11A.9Real-world research on the effects of plain packaging

Last updated: November 2018

Suggested citation: Greenhalgh, EM & Scollo, MM. InDepth 11A.9 Real-world research on the effects of plain packaging. In Scollo, MM and Winstanley, MH [editors]. Tobacco in Australia: Facts and issues. Melbourne: Cancer Council Victoria; 2018. Available from http://www.tobaccoinaustralia.org.au/chapter-11-advertising/11a-9-real-world-research-on-the-effects-of-plain- 

11A.9.1 Effects on smokers

The introduction of plain packaging legislation in Australia was informed by an understanding of the way packaging affects perceived appeal of tobacco products, noticeability and impact of health warnings, and perceptions of relative harmfulness.1 Experimental research conducted prior to implementation of the Tobacco Plain Packaging Act 2011,2 showed that, when compared with fully branded packs, plain packs made smoking and products less appealing to smokers, increased the effectiveness of health warnings, and (when packs were darker in colour) reduced misperceptions about relative harmfulness of cigarettes3 (see Section 11A.8 ).

Since being implemented, research has begun to investigate the effects of plain packaging on each of the intended mechanisms by which the Act was intended to contribute to its Objects2 including:

i. Reducing the appeal of tobacco products

Research in Victoria conducted over the phase-in period of plain packaging found that plain pack smokers perceived their cigarettes to be of lower quality and less appealing, and were more likely to think about and prioritise quitting when compared with branded pack smokers.4 A large survey of NSW smokers showed a significant increase in negative perceptions about packs in the months following implementation of the policy, including strong disagreement that the packs are attractive, fashionable, and influence their choice of brand.5 National research comparing smokers’ attitudes pre- and post-implementation supported these preliminary results; one year after plain packaging, more smokers disliked their pack, perceived lower pack appeal, lower cigarette quality, lower satisfaction, and lower value, and disagreed brands differed in prestige.6 Another study found that Australian smokers experienced a significant decrease in the extent to which they identified with their cigarette brand following the introduction of plain packaging, and this was associated with lower smoking behaviours and increased intentions to quit.7 Although exposure to plain packaging appears to be more variable (due to purchasing duty free or online), cigar and cigarillo smokers also report reduced product appeal post-implementation.8 Among Aboriginal and Torres Strait Islander peoples, compared with pre-plain packaging, younger people post-implementation of the policy were less likely to view some brands as more prestigious than others.9

The appeal of cigarettes packs also decreased significantly among Australian adolescents following the introduction of plain packaging. Findings also suggested that plain packs were beginning to reduce the pack’s ability to communicate messages about the brands and cigarettes; adolescents reported higher levels of uncertainty regarding whether brands differed in their ease of being smoked, and more disagreement that some brands have better looking packs.10  

ii. Increasing the effectiveness of health warnings

The introduction of plain packs was associated with a greater salience and self-reported impact of the health warnings among a large sample of NSW smokers. Compared with pre-policy, smokers were more likely to report thoughts and concerns about quitting, seeing only the warnings on the packs, and feeling like they should hide their packs. These responses were comparable to those measured when pictorial health warnings were first introduced on packs in 2006, suggesting that an additional benefit of plain packs has been reversing a decline over time in the impact of the warnings.5 Research post-implementation also found that Australian smokers preferentially attended to and noticed the larger warnings more than they did pre-implementation.11 Similarly, one year post-implementation, more smokers noticed health warnings and attributed their motivation to quit to the warnings. Smokers also avoided specific health warnings when purchasing cigarettes.6 Cigar and cigarillo smokers exposed to plain packaging also report greater noticeability of graphic health warnings (GHWs).8

Australian adolescents’ acknowledgement of the health risks of smoking remained high before and after the implementation of plain packs, and the new health warnings significantly increased their awareness that smoking causes bladder cancer.12  

iii. Reducing the ability of the packaging to mislead consumers about the harmful effects of tobacco use

Evaluation of changes in beliefs following implementation suggested some (if more limited) impact on misperceptions about the relative harmfulness of tobacco products.

Prior to implementation, several of the manufacturers reassured smokers that the product itself would not change following implementation.13 Not surprisingly, there was no increase in the proportion of smokers who believed that products were more harmful than they were a year ago. The variant names were allowed to remain on the packs (for example, red, blue, light blue, silver, white),13 so it was also not surprising that there was no decline in the proportion of smokers who believe that brands differ in strength. Despite these two mitigating factors, there was a small increase in the proportion of smokers who believed that brands do not differ in harm.6 Among Indigenous Australians, one study similarly found that plain packaging had reduced misperceptions that some brands are healthier than others.9  

Effects on uptake, cessation, relapse, and exposure?

Uptake

Research conducted on the effects of regulating packaging among secondary school students provides some encouraging evidence of a disruption in uptake. Studies of secondary school students in two large Australian states examined changes between 2011 and 2013 in exposure to packs, attitudes, and beliefs about packs and brands,10 and beliefs about health effects.12 These studies also reported incidentally on smoking status. Among those who had seen cigarette packs in the previous six months, the percentage of students defined as non-susceptible never smokers (i.e., had never smoked a cigarette and were certain they would not smoke in the next year) significantly increased and the proportions defined as experimental (had at least a puff of a cigarette, but had not smoked in the last week) and committed smokers declined significantly. 

A study funded by the Government of France and published in Tobacco Control in November 2018 concluded that compared to immediately before introduction of plain packs, French adolescents were more likely to report fear of the consequences of smoking and that smoking is dangerous. They were also less likely to report that their friends and family accept smoking. Additionally, smoking initiation significantly decreased and smokers’ attachment to their tobacco brand also decreased. 14

Cessation

There was also evidence of increased cessation activity among adult smokers. A study examining “Quitline” calls in the Australian state of New South Wales found, similar to the pattern after the initial introduction of GHWs in 2006, calls increased by 78%, peaking four weeks after the start of the transition to PP. Notably though, calls remained elevated for six months, a longer time than that observed after the introduction of the 2006 GHWs.15 Among a large sample of Australian adult smokers, plain packaging increased short-term rates of quit intentions, pack avoidance, stopping themselves from smoking, and quit attempts during the transition period.16 During the first 12 months after policy implementation, reduced appeal and increased effectiveness of graphic health warnings in response to the new packs also predicted one month later quitting-related thoughts and behaviours such as increased levels of pack avoidance, stubbing out prematurely and quit attempts.17

Exposure to modelling of smoking

Following the implementation of plain packaging, a significant decrease was observed in smoking and the number of packs clearly visible on tables at outdoor café strips. A minority of smokers also actively concealed their packs. The authors suggested that plain packaging was helping to reduce exposure of young people to tobacco promotion and reduce perceptions of smoking prevalence.18 One year later, a sustained reduction in visible smoking and packs at outdoor café strips was observed, again suggesting that plain packaging may be changing norms about smoking. Such changes in norms may in turn support quit attempts, reduce the risk of relapse, and reduce exposure to tobacco and uptake by young people.19 Another study two years post-implementation found that the effects of plain packaging on pack display and smoking were sustained at venues where children were present, but not at venues where children were not present. The authors suggest that more regular refreshment of graphic health warnings may be needed to prolong the positive effects of plain packaging on these behaviours.20

Industry assessments of this evidence

Tobacco companies have been highly critical of research funded by the Australian Department of Health conducted in Australia.21 They have commissioned critiques of the research and submitted these to the post-implementation review of plain packaging in Australia,22 to a Senate Inquiry on personal liberty in Australia,23 and to parliamentary and departmental consultations considering legislation in other countries.24-26 Some of the major critiques were promoted on company websites including here.

Effects on prevalence?

Plain packaging is one in a comprehensive set of tobacco control measures that, together, aim to reduce the prevalence of smoking. Its long-term contribution to these efforts will likely be through achieving its goals of reducing the appeal of tobacco products, increasing the efficacy of health warnings, and reducing the ability of packaging to mislead consumers.27  

Data from the Australian Secondary School Survey on Smoking Alcohol and Drugs showed a substantial decline in smoking among secondary school students between 2011 and 2014.28 While many factors—including many other elements of tobacco control policy—would have contributed to this decline, the changes in smoking status between 2011 and 2013 reported above (during a period where there were no real increases in prices and no other major changes in policy) are suggestive of a contribution from plain packaging.

Data from the National Drugs Strategy Household Survey in 2013 indicated a historic low in smoking prevalence following the implementation of plain packaging, with only 12.8 % smoking daily29 and a decline between 2013 and 2010 that was substantially larger than previous three-yearly falls. Although there was no overall decline between 2013 and 2016, there was a significant decrease in smoking prevalence among 18–24 year olds, and among the most disadvantaged Australians. There was also a significant increase in never smokers (see Chapter one and Cancer Council Victoria’s fact sheet). 

Researchers based in Europe reconstructed and analysed Roy Morgan monthly smoking prevalence data that they obtained from industry-funded reports purporting to show no decrease in smoking prevalence following the introduction of plain packaging. In contrast to the industry-funded conclusions, they found that between 2001 and 2013, the three key tobacco control measures that were introduced (comprehensive smoke-free policies, the large tax increase of April 2010 and plain packaging) were all associated with a significant reduction in smoking prevalence. In particular, the reduction in prevalence following the introduction of plain packaging appears to have been even greater than expected.30 A similar study, this time looking at smoking prevalence among children, also contradicted industry-funded findings and concluded that there was a decline in youth smoking prevalence following the introduction of plain packaging in Australia.31

The Post-Implementation Review of plain packaging legislation in Australia22 includes expert analysis of smoking prevalence also based on Roy Morgan Company’s single source survey between 2001 and 2015. Controlling for the effects of tax increases and a range of other policies over this period, the analysts conclude that plain packaging policy contributed approximately 0.55% of the 2.2% decline in smoking prevalence over the 34 months following implementation.

Public support?

Several studies have also found widespread public support for plain packaging legislation in Australia. One found a substantial increase in support from pre- to post-implementation among Australian smokers,32 while another found consistently high support among adults in the state of Victoria, along with decreasing disapproval over time.33 Support for plain packaging also increased from pre- to post-implementation among adolescents and young adults.34

11A.9.2 Effects on sales

In the lead up to the implementation of plain packaging, the tobacco industry argued that the legislation would cause: a decrease in the use of premium and mainstream brands and an increase in use of value brands; a decline in prices paid for tobacco products, particularly for premium brands; and in turn, an increase in the consumption of tobacco products.35-37  

Since the legislation has come into effect, there have been a number of analyses of data relevant to these predictions. 

Brand share and prices

Recommended retail prices of tobacco products increased across the market following the implementation of plain packaging.38 A study that looked at the advertised prices in retail outlets across Australia found that the price of cigarettes most prominently promoted on price boards did not fall in the months following implementation of plain packaging (as was predicted by the tobacco industry); rather, retail prices continued to increase, even at the lowest-priced end of the market.39 Results from large cross-sectional surveys of adult smokers showed an increase in the proportion of people using value brands following the introduction of plain packaging, which was attributed largely to the increased availability and affordability of such brands in smaller pack sizes. However, contrary to tobacco industry predictions, prices paid for cigarettes increased, with the largest increases among premium brands.

Reported consumption by smokers and total population consumption and sales

Even with the increased availability and use of value brands, reported consumption did not change significantly among remaining smokers following implementation.40

Across the market as a whole, Imperial Tobacco reported to its international shareholders at least an immediate decline in sales.41 Tobacco companies point to steady wholesale shipment figures of tobacco products over the period of implementation,42, 43 however it is difficult to interpret these figures given that the policy itself required companies to provide extra stock during the implementation period in order to comply with the legislation. Data from the Australian Government suggest a continuing decline in per capita consumption of tobacco products44 (for a detailed analysis, see Cancer Council Victoria’s fact sheet). 

11A.9.3 Effects on use of illicit tobacco

One of the tobacco industry’s predictions regarding plain packaging was that it would allow for easier and therefore increased counterfeiting; illicit tobacco would ‘spiral out of control’ and lead to greater uptake and use.45 It argued that organised crime gangs would experience unprecedented profits, while the new legislation would disadvantage honest retailers and smokers.46, 47 KPMG and Deloitte have released a series of tobacco industry funded reports claiming that there has been an increase in use of illicit tobacco since 2013; however they have provided no evidence of increases in counterfeiting of local brands. Critiques of these reports have identified fundamental problems with the internet and litter surveys upon which estimates of prevalence of use of illicit tobacco are based (see the reports and their critiques here. For a detailed analysis, see Cancer Council Victoria’s fact sheet). 

Research independent of the tobacco industry has consistently found minimal use of illicit tobacco in Australia, both before and after the introduction of plain packaging. Data from the National Drug Strategy Household Survey in 2016 found that only 3.8% of smokers aged 14 years and older reported currently using unbranded loose tobacco, a similar proportion to 2013 (3.6%) and lower than pre-implementation (4.9% in 2010).48 Cross-sectional surveys of smokers interviewed before, during, and one year after implementation showed no significant changes across time in the proportion of smokers reporting current use of unbranded illicit tobacco.49 A study exploring the availability of illicit tobacco in small retail outlets found no increase in retailers’ willingness to sell illicit tobacco post-implementation, and overall numbers of purchased illicit packs were negligible.50 A large national survey of current cigarette smokers conducted continuously from six months before implementation to 15 months after found no evidence of increased use of contraband cigarettes, no increase in purchase from informal sellers, and no increased use of illicit tobacco.51   

11A.9.4 Effects on retailers

Since the implementation of plain packaging, a number of studies have tested opponents’ predictions that the legislation would have a range of negative outcomes on retailers. Suggestions that serving times would significantly increase due to the products being difficult to locate and differentiate have not been born out; one study found that plain packaging actually resulted in modest gains in retailer efficiency.52 Others found a small, temporary increase in cigarette pack retrieval times immediately following plain packaging implementation, which quickly returned to baseline. Thus, effects were minor and short-lived.53, 54  

Opponents of the legislation also argued that the longer serving times would result in consumers shifting their custom from small retailers to large supermarkets. A telephone survey of Victorian smokers before, during, and after implementation found no evidence that small retail outlets had lost smoker patrons, or that there was an increase in purchases from supermarkets.49 Follow-up research—this time using a large, nationwide sample—replicated these findings.55   

Relevant news and research

For recent news items and research on this topic, click here.(Last updated November 2018)

 

References 

1. Cancer Council Victoria. Plain packaging of tobacco products: A review of the evidence. Melbourne: Cancer Council Victoria, 2011. Available from: http://www.cancervic.org.au/plainfacts/browse.asp?ContainerID=plainfacts-evidence.

2. Tobacco Plain Packaging Act. No. 148 2011; Available from: http://www.comlaw.gov.au/Details/C2013C00190.

3. Moodie C, Stead M, Baulda L, McNeill A, Angusa K, et al. Plain tobacco packaging: A systematic review. Stirling, Scotland: University of Stirling, 2011. Available from: http://phrc.lshtm.ac.uk/project_2011-2016_006.html.

4. Wakefield MA, Hayes L, Durkin S, and Borland R. Introduction effects of the Australian plain packaging policy on adult smokers: A cross-sectional study. BMJ Open, 2013; 3(7). Available from: http://www.ncbi.nlm.nih.gov/pubmed/23878174

5. Dunlop SM, Dobbins T, Young JM, Perez D, and Currow DC. Impact of Australia's introduction of tobacco plain packs on adult smokers' pack-related perceptions and responses: Results from a continuous tracking survey. BMJ Open, 2014; 4(12):e005836. Available from: http://www.ncbi.nlm.nih.gov/pubmed/25524542

6. Wakefield M, Coomber K, Zacher M, Durkin S, Brennan E, et al. Australian adult smokers’ responses to plain packaging with larger graphic health warnings 1 year after implementation: Results from a national cross-sectional tracking survey. Tobacco Control, 2015; 24:ii17-ii25. Available from: http://tobaccocontrol.bmj.com/content/24/Suppl_2/ii17.full

7. Webb H, Jones BM, McNeill K, Lim L, Frain AJ, et al. Smoke signals: The decline of brand identity predicts reduced smoking behaviour following the introduction of plain packaging. Addictive Behaviors Reports, 2017; 5:49-55. Available from: https://www.ncbi.nlm.nih.gov/pubmed/29450227

8. Miller C, Ettridge KA, and Wakefield MA. “You’re made to feel like a dirty filthy smoker when you’re not, cigar smoking is another thing all together.” responses of Australian cigar and cigarillo smokers to plain packaging. Tobacco Control, 2015; 24:ii58-ii65. Available here: https://tobaccocontrol.bmj.com/content/24/Suppl_2/ii58

9. Maddox R, Durkin S, and Lovett R. Plain packaging implementation: Perceptions of risk and prestige of cigarette brands among aboriginal and torres strait islander people. Australian and New Zealand Journal of Public Health, 2016; 40(3):221–5. Available from: http://www.ncbi.nlm.nih.gov/pubmed/26713418

10. White V, Williams T, and Wakefield M. Has the introduction of plain packaging with larger graphic health warnings changed adolescents’ perceptions of cigarette packs and brands? Tobacco Control, 2015; 24:ii42-ii9. Available from: http://tobaccocontrol.bmj.com/content/24/Suppl_2/ii42.full

11. Yong HH, Borland R, Hammond D, Thrasher JF, Cummings KM, et al. Smokers' reactions to the new larger health warning labels on plain cigarette packs in australia: Findings from the ITC Australia project. Tobacco Control, 2015. Available from: http://www.ncbi.nlm.nih.gov/pubmed/25700365

12. White V, Williams T, Faulkner A, and Wakefield M. Do larger graphic health warnings on standardised cigarette packs increase adolescents' cognitive processing of consumer health information and beliefs about smoking-related harms? Tobacco Control, 2015; 24:ii50-ii7. Available from: http://tobaccocontrol.bmj.com/content/24/Suppl_2/ii50.full

13. Scollo M, Occleston J, Bayly M, Lindorff K, and Wakefield M. Tobacco product developments coinciding with the implementation of plain packaging in Australia. Tobacco Control, 2014; 24(e1):e116-22. Available from: http://tobaccocontrol.bmj.com/content/early/2014/04/30/tobaccocontrol-2013-051509.short

14. El-Khoury Lesueur F, Bolze C, Gomajee R, White V, and Melchior M. Plain tobacco packaging, increased graphic health warnings and adolescents’ perceptions and initiation of smoking: Depict, a French nationwide study. Tobacco Control, 2018. Available from: https://tobaccocontrol.bmj.com/content/tobaccocontrol/early/2018/11/08/tobaccocontrol-2018-054573.full.pdf

15. Young J, Stacey I, Dobbins T, Dunlop S, Dessaix A, et al. Association between tobacco plain packaging and Quitline calls: A population-based, interrupted time-series analysis. The Medical Journal of Australia, 2014; 200(1):29–32. Available from: http://www.ncbi.nlm.nih.gov/pubmed/24438415

16. Durkin S, Brennan E, Coomber K, Zacher M, Scollo M, et al. Short-term changes in quitting-related cognitions and behaviours after the implementation of plain packaging with larger health warnings: Findings from a national cohort study with Australian adult smokers. Tobacco Control, 2015; 24:ii26-ii32. Available from: http://tobaccocontrol.bmj.com/content/24/Suppl_2/ii26.full

17. Brennan E, Durkin S, Coomber K, Zacher M, Scollo M, et al. Are quitting-related cognitions and behaviours predicted by proximal responses to plain packaging with larger health warnings? Findings from a national cohort study with Australian adult smokers. Tobacco Control, 2015; 24:ii33-ii41. Available from: http://tobaccocontrol.bmj.com/content/24/Suppl_2/ii33.full   

18. Zacher M, Bayly M, Brennan E, Dono J, Miller C, et al. Personal tobacco pack display before and after the introduction of plain packaging with larger pictorial health warnings in Australia: An observational study of outdoor cafe strips. Addiction, 2014; 109(4):653-62. Available from: http://www.ncbi.nlm.nih.gov/pubmed/24428427

19. Zacher M, Bayly M, Brennan E, Dono J, Miller C, et al. Personal pack display and active smoking at outdoor café strips: Assessing the impact of plain packaging 1 year post-implementation. Tobacco Control, 2015; 24:ii94-ii7. Available from: http://tobaccocontrol.bmj.com/content/24/Suppl_2/ii94.full  

20. Brennan E, Bayly M, Scollo M, Zacher M, and Wakefield MA. Observed smoking and tobacco pack display in australian outdoor cafes 2 years after implementation of plain packaging. European Journal of Public Health, 2018. Available from: https://www.ncbi.nlm.nih.gov/pubmed/29596579

21. Department of Health, National monthly tobacco plain packaging tracking survey. Australian Government. Available from: http://www.health.gov.au/internet/main/publishing.nsf/content/tobacco-plain-packaging-evaluation#a.

22. Australian Government Department of Health. Tobacco plain packaging post–implementation review - Department of Health.  2016. Available from: https://ris.pmc.gov.au/2016/02/26/tobacco-plain-packaging.

23. Senate Economics References Committee, Inquiry into personal choice and community impacts. Parliament of Australia; 2015. Available from: http://www.aph.gov.au/Parliamentary_Business/Committees/Senate/Economics/Personal_choice.

24. UK Government. Consultation outcome. Standardised packaging of tobacco products: Draft regulations. 2015. Available from: https://www.gov.uk/government/consultations/standardised-packaging-of-tobacco-products-draft-regulations

25. Department of Health, Standardised/plain pack cigarettes. Government of Ireland; 2014. Available from: https://health.gov.ie/healthy-ireland/tobacco/standardisedplain-pack-cigarettes/

26. Ministry of Health, Plain packaging. New Zealand Government; 2014. Available from: http://www.health.govt.nz/our-work/preventative-health-wellness/tobacco-control/plain-packaging.

27. Tobacco Plain Packaging Bill 2011 - Exposure draft: Explanatory memorandum. 2011; Available from: https://www.legislation.gov.au/Details/C2011B00128/Explanatory%20Memorandum/Text

28. White V and Williams T, Australian secondary school students’ use of tobacco in 2014. Centre for Behavioural Research in Cancer, Cancer Council Victoria; 2015. Available from: http://www.nationaldrugstrategy.gov.au/internet/drugstrategy/Publishing.nsf/content/school11.

29. Australian Institute of Health and Welfare. National Drug Strategy Household Survey detailed report: 2013. Cat. no. PHE 183 Canberra: AIHW, 2014. Available from: http://www.aihw.gov.au/publication-detail/?id=60129549469&tab=3.

30. Diethelm P and Farley T. Refuting tobacco-industry funded research: Empirical data shows decline in smoking prevalence following introduction of plain packaging in australia. Tobacco Prevention & Cessation (European Network of Smoking and Tobacco Prevention), 2015; 1. Available from: http://www.tobaccopreventioncessation.com/Refuting-tobacco-industry-funded-research-empirical-data-shows-decline-in-smoking-prevalence-following-introduction-of-plain-packaging-in-Australia,60650,0,2.html

31. Diethelm PA and Farley TM. Re-analysing tobacco industry funded research on the effect of plain packaging on minors in Australia: Same data but different results. Tobacco Prevention & Cessation, 2017; 3(November). Available from: http://dx.doi.org/10.18332/tpc/78508

32. Swift E, Borland R, Cummings KM, Fong GT, McNeill A, et al. Australian smokers’ support for plain or standardised packs before and after implementation: Findings from the ITC four country survey. Tobacco Control, 2015; 24(6):616-21. Available from: http://tobaccocontrol.bmj.com/content/24/6/616.abstract

33. Hayes L, Wakefield MA, and Bain E. Change in public support for the introduction of plain packaging and new, enlarged graphic health warnings in the Australian state of Victoria, 2011–2013. Tobacco Control, 2017; 26(6):627-8. Available from: http://tobaccocontrol.bmj.com/content/tobaccocontrol/26/6/627.full.pdf

34. Dunlop S, Perez D, Dessaix A, and Currow D. Australia's plain tobacco packs: Anticipated and actual responses among adolescents and young adults 2010–2013. Tobacco Control, 2017; 26(6):617-26. Available from: http://tobaccocontrol.bmj.com/content/tobaccocontrol/26/6/617.full.pdf

35. British American Tobacco Australia. Submission on the Plain Packaging Bill 2011. Canberra: Department of Health and Ageing Consultation website, 2011. Available from: http://content.webarchive.nla.gov.au/gov/wayback/20130904173432/http://www.yourhealth.gov.au/internet/yourhealth/publishing.nsf/Content/2EE2F6F3EC74F628CA2579540005F68B/$File/British%20American%20Tobacco%20Australia%20-%20Public%20Submission.pdf  

36. Philip Morris Limited. Commoditising tobacco products through plain packaging will harm public health, violate treaties and does not meet the test of 'evidence-based policy' Submission on the Tobacco Plain Packaging Bill Exposure Draft Melbourne 2011. Available from: http://webarchive.nla.gov.au/gov/20130329051831/http://www.yourhealth.gov.au/internet/yourhealth/publishing.nsf/Content/Phillip-Morris-Limited~Phillip-Morris-Limited-2.

37. Imperial Tobacco. Submission to the Department of Health and Ageing regarding the Tobacco Plain Packaging bill 2012 (exposure draft) and  consultation paper, 2011: Sydney. Available from: http://webarchive.nla.gov.au/gov/20130329044623/http://www.yourhealth.gov.au/internet/yourhealth/publishing.nsf/Content/ppit~ncr~loe

38. Scollo M, Bayly M, and Wakefield M. Did the recommended retail price of tobacco products fall in Australia following the implementation of plain packaging? Tobacco Control, 2015; 24:ii90-ii3. Available from: http://tobaccocontrol.bmj.com/content/24/Suppl_2/ii90.full

39. Scollo M, Bayly M, and Wakefield M. The advertised price of cigarette packs in retail outlets across Australia before and after the implementation of plain packaging: A repeated measures observational study. Tobacco Control, 2015; 24:ii82-ii9. Available from: http://tobaccocontrol.bmj.com/content/24/Suppl_2/ii82.full

40. Scollo M, Zacher M, Coomber K, Bayly M, and Wakefield M. Changes in use of types of tobacco products by pack sizes and price segments, prices paid and consumption following the introduction of plain packaging in Australia. Tobacco Control, 2015; 24:ii66-ii75. Available from: http://tobaccocontrol.bmj.com/content/24/Suppl_2/ii66.full

41. Cooper A. Preliminary results 2013, transcript of presentation to shareholders. London: Imperial Tobacco Ltd, 2013. Available from: http://www.imperialbrandsplc.com/content/dam/imperial-brands/corporate/investors/results-centre/2013/pr_2013_transcript.pdf.

42. British American Tobacco (New Zealand) Ltd. Proposal to introduce plain packaging of tobacco products in new zealand: Submission by British American Tobacco (New Zealand) limited. Wellington: Parliament of New Zealand, 2014. Available from: http://www.parliament.nz/en-nz/pb/sc/documents/evidence?Custom=00dbhoh_bill12969_1&Criteria.PageNumber=2.

43. British American Tobacco UK. Consultation on the introduction of regulations for the standardised packaging of tobacco products. Response of British American Tobacco UK limited. London: BATA UK, 2014. Available from: http://www.bat.com/group/sites/uk__9d9kcy.nsf/vwPagesWebLive/DO9DKJEB/$FILE/medMD9MWB4B.pdf?openelement.

44. Australian Government. Total tobacco clearances data. Available from:  https://treasury.gov.au/foi/total-tobacco-clearances-data/

45. Crowe D. Campaign questions expensive plain packaging experiment, 2011. Available from: http://www.bata.com.au/group/sites/bat_7wykg8.nsf/vwPagesWebLive/DO7WZEX6/$FILE/medMD8GX5XH.pdf?openelement.

46. British American Tobacco Australia. Booming illegal tobacco costs government billions. Media release, Sydney: BATA, 2013. Available from: http://www.bata.com.au/group/sites/bat_9rnflh.nsf/vwPagesWebLive/DOA3CLYP/$FILE/medMD9D4SVZ.pdf?openelement.

47. British American Tobacco Australia. Sydney number one hot spot for illegal tobacco. Sydney 2011. Available from: http://www.bata.com.au/group/sites/bat_9rnflh.nsf/vwPagesWebLive/DOA3CLZS/$FILE/medMD8J5782.pdf?openelement.

48. Australian Institute of Health and Welfare. National Drug Strategy Household Survey (NDSHS) 2016 key findings data tables. Canberra: AIHW, 2017. Available from: https://www.aihw.gov.au/reports/illicit-use-of-drugs/2016-ndshs-detailed/data.

49. Scollo M, Zacher M, Durkin S, and Wakefield M. Early evidence about the predicted unintended consequences of standardised packaging of tobacco products in Australia: A cross-sectional study of the place of purchase, regular brands and use of illicit tobacco. BMJ Open, 2014; 4(8). Available from: http://bmjopen.bmj.com/content/4/8/e005873.abstract

50. Scollo M, Bayly M, and Wakefield M. Availability of illicit tobacco in small retail outlets before and after the implementation of Australian plain packaging legislation. Tobacco Control, 2014. Available from: http://www.ncbi.nlm.nih.gov/pubmed/24721966

51. Scollo M, Zacher M, Coomber K, and Wakefield M. Use of illicit tobacco following introduction of standardised packaging of tobacco products in Australia: Results from a national cross-sectional survey. Tobacco Control, 2015; 24:ii76-ii81. Available from: http://tobaccocontrol.bmj.com/content/24/Suppl_2/ii76.full

52. Carter O, Welch M, Mills B, Phan T, and Chang P. Plain packaging for cigarettes improves retail transaction times. British Medical Journal, 2013; 346:f1063. Available from: http://www.ncbi.nlm.nih.gov/pubmed/23423370

53. Wakefield M, Bayly M, and Scollo M. Product retrieval time in small tobacco retail outlets before and after the Australian plain packaging policy: Real-world study. Tobacco Control, 2014; 23(1):70-6. Available from: http://www.ncbi.nlm.nih.gov/pubmed/23712769

54. Bayly M, Scollo M, and Wakefield M. No lasting effects of plain packaging on cigarette pack retrieval time in small Australian retail outlets. Tobacco Control, 2014; 24(e1):e108-9. Available from: http://tobaccocontrol.bmj.com/content/early/2014/05/30/tobaccocontrol-2014-051683.short

55. Scollo M, Coomber K, Zacher M, and Wakefield M. Did smokers shift from small mixed businesses to discount outlets following the introduction of plain packaging in Australia? A national cross-sectional survey. Tobacco Control, 2015; 24:ii98-ii100. Available from: http://tobaccocontrol.bmj.com/content/24/Suppl_2/ii98.full


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