13.13 Best practice recommendations and future directions for tobacco price and tax policy

13.13.1  WHO Best practice recommendations for tobacco tax policy design and administration

With its ratification of the WHO Framework Convention on Tobacco Control (WHO FCTC), which came into force on 27 February 2005,¹ Australia is obligated to report on its rates of taxation for tobacco products in periodic reports to the Conference of Parties. The Convention (Part III, Article 6)² also states:

1. The Parties recognize that price and tax measures are an effective and important means of reducing tobacco consumption by various segments of the population, in particular young persons.
2. Without prejudice to the sovereign right of the Parties to determine and establish their taxation policies, each Party should take account of its national health objectives concerning tobacco control and adopt or maintain as appropriate measures which may include:
   1. implementing tax policies and, where appropriate, price policies, on tobacco products so as to contribute to the health objectives aimed at reducing tobacco consumption.

In 2017, the FCTC published Guidelines for Implementation of Article 6.³ This is complemented by a WHO technical manual on tax administration first published in 2010,⁴ then updated as the WHO Technical Manual on Tobacco Tax Policy and Administration in 2021.⁵ The Article 6 Guidelines³ are grounded in 6 guiding principles:

1. 1. 1. 1. Determining tobacco taxation policies is a sovereign right of the Parties
         2. Effective tobacco taxes significantly reduce tobacco consumption and prevalence
         3. Effective tobacco taxes are an important source of revenue
         4. Tobacco taxes are economically efficient and reduce health inequalities
         5. Tobacco tax systems and administration should be efficient and effective
         6. Tobacco tax policies should be protect from vested interests.

The 2021 WHO Technical Manual on Tobacco Tax Policy and Administration⁵ provides 26 recommendations for developing, administering, and evaluating effective tax policy. These recommendations are summarised in Table 13.13.1 below, with references to sections of this Chapter that describe these issues in more detail.

13.13.1.1    Areas to strengthen Australia’s tobacco tax administration

The WHO’s MPOWER report⁶ on the tax structure and tobacco prices in all member states provides a snapshot of Australia’s tobacco tax system. In 2022, Australia was characterised by very high tobacco prices, high levels of total taxation, and automatic adjustment of tobacco taxes for inflation. However, the dispersion of prices—that is, the price of the cheapest brand as a proportion of the price of a premium product—was relatively wide, with the cheapest pack costing only two-thirds of the price of a premium brand in 2022. There was also no change in affordability (as measured as share of GDP required to purchase 2000 cigarettes) between 2020 and 2022. In addition, the report identified that Australia had no policies for tax markings or stamps (covert or overt) and unique identifiers on tobacco products, including for tracking and tracing purposes.

Systems where tax rates are unequal across different types of tobacco products, such as cigarettes and RYO tobacco, provide an incentive for product switching when the price of the higher-taxed product increases more than the lower-taxed product.⁷ Equivalising, or harmonising, the tax on tobacco products—and emerging products with similar levels of risk to health—is important to maximising the effectiveness of a tax system.⁸ The different levels of tax on FMC and RYO products in Australia, and polices to harmonise the tax on these products, is described in detail in Sections 13.4.5 and 13.6.3.7.

13.13.2  Actions to reduce the affordability of tobacco products in the Australian National Tobacco Strategy 2022-2030

In 2023 the Australian Government released the 2022-2020 National Tobacco Strategy.⁹ Seven actions were identified to address the priority area of ‘Continue to reduce the affordability of tobacco products’ that emphasise the need to continually monitor and evaluate the impacts of tobacco excise increases, strengthen impact of future increases, and explore additional policies to reduce the affordability of tobacco.

1. 1. 1. 1. Continue to monitor the need for, and benefit of, changes in tobacco excise ad excise-equivalent duty.
         2. Amend the Commonwealth Tobacco Plain Packaging Act 2011 to standardise pack sizes and stick sizes of manufactured cigarettes, cigarillos and roll-your-own tobacco products.
         3. Review tobacco industry strategies and other practices that may be undermining the public health benefits of tobacco excise increases and implement strategies to prevent and minimise these practices.
         4. Analyse the effects of tobacco excise increases, including on young people and low-income populations.
         5. Complement tobacco excise increases with additional efforts to motivate and support quit attempts among low-income populations.
         6. Complement tobacco excise increases with additional efforts to prevent and minimise the illicit tobacco trade.
         7. Explore the potential impacts and feasibility of, and best practice regulatory approaches to, measures to further reduce affordability of tobacco products, such as introducing a minimum floor price on tobacco products and once-only price changes after each excise increases.

Minimum pricing policies are discussed further in Section 13.13.3.1 below.

13.13.3  Further pricing policies that could be applied in Australia

Tobacco companies ultimately set the price of tobacco products. Even strong tobacco taxation systems can be undermined by strategic price manipulations by the tobacco industry, both across and within types of tobacco products,¹⁰ This may be in the form of price promotions and discounting, price segmentation, and the relative price of different forms of tobacco. These pricing differentials can be further manipulated by varying the frequency and magnitude of price increases over time. For example, price increases resulting from tax increases can be minimised by staggering the increase over several months, rather than one large jump in price.¹¹

Tobacco products themselves can be designed to undermine tobacco taxes. Pack and pouch sizes can provide bulk-buy discounts, several price points, and make comparisons of unit pricing difficult for consumers at the point of sale. Product features including flavour capsules, tobacco blends, filter innovations, and varying stick lengths can introduce different price points and a sense of ‘premiumisation’ for products with these additional features. Additionally, even the name of tobacco products can have value connotations that seek to manipulate consumers. For example, roll-you-own tobacco pouches with names that imply a plentiful supply such as ‘Lasting’, ‘Endless’, and ‘Abundant’, and cigarette brand names that imply quality such as ‘Supreme’ and ‘Signature’. (See also Section 13.4 and Section 10.9).

People experiencing socioeconomic disadvantage, young people, and other priority population groups such as those experiencing homelessness, are particularly susceptible to these strategies. Disadvantaged groups are more likely to engage in price minimising behaviours when faced with tax increases, blunting the impact of price increases in these groups and further widening inequities in tobacco use.^7,12-14 Measures in addition to taxation that address tobacco prices can be used to leverage greater impact on disadvantaged populations.¹⁵

These product and pricing strategies are not able to be addressed by tobacco tax policies. The following sections outline policies that directly address the pricing and characteristics of tobacco products. Note, though, that these policies would be ineffective in the absence of a strong tax system.

13.13.3.1    Minimum pricing

Minimum pricing policies set specific prices below which tobacco products cannot be sold to consumers.⁷ Different minimum prices may be set for different types of tobacco product (e.g. cigarettes, roll your own tobacco, cigarillos). Minimum unit pricing can address price dispersion within types of tobacco products and selective price discounting. The minimum price increases the price of the lowest-priced products on the market, but does not impact the retail price of mid-priced or premium products. It has been suggested that minimum price policies can curtail the practice of price segmentation,^7,16 where tobacco companies position brands at different price points in the market. Tobacco companies maintain and exacerbate these price segments by differential pass through of tax increases, increasing the price of certain products more than others (see Section 13.4.6).^17,18

Minimum price laws for tobacco products have been implemented in almost half of all US states as part of efforts to protect the viability of small retailers in the face of unfair competition from large retail chains. Research on the effects of these laws suggests that regulations requiring a mark-up on wholesale prices of at least 25% and restricting trade discounts resulted in higher average prices both in the cheapest segment and cigarette prices overall. In the US context, those laws specifying a particular minimum price were simpler and easier to monitor and enforce,¹⁹ although tobacco companies have successfully challenged the structure of minimum price laws in numerous states.²⁰

Minimum price policies can eliminate the cheapest price segments, thereby having strong pro-equity impacts on tobacco use.^7,21,22 Because the price of all very cheap products are raised, but the cheapest products are increased more to reach the floor price, a minimum price would be expected to have a greater impact on very price sensitive smokers than just increasing the excise on all products equally.¹⁹ To be maximally effective, a the policy should be paired with bans on discounts and other forms of price promotion.²³

A limitation of minimum price policies is that tobacco companies and retailers remain free to set tobacco prices at any level above the minimum.¹⁰ Price segmentation and price dispersion can continue to grow because there is no limit on the upper range of prices. While some suggest that further raises to tobacco prices would not be problematic,²⁴ tobacco companies could opt to price some products very highly knowing that very consumers would opt to purchase these but that other products would seem cheap in comparison. Minimum pricing policies have also been criticised because the additional price of the tobacco product would become tobacco industry profit, unless the policy is structured as a simple minimum excise tax. For this reason, minimum excise taxes are more common than minimum price policies.⁷

13.13.3.2    Wholesale price cap regulation

In contrast to minimum pricing, a wholesale price cap system would establish a maximum wholesale price for tobacco products, specific to each type of tobacco.^10,25 That is, the wholesale price for all cigarettes would be capped at a uniform price, and the wholesale price of all RYO tobacco price would be capped at another price. The cap would be set and adjusted by a regulator, taking into account manufacturing and other costs, and a reasonable profit margin. Taxes and distributor and retailer costs, would then be added to determine the final price. To be maximally effective, the system would also need to mandate the timing of price increases so that tobacco companies (and retailers) could not engage in the strategic and incremental timing of price changes.¹⁰ This system effectively means a regulator, not the tobacco industry, would control the final price and timing of price increases. This policy also addresses the strong market power held by relatively few tobacco companies within most countries.²³ A wider benefit would be greater oversight of tobacco industry revenue and expenditure, such as advertising.²⁵

Another major impact of this system is that, by capping the prices that can be charged, it would limit the profits of tobacco companies. To achieve this, and prevent prices initially dropping when first implemented, excise rates would need to be increased to cover the portion of the final purchase price that was previously tobacco company profit. This would then become government revenue.^10,23,25

By limiting and equalising the upper limit of tobacco prices, a wholesale price cap would address the dispersion of prices across brands, price segments, and the differential pass-through of tax increases. Companies could theoretically choose to price their products well below this cap, however expert opinion suggests this would be unlikely for two reasons.¹⁰ First, the system greatly reduces revenue to tobacco companies, and they would be unlikely to further meaningfully cut profits. Second, the price cap would be reviewed at least annually, and could be reduced if tobacco prices had decreased during the review period.  

13.13.3.3    Retail licensing to regulate the price of tobacco products

In addition to their many other benefits to licensing tobacco retailers—see InDepth 11B—retail licensing schemes can be utilised to restrict the types of tobacco products that can be sold and their final price.¹⁰ For example, licensing conditions can prohibit the sale of flavoured tobacco products, enforce a minimum retail price, or prohibit price discounting and bulk-buy purchasing.²³ Failure to comply with these provisions could result in penalties and eventual cancellation of the license. Licensing schemes that require retailers to submit sales data on volumes and prices paid allow for more effective policy evaluation and public health research.

13.13.3.4    Bans on price discounting at the point of sale

In Australia, with taxes on tobacco products applicable only at a national level, consumers are not able to ‘shop for tax’ to seek lower-taxed products in different geographic areas, as in the US.²⁶ However prices across retailers and areas in Australia can be highly variable—see Section 13.4.7. Prices vary by type of retailer, where tobacconists and major supermarket chains have the lowest prices, over time, where prices of particular products are dropped for a short period, or by area, where prices in lower socioeconomic areas may be notably lower than higher socioeconomic areas.^27-31 Bulk-buy discounts are also frequently available for cartons or multi-packs.³²

A 2016 review of non-tax price policies noted that bans on price promotions were among the most prevalent in the literature.²³ To be maximally effective, price promotion bans should be comprehensive and explicitly prohibit all forms of discounting. These should include offers made to consumers, such as specials, coupons or bulk-buy purchases, but also discounts offered by wholesalers or tobacco companies such as rebates and buy-down programs.²³ The effectiveness of other tobacco pricing policies can also be greatly enhanced by bans on price promotions and discounts.⁷

13.13.3.5    Standardising tobacco pack and stick sizes

Policies that regulate the minimum pack size for tobacco products, typically cigarettes, are common. This prohibits very small packs that are attractive to young people. In the absence of  minimum pack sizes, tobacco companies may engage in ‘shrinkflation’ by introducing smaller pack sizes that offer fewer cigarettes for the same price as the pre-tax increase price, allowing consumers to continue purchasing their usual pack.^8,33,34 There has been no minimum RYO pouch size in Australia—until July 2025—and this has resulted in shrinking pouch sizes.^13,35

The unique previous tax structure and minimum pack size restrictions in Australia have resulted in a wide range of large pack sizes (see Section 13.4.2 and Section 13.6.3.3). This offers a range of potentially confusing price points, and a plethora of opportunities to down-trade to a smaller product that is cheaper up-front, or a larger product that offers better value per stick. Other countries, such as New Zealand and the UK, also feature a range of tobacco pack sizes. Varying cigarette stick dimensions in terms of length and diameter can also contribute to the range of product offerings. This also applies to RYO filters, which are available in ‘super slim’, ‘micro’, and ‘nano’ sizes, allowing consumers to roll cigarettes with less tobacco.³⁶

Scollo and Branston¹⁰ recommend that tobacco pack sizes should be standardised, as well as cigarette dimensions, so that only one size is available for sale in a given country. The pack size may vary by country, but should be large enough so that the upfront purchase price discourages young people, and small enough that existing consumers are not encouraged to consume more cigarettes by having more cigarettes available.³²

In December 2023, the Australian Parliament passed a bill that will require tobacco products sold in Australia to be in standard pack sizes (also known as pack size standardisation).³⁷ Cigarettes will only be able to be sold in packs of 20, and RYO and pipe tobacco will only be able to be sold in pouches of 30 grams. Pack size standardisation will come into effect on 1 July 2025. This policy will significantly impact the spread of upfront purchase prices available in Australia, but will not impact price segmentation.

13.13.3.6    Restricting the names and flavourings of tobacco products

Tobacco companies use variant names to convey information about the product to consumers, such as how it may taste or feel to smoke that product, or connotations of modernity, value, or reduce harm (among many others—see Sections 10.8 and 10.9). Seemingly premium products with higher price points can be used by the tobacco industry to cross-subsidise the price of more budget offerings.¹⁰

Uruguay has implemented a ban on variants, so that each brand is allowed only one presentation (variant).³⁸ From 1 July 2025, increased restrictions on the variant descriptors allowed on tobacco products and bans on characterising flavours, including menthol, will be introduced in Australia.³⁷ These bans will prohibit features such as flavour capsules and product names that imply positive qualities, among other restrictions.

13.13.3.7    Other approaches to regulate tobacco prices

These strategies may be incorporated into other policies, such as a wholesale price cap, or retail licensing scheme.

• Anti-forestalling measures: The anticipation of a tax increase can encourage tobacco suppliers (manufacturers or importers) to release a large volume of stock into the market before the tax increase is applied, also known as stockpiling.⁸ This may result in lower-priced tobacco available to consumers, or that tobacco companies receive extra profits if these products are sold at the post-tax increase price. To prevent this, measures may be implemented to restrict the volume of tobacco released in the lead-up to a tax increase and/or levies on existing stock to ensure it is sold at the post-tax increase price.³  
• Controlling the frequency of price changes: The prices of tobacco products are often incrementally changed around the time of a tax increase, rather than a one-off change in price as intended.¹¹ This smooths or cushions the impact of the price increase on consumers.⁸ A measure to restrict the number of times per year that tobacco prices could be adjusted would enhance the effectiveness of routine tax adjustments and pre-announced tax increases, and would also restrict price discounting. It has been suggested that large, sudden tax increases may be more effective that pre-announced increases because the tobacco industry (and consumers) are not able to pre-emptively respond.¹⁸
• Restricting the entry of new products to the market: Freezing the tobacco market would prohibit the introduction of new cheap products, or products designed to entice consumers.⁸ In Indonesia, tobacco companies are prohibited from introducing new brands at a lower price point than existing products within the market in that year, thereby preventing the lowest-priced product from decreasing in price.³⁹
• Fee-based policies: Fees can be added to the price of tobacco products to cover the costs of programmes such as management of cigarette butt litter or administration of licensing schemes²³

None of these strategies is currently under active consideration in Australia. Surveillance of data that includes sales volumes and prices can identify patterns of price discounting and changes in consumer preference over time. Mandatory reporting of tobacco sales required now of companies importing cigarettes into Australia (and also required in some states and territories—see Table 11B.1 — will provide a rich and accurate resource for identifying weaknesses in tax and price policy and evaluating impact of new policies over time.⁴⁰

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References

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