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Tobacco Advertising And Promotion Bill

UNISON Scotland's response

to Scottish Executive Consultation Document and Draft Regulatory Impact Assessment on Regulations Concerning Sponsorship, Brandsharing, and Point of Sale Advertising.

November 2002

Executive Summary

UNISON welcomes the opportunity to respond to the consultation on the Regulations concerning sponsorship, brandsharing and point of sale advertising of tobacco.

  • We agree with proposals to ban tobacco advertising.
  • We believe that tobacco promotion should also end, there should be allowances for the continuation of tobacco sponsorship of global events.
  • Brand sharing should be prohibited.
  • UNISON believes these regulations should be introduced as soon as is possible.


UNISON is Scotland's largest trade union representing over 145,000 members working in the public sector. We are the largest union in the health service, so our members deal with the effects of tobacco smoking on a daily basis. UNISON Scotland also has an interest in the Bill's proposals as a public health issue for the people of Scotland.

This paper constitutes UNISON Scotland's response to the consultation document issued by the Scottish Executive on the proposals for the tobacco advertising and promotion.


General Comments

UNISON Scotland strongly supports the proposals to end the advertising and promotion of tobacco. We agree with the Cancer Research charities that a ban on tobacco advertising is essential for the future health of Scotland. Cancer Research points to statistics that:

  • Over 120,000 people in the UK die from tobacco related diseases and smoking is responsible for 1/3 of all cancer deaths.
  • Tobacco companies face an ongoing struggle to replenish their market with new customers because smoking kills around 330 smokers every day in the UK.

  • Tobacco causes 22% of all deaths in Scotland (Callum C , The UK Smoking Epidemic, Health Education Authority, London) - compared to 19% in England.
  • Tobacco advertising bans in other countries have led to per capita consumption of cigarettes has dropping by between 14 and 37%.

With these appalling statistics it is clear that the continuation of tobacco smoking is having a detrimental impact on Scotland's health record. Evidence shows that tobacco advertising and promotion does encourage people, particularly young people, to start smoking, and the addictive nature of tobacco ensures that they continue. If we are serious about tackling Scotland's atrocious health record, then we have to address the causes - which clearly include smoking.

Sponsorship (Transitional Regulations) Consultation Document and Regulatory Impact Assessment

UNISON believes that the tobacco advertising should cease as soon as possible and we agree with the proposals to allow existing tobacco sponsorship agreements to run until 30 July 2003, ending thereafter.

We have concerns that tobacco sponsorship of global events are being allowed to operate for an extra three years until 1 October 2006. Global events, by their nature have the biggest impact and widest geographical, TV and media coverage. The continuation of global events will cancel out the positive impact of ending the national and local tobacco advertising. UNISON believes that if we are serious about tackling the issues, then we need to end all tobacco promotion and advertising as soon as possible.

The ending of tobacco sponsorship should not impact too drastically on sponsorship. There are a range of companies and organisations that are already involved in sponsorship of sporting, educational and other social events that are not connected with tobacco. We would hope that this creates opportunities for them to support such activities.

We agree that tobacco sponsorship undermines health promotion, particularly sponsorship of sporting activities. Tobacco advertising does have a role in legitimising smoking as an acceptable activity especially for young people during an impressionable time of their lives. The view from industry that tobacco companies see sponsorship as a vital means of promoting product as glamorous and exciting only illustrates the importance they place on sponsorship and promotion as a means of associating their product with a "positive" activity to sell it to more people.

Sports which rely on tobacco sponsorship tend to be those which operate on multi-million pound budgets in the first place, such as Formula One and snooker. We believe that it is appropriate that these sports should look elsewhere for sponsorship.

Point of Sale - Consultation Document & Regulatory Impact Assessment

UNISON Scotland agrees that this legislation should provide an appropriate framework for the protection of public health and the transaction of legitimate business. We welcome the fact that the legislation will cover all situations where tobacco may be sold, and we support the restrictions of adverts in places where tobacco is sold. The proposed restrictions on websites selling tobacco are also welcome , we agree it is appropriate that adverts for tobacco should only be on pages accessed from home page.

Branding - Consultation Document and Regulatory Impact Assessment

UNISON agrees with the general prohibition on the shared use of names, emblems and other features between tobacco and non-tobacco products. We believe that bans are only really effective if they are comprehensive, and if tobacco companies are allowed to promote their brand through non-tobacco products, this is having the same affect as promoting tobacco directly.

We also agree with proposals to ban brand-sharing. Transferring tobacco branding into new but complementary fields clearly does need regulating, as the evidence cited shows that brand sharing does promote and encourage smoking when used by tobacco companies.

Timing of introduction

As stated above UNISON Scotland believes that these restrictions on tobacco advertising and promotion should be introduced as soon as possible. However we do recognise that the process of changing the rules on tobacco advertising and promotion may take time, and that allowing a transitional period may be appropriate, although we would suggest that the transitional period could be less than the 18 months set out in the consultation document.

For Further Information Please Contact:

Matt Smith, Scottish Secretary

14, West Campbell Street,
Glasgow G2 6RX
Tel 0141-332 0006 Fax 0141 342 2835

e-mail matt.smith@unison.co.uk

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