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19 June 2014

Open Letter to Michael Moore, CEO, Public Health Association of Australia


Dear Mr. Moore,

In an 18 June 2014 Public Health Association of Australia press release, you were quoted as saying, if the
tobacco industry has nothing to hide, why would it refuse to release reports on which it bases claims about
trends in Australia?

Exactly which reports are you referring to? Did you mean the analysis by renowned consulting firm London
Economics - publicly available here - which found no evidence of a change in smoking prevalence following
the implementation of plain packaging?

Was it the KPMG analysis of the Australian tobacco black market publicly available here which found
that not only did illicit trade increase following the implementation of plain packaging, but so did total
tobacco consumption. Was it the industry sales volume data for the past five years publicly available here
- which shows an increase in legal tobacco sales volumes after the implementation of plain packaging?

Was it the South Australian government data showing that smoking prevalence increased more than 16%
following the implementation of plain packaging at least thats what Health Minister Jack Snelling said,
here.

Perhaps, because as you say, plain packaging is aimed especially at children and young people, you were
referring to the analysis of adolescent smoking prevalence by experts from the Universities of Saarland and
Zurich which failed to find any evidence for an actual Plain Packaging effect on minors. Perhaps you
missed that paper when it was published in the prestigious University of Zurich Department of Economics
Working Paper Series if so, you can find it here. Had you seen this publicly available report, you would
know that despite conducting multiple analyses of publicly available youth smoking prevalence data and
structuring them in a way that was most likely to find that plain packaging reduced smoking, the experts
could find no evidence of a plain packaging effect.

We also noted with some concern your accusation that the tobacco industry is lying about the impacts of
plain packaging. This accusation is completely false. The real question is whether relying on the Australian
Bureau of Statistics (ABS) household expenditure data to support claims that plain packaging is a winner
is completely honest.

The data you rely on show that, in December 2013, one year after the implementation of plain packaging,
household spending on tobacco had actually increased by 2.5%. In fact, in the three quarters before the
December 2013 excise hike of 12.5% impacted the market, household spending on tobacco went in one
direction up the first time it had increased since March 2010.

In addition, even the ABS admits that its data measures household expenditures only, not the actual
amount of tobacco consumed. It doesnt account for consumers switching to less expensive legal or even
black market tobacco, which would allow them to spend the same amount or even less but buy just as
much or more tobacco.




In the future, instead of accusing companies of lying, wed hope that the public discourse moves beyond
accusatory rhetoric that prevents sensible debate about tobacco policy and rather focus on the facts, even
when they are inconvenient.


Sincerely,

Chris Argent
Director Corporate Affairs
Philip Morris Limited