of tobacco products. London, Cancer Research UK, Moodie C, Mackintosh AM, Brown A, et al. Tobacco marketing awareness on youth smoking susceptibility and perceived prevalence before and after an advertising ban. Eur J Public Health 2008;18: Moodie C, Hastings G. Tobacco packaging as promotion. Tob Control 2010;19: Wakefield, M. The effect of retail cigarette pack displays on impulse purchase. Addiction 2008; 103 (2): Beyond Smoking Kills: protecting children, reducing inequalities. London, ASH, Plain packaging of tobacco products: A review of the evidence. Cancer Council Victoria, ASH response to Government consultation on standardised packaging, The growing evidence on standardised packaging of tobacco products. (a collection of peer-reviewed research papers and commentaries reviewing the evidence base from 2008 to 2015) Addiction, 17 Feb Moodie C, Stead M, Bauld L et al. Plain tobacco packaging: a systematic review, Public Health Research Consortium, University of Stirling, Moodie, C Angus K, Stead M and Bauld L. Plain Tobacco Packaging Research: An Update. Stirling, Scotland: Centre for Tobacco Control Research, Institute for Social Marketing, University of Stirling, Sept Standardised packaging of tobacco. Report of the independent review undertaken by Sir Cyril Chantler. Kings College London, April Post-Implementation Review: Tobacco Plain Packaging Best Practice Regulation Updates. Australian Government, Feb Tobacco key facts and figures. Australian Government Department of Health website 21. J. Young, I. Stacey, T. Dobbins, D. Dunlop, A. Dessaix and D. Currow, Association Between Tobacco Plain Packaging and Quitline Calls: A Population-based, Interrupted Time-series Analysis (2014) 200(1) Medical Journal of Australia pp Implementation and evaluation of the Australian tobacco plain packaging policy. April 2015, Volume 24, Suppl White V, Williams T & Wakefield M. Has the introduction of plain packaging with larger graphic health warnings changed adolescents perceptions of cigarette packs and brands? Tob Control 2015;24:ii42-ii Scollo M, Zacher M, Coomber K & Wakefield M. Use of illicit tobacco following introduction of standardised packaging of tobacco products in Australia: results from a national cross-sectional survey. Tob control 2015; ;24:ii76-ii Zacher M et al. Personal pack display and active smoking at outdoor café strips: assessing the impact of plain packaging 1 year post-implementation. Tob Control 2015;24:ii94-ii EU Tobacco Advertising Directive 2003/33/EC 27. Tobacco Advertising and Promotion Act European Union Directive COD 2001/ Consultation on standardised packaging of tobacco products, Department of Health, 16 April Consultation on Standarised Packaging of Tobacco Products. Written Ministerial Statement, Department of Health, 12th July 2013 Consultation on standardised packaging of tobacco products: summary report, Department of Health, 12th July Committee Stage of the Children and Families Bill. 20th November Statement by Minister for Public Health (Jane Ellison) on Tobacco Products (Standard Packaging), Hansard, Column 1018, 3 Apr End of day adjournment debate on standardised packaging (Tobacco Products). House of Commons, Hansard, 21 Jan Cols Standardised Packaging of Tobacco Products Regulations House of Commons. Delegated Legislative Committee debate, 9 March 2015 Add Ref to vote on 11 March. 36. Lords discuss tobacco packaging. Parliament UK, 17 March ASH Briefing: Standardised tobacco packaging

10 37. Senate passes world first for plain packaging of tobacco legislation. Department for Health and Ageing, 10 November Tobacco free Ireland 39. La France adopte le paquet de cigarettes neuter. Le Soir 20 Dec Plain packaging Overview. Canadian Cancer Society, March On the state of the public health: Report of the Chief Medical Officer, Other supporters include: Dr. David Kessler, former Commissioner, US Food and Drug Administration (2001); Canadian House of Commons Standing Committee on Health (1994); World Conference on Tobacco or Health (1994). In the UK, all members of the Smokefree Action Coalition support standard packaging, See: The new EU directive on tobacco products is valid. Press release of the Court of Justice of the European Union, 4 May European Commission. Proposal for a Directive of the European Parliament and of the Council on the approximation of the laws, regulations and administrative provisions of the Member States concerning the manufacture, presentation and sale of tobacco and related products. December 2012 Update with link to final text 44. Results of plain packaging committee hearings. 22 June Legacy Tobacco Documents Library. 45. Dangoor D. PMI corporate affairs meeting, Rye Brook & In: Pim P. I. M., editor. Philip Morris; 1995: / Campbell, D. Plain packets law to strip cigarettes of their glamour. The Observer, 21/9/ Plain packaging is a serious threat but quite unlikely. Morgan Stanley, Material new risk appears: UK Govt. suggests plain packaging. Citigroup, Spielman A. Little hope in appealing to natural justice. Tobacco Journal International, September Philip Morris sues Australia over cigarette packaging, BBC online, 21 November Case Study: Ban on Cigarette Advertisement and Promotion Within the Scope of GATT/WTO 52. Davison M. Plain packaging of cigarettes: would it be lawful? Australian Intellectual Property Law Bulletin, October World leading plain packaging laws given clean bill of health. Press release. Office of the Minister of Health, Australia 15 Aug Mahood G. Warnings that tell the truth: breaking new ground in Canada. Tob Control 1999 ; 8 : Smuggling, the tobacco industry, and plain packs. Cancer Research UK, Tackling Tobacco Smuggling Together: An integrated strategy for HM Revenue & Customs and the UK Border Agency. HMRC November The Alliance of Australian Retailers Submission on the exposure draft Tobacco Plain Packaging Bill 2011 and Consultation Paper. June Carter, O et al... Measuring the effect of cigarette plain packaging on transaction times and selection errors in a simulation experiment. Tob Control /tobaccocontrol Carter, O et al. Plain packaging for cigarettes improves retail transaction times. BMJ 2013; 346: f Padilla, J. The impact of plain packaging of cigarettes in the UK: a simulation exercise. A report for Philip Morris International, November Reed, H. Analysis and review of J. Padilla, The impact of plain packaging of cigarettes in the UK: a simulation exercise A report for Action on Smoking and Health. London. September ASH Briefing: Standardised tobacco packaging