Consultation outcome

Mandating quit information messages inside tobacco packs: government response

Updated 5 November 2024

Summary

Creating a smoke-free UK

Smoking is the single most entirely preventable cause of ill health and death, and it exacerbates inequality and poverty. Nationally, the proportion of adults who smoke is now the lowest on record at around 12% (according to the Office for National Statistics (ONS) report Adult smoking habits in the UK: 2023), but in some parts of the UK, prevalence is as high as around 22%.

We have an ambition to create a smoke-free UK. Our approach to this is twofold. Firstly, we are breaking the cycle of addiction and disadvantage by legislating for a progressive smoking ban that will gradually end the sale of tobacco products across the country.

Secondly, we are supporting smokers to quit in a number of ways, including through:

• funding for local stop smoking services
• stop smoking campaigns
• NHS England’s smoke-free pregnancy incentive scheme

The work on pack inserts forms part of this second aim and will help to provide information to current smokers to encourage them to quit.

The consultation on pack inserts

Pack inserts are positive quit-themed messages and advice inside tobacco packets to help smokers to quit which could help complement the existing regulations on tobacco packaging.

The Office for Health Improvement and Disparities (OHID) in the Department of Health and Social Care led a UK-wide consultation on introducing pack inserts, which was agreed and undertaken in partnership with the devolved governments. It ran for 8 weeks from 14 August to 10 October 2023.

Respondents were asked a range of questions to help us better understand the evidence behind pack inserts and how they could be introduced in the UK.

When respondents were asked about the public health impact of pack inserts, the most popular response was that smokers would be encouraged to quit, with 52% of those who answered this question selecting this option. This builds on existing evidence and practice, as well as new evidence provided through the consultation, which shows that pack inserts can help more smokers to quit smoking. We estimate in our draft impact assessment that there would be around 150,000 additional quit attempts and 30,000 successful quits over the first 2 years if pack inserts were introduced for cigarettes and hand rolling tobacco.

A small number of respondents noted the potential limitations of pack inserts, for example they believed that smokers could ignore the messages and that the impact of the packaging change would be minimal.

Mandating pack inserts

We will look to mandate pack inserts in 2 phases.

Firstly, we will mandate pack inserts in cigarettes and hand rolling tobacco as these products are already subject to the most stringent tobacco packaging requirements in the UK and have standardised packaging. Standardised packaging means that the packaging for these products has to conform to prescribed requirements for the colours, shapes and textures of the external packaging as well as minimum quantities of the products. This allows for a more practical introduction of inserts to these products. Mandating pack inserts in cigarettes and hand rolling tobacco means that the tobacco industry will be required under legislation to include information within the packaging on the benefits of quitting alongside advice and available support.

We intend to incorporate pack inserts into the internal packaging of these products, through a ‘slide and shell’ design for cigarette packets and on the flap of hand rolling tobacco products. The slide and shell design means that when people open and remove cigarettes from the packet, they have to push up an interior sliding compartment with the health messaging to open the package and remove the cigarettes. The information remains fixed as part of the packaging design and is presented to the smoker each time they take a cigarette from the pack. This is because we recognise the environmental concerns related to loose inserts. As this will have implications for the packaging design, we will engage with relevant stakeholders and consult on the final specifications before laying the legislation in Parliament.

Secondly, we will look to extend the legislation on pack inserts to cover all tobacco products, tobacco-related devices, cigarette papers and herbal smoking products. To do this, we will first consider introducing more stringent packaging requirements for the different product types, wherever possible.

To begin the second phase, we are running a call for evidence on standardising packaging for all tobacco products, which also considers issues for the potential introduction of pack inserts to these products. After we have gathered this evidence, we will publish a consultation to explore further requirements on packaging and requiring pack inserts with:

• all tobacco products
• tobacco-related devices
• cigarette papers
• herbal smoking products

The UK government and devolved governments will continue to work together to develop proposals on a 4-nation basis, ensuring as far as possible that recommendations are adopted in a consistent manner across the UK and that there is regulatory alignment.

Introduction

The harms caused by smoking

The ONS report Adult smoking habits in the UK: 2023 shows adult smoking prevalence is currently around 12% in the UK, the lowest on record. A comprehensive approach to tobacco control has been instrumental in reducing smoking rates including a history of:

• introducing plain packaging
• restricting tobacco advertising and promotion
• funding local stop smoking services
• impactful stop-smoking campaigns

Tobacco, and especially cigarette smoking, is the single most important, entirely preventable cause of ill health, disability and death in this country. Across the UK, it causes around 80,000 deaths a year^{[footnote 1]}. Smoking also causes harm throughout people’s lives, with a report on smoking, pregnancy and fertility finding a 47% increase in stillbirth risk and research from South Korea on smoking and dementia in 2018 finding a greater risk of dementia in older people.

Smoking is also a major cause of premature heart disease, stroke and heart failure. A cohort study from Australia on tobacco smoking in 2015 found that up to two-thirds of smokers will die from smoking. Cancer Research UK’s analysis on tobacco statistics estimates smoking causes around 1 in 5 of all UK cancer deaths. Cancer Research UK’s analysis on smoking and primary care found up to 75,000 GP appointments could be attributed to smoking each month, equivalent to over 100 GP appointments an hour in England. A survey of 2,000 current smokers in 2021 found that three-quarters of smokers in England would never have started if they had the choice again.

Mortality rates attributed to smoking in the most deprived local authorities (available at Fingertips Smoking Profile) are more than double that in the least deprived. Poor mental health is more common in deprived communities. Smoking is associated with mental health conditions and may contribute to health disparities. Public health data on smoking shows a quarter (25.1%) of people with a long-term mental health condition smoke (any condition expected to last 12 months or more). A study from Oxford University on smoking cessation in 2023 found that cessation is associated with improved mental health outcomes (including reduced anxiety and depression).

NHS data on smoking in pregnancy shows on average in England, 7.4% of mothers smoked at the time of delivery in 2023 to 2024. And statistics on maternal smoking in Scotland found 11% of women reported being a smoker at the time of booking an antenatal appointment in 2023. These smoking rates vary - OHID analysis of NHS data on smoking in pregnancy and ONS income deprivation data shows that nearly 1 in 5 mothers smoked in some of the most deprived parts of the country. Smoking in pregnancy increases the risk of stillbirth, miscarriage and sudden infant death syndrome.

Quitting smoking presents many individual benefits. The Royal College of Physicians report Hiding in plain sight notes that someone quitting before turning 30 could add 10 years to their life. And the NHS quit smoking website notes after just one year of quitting smoking, the risk of heart attack halves compared to a smoker’s. There are also financial benefits - calculations on the costs of smoking made in 2024 show that the average smoker could save up to £48 a week (around £2,500 a year) by quitting smoking.

The health mission

The main public health objectives of the UK government’s health mission are to:

• support people to stay healthier for longer
• shorten the time people spend in ill health
• shift the health system away from a focus on treatment to one focused on prevention

To achieve these objectives the UK government, as well as the devolved governments, are committed to reducing the harms caused by tobacco and creating a smoke-free UK.

The Tobacco and Vapes Bill is the first step and will be the biggest public health intervention in a generation. It will help reduce the number of lives lost to the biggest killers, including cancer and cardiovascular diseases.

The Tobacco and Vapes Bill

In addition to the work on pack inserts, the government has introduced the Tobacco and Vapes Bill which will:

• create a smoke-free generation, gradually ending the sale of tobacco products across the country and breaking the cycle of addiction and disadvantage
• strengthen the existing ban on smoking in public places to reduce the harms of passive smoking, particularly around children and vulnerable people
• ban vapes and nicotine products from being deliberately branded, promoted, and advertised to children to stop the next generation from becoming hooked on nicotine
• take powers to make most public places and workplaces that are currently smoke-free, vape-free (many places have already done this voluntarily)
• take powers to introduce a licensing scheme for the retail sale of tobacco, vapes and nicotine products in England, Wales and Northern Ireland, and expand the retailer registration scheme in Scotland

Packaging regulations to prevent harm

A number of tobacco packaging regulations are already in place to help prevent harm including the Tobacco and Related Products Regulations 2016 (TRPR) and the Standardised Packaging of Tobacco Products Regulations 2015 (SPOT). TRPR introduced new graphic health warnings on the outside of packaging for tobacco products, and SPOT introduced plain (standardised) packaging.

Current packaging requirements for tobacco products

The current packaging requirements for tobacco products varies depending on the product.

Both cigarettes and hand rolling tobacco are already subject to the most stringent regulations under SPOT, including standardised packaging (specified packet shape and colour, among other requirements) and minimum pack sizes.

A number of products must have a combined picture and health text warning (cigarettes, hand rolling tobacco, certain cigars and cigarillos, pipe tobacco and waterpipe products). All tobacco products must include a text health warning. Packaging requirements do not apply to cigarette papers and tobacco-related devices.

Health is a predominantly devolved matter, so there are different regulatory regimes across the UK. However, the current regulatory regimes on tobacco packaging are UK-wide with close co-operation between the UK government and the devolved governments. This is underpinned by regulations made by the UK government with the consent of the devolved governments.

International evidence and public support for pack inserts

Pack inserts were first introduced in Canada and have also been introduced in Israel. Australia recently announced its intention to introduce them.

An evaluation of the Canadian pack inserts policy suggests that tobacco pack inserts can increase the likelihood of smokers making a quit attempt, by providing motivational cessation messages and information on the benefits of quitting. These complement the graphic health warnings already present on tobacco packaging.

Public support for government action on tobacco in Great Britain, based on polling, found that 67% of adults in Great Britain support requiring cigarette packs to include inserts with government mandated information about quitting.

Consultation on pack inserts

Purpose of the consultation

On 14 August 2023, OHID launched a UK-wide consultation, in partnership with the devolved governments, on introducing pack inserts to help smokers quit smoking. Pack inserts could help complement the existing regulations on tobacco packaging.

The consultation was open for 8 weeks and closed on 10 October 2023.

The purpose of the consultation was to gain information on whether pack inserts could:

• encourage more smokers to quit by providing information on the benefits of quitting, alongside advice and available support
• have a positive effect on smoking-related attitudes, beliefs, intentions and behaviours, particularly among children and young people
• reduce the number of smokers and so reduce second hand smoke exposure

The consultation document also outlined that OHID had commissioned research from the University of Stirling on the messages that should be included within the pack inserts. This included messaging on 8 themes:

• mental health
• physical health
• conception and pregnancy
• financial benefits
• stop-smoking aids
• quitting in older age
• perseverance
• cravings

Consultation questions

Respondents were asked questions about:

• evidence on pack inserts to help smokers quit
• how pack inserts could be implemented in the UK
• the scope and location of pack inserts
• other considerations for mandating pack inserts
• any further information on pack inserts
• the draft impact assessment, published alongside the consultation

Methodology

The consultation included 36 questions of which:

• 15 were multiple choice
• 21 were free text
• 14 related to the draft impact assessment

We manually analysed the responses to the open-ended questions and themed them accordingly. We determined the strength of the themes in these responses by counting the number of times a theme came up in the responses to a question.

Some of these questions and responses have been combined in this report.

Respondents could choose whether to answer each question, and the open-ended questions were optional. For some questions, respondents could select multiple responses and this may result in more responses than respondents. Some questions are analysed based on share of responses received and others are based on share of respondents.

Any percentages have been rounded to the nearest whole number. Due to rounding, the total may not always sum to exactly 100%.

Tobacco industry declaration

The UK is a party to the World Health Organization (WHO) Framework Convention on Tobacco Control (FCTC) and so has an obligation to protect the development of public health policy from the vested interests of the tobacco industry under article 5.3.

To meet this obligation, the consultation included a mandatory question where we asked all respondents to disclose whether they have any direct or indirect links to, or receive funding from, the tobacco industry. In total, we received 13 responses from respondents who disclosed links to the tobacco industry.

In line with article 5.3 of the WHO FCTC, we have documented tobacco industry comments as part of this analysis. We give the responses for each question as the total responses, including those from people with links to the tobacco industry. We also outline the tobacco industry-related responses separately.

Consultation responses

In total the consultation received 213 responses. Of the 213 responses, we heard from:

• 57 organisations
• 117 individuals sharing personal views
• 39 individuals sharing professional views

Respondents generally did not provide data on their nationality, so we were unable to provide this information accurately broken down by devolved government.

The following sections outline the responses to the consultation questions, grouped by the categories they were asked in.

We are grateful to everybody who has taken the time to complete the consultation. It has informed and strengthened the UK government’s and the devolved governments’ policy decision.

Evidence on pack inserts to help smokers quit

Question

What effect (if any) do you think pack inserts will have to improve public health?

• Smokers will be encouraged to quit
• Young people will be discouraged from taking up smoking
• Second hand smoke exposure will be reduced (given the reduced number of smokers)
• There will be no effect
• Other

For this question, respondents could select multiple answers, resulting in a higher number of responses than the number of respondents. To assess respondent views on the impact of pack inserts, we analysed the proportion of respondents who selected each option, rather than the share of responses.

Of the respondents that answered this question:

• 52% said ‘Smokers will be encouraged to quit’
• 30% said ‘Young people will be discouraged from taking up smoking’
• 38% said ‘Second hand smoke exposure will be reduced (given the reduced number of smokers)’
• 42% said ‘There will be no effect’
• 8% said ‘Other’

This breakdown of respondents reflects the fact that interventions on tobacco control tend to have more than one outcome.

Over half of respondents (53%) selected at least one of the public health benefits (‘Smokers will be encouraged to quit’, ‘Young people will be discouraged from taking up smoking’, ‘Second hand smoke exposure will be reduced (given the reduced number of smokers))’.

There were 11 responses to this question from respondents with links to the tobacco industry. Overall, there was less support from this group that pack inserts would have a positive public health benefit, and 63% said ‘There will be no effect’.

Question

If you have examples or cases of tobacco users quitting as a result of reading pack inserts in tobacco products, please provide details.

Respondents noted that providing smokers with positive reminders of the benefits of quitting can help encourage them to quit. Many focused on the international evidence, largely from Canada, supporting the introduction of pack inserts. This included referring to the research paper Cigarette pack inserts can promote efficacy beliefs and sustained smoking cessation attempts. It found that cigarette pack inserts can:

• positively influence smokers’ confidence in their ability to quit
• promote sustained quitting behaviour beyond graphic health warnings (with quit attempts lasting 30 days or longer)

Some respondents provided suggestions of alternatives to pack inserts that could help people quit, such as:

• changing the current health warnings to ensure that they also include positive messaging
• increasing the level of training that healthcare professionals receive on smoking cessation

Some respondents did not agree with the introduction of pack inserts and believed that pack inserts would have a limited impact, as the messaging would be ignored. Others wanted to ban smoking entirely.

There were 7 responses to this question from respondents with links to the tobacco industry. From this group, the main theme was the suggestion of alternative measures to pack inserts to encourage smoking cessation. Others noted that pack inserts may have minimal impact because messaging would be ignored.

Question

If you have examples to suggest digital communication is useful to help people seek advice to stop smoking, please provide details.

Digital communications in this question means using online tools like email, text messaging or social media to reach an audience.

Several respondents provided various examples of digital communications that can help provide advice to quit smoking. A common theme was the use of QR codes, because they can be presented on a range of media such as:

• posters
• staff name badges
• tobacco packaging

Specific research where QR codes have been used to signpost to stop smoking service websites or allow people to self-refer to stop smoking services were provided as forms of evidence. Others suggested specific apps and websites that provide quitting advice, including the ‘Smoke Free - quit smoking now’ app and the NHS website. The use of anti-smoking adverts and social media to provide advice was also mentioned.

Some respondents acknowledged the limitations of digital communications in providing information to all groups. Some people may not have easy access to the relevant technology required to use the digital communications, and some of these groups have higher smoking rates than average, such as those living with the highest levels of deprivation.

Some respondents used the free text box as an opportunity to advocate for the benefits of vaping as a smoking cessation method, or to express their disapproval of pack inserts in general.

There were very few responses to this question from individuals with links to the tobacco industry, with only 3 responses received. The main theme in these responses was the benefits of QR codes which could be placed on cigarette packaging.

Question

Is there additional evidence and experience internationally on the use of pack inserts to promote a switch to vaping, nicotine replacement therapy or quitting support which could help inform policy development?

Please provide more information.

A number of respondents provided evidence on the use of pack inserts to promote:

• a switch to vaping
• nicotine replacement therapy
• quitting support

Many individuals cited studies undertaken both in the UK and internationally, including:

• the evaluation of the Canadian pack inserts policy
• a focus group study on young adult smokers in Turkey
• a study on assessing smoking cessation messages in the USA

This evidence noted the positive impacts of pack inserts, particularly from the same Canadian research paper ‘Cigarette package inserts can promote efficacy beliefs and sustained smoking cessation attempts’. People reading them a few times or more in the past month were more likely to make a quit attempt. Respondents also highlighted research undertaken by the University of Stirling which was referenced in the consultation document.

Some respondents suggested alternative or additional measures to pack inserts, including:

• printing information directly onto the packaging
• introducing ‘dissuasive’ cigarettes (cigarettes that display warnings, are in an unappealing colour or both)
• changing the age of sale of tobacco

Some respondents used the free text box to express their discontent with the proposed policy to introduce pack inserts.

Only 2 responses were received to this question from respondents with links to the tobacco industry. These responses noted that pack inserts are a useful tool to promote a switch to vaping, nicotine replacement therapy or quitting support. They also suggested alternative measures to pack inserts including amending existing packaging to include QR codes directing smokers to cessation services.

Government response on evidence to support the introduction of pack inserts

The majority of respondents (53%) selected at least one of the options associated with public health benefits (‘Smokers will be encouraged to quit’, ‘Young people will be discouraged from taking up smoking’, ‘Second hand smoke exposure will be reduced (given the reduced number of smokers)’).

We know that pack inserts inside tobacco packets can help more smokers quit smoking. This is clear from:

• existing international evidence and practice
• evidence provided in response to this consultation
• the draft impact assessment estimated that there would be about 150,000 additional quit attempts and 30,000 successful quits over the first 2 years if pack inserts were introduced for cigarettes and hand-rolling tobacco

As a result, the UK government, in partnership with the devolved governments will take forward regulations to mandate industry to include tobacco pack inserts on cigarettes and hand rolling tobacco and look to explore this for:

• other tobacco products
• tobacco-related devices
• cigarette papers
• herbal smoking products

Respondents raised accessibility issues when we asked about the use of digital communications. We will ensure that pack inserts will provide information as a standalone resource without relying primarily on digital communications. We also intend on including digital communications as part of the pack inserts wherever possible, details of which will be included in a subsequent consultation ahead of bringing forward the final legislation.

How pack inserts could be implemented in the UK

Question

Which of the following suggested conditions do you think should apply to pack inserts?

• Defining which tobacco products pack inserts should be used in
• Setting out the type and size of font, colour, layout with dimensions and whether to include pictures
• Defining the location of the insert inside tobacco packaging
• Defining the specific information to use on where to seek more help to quit
• Allowing a suitable transition period for suppliers for when inserts must appear on the UK market
• Outlining that central government would lead on the research and design of the inserts and host the insert graphics for industry to access
• Providing a selection of inserts to be rotated
• Ensuring that industry cover the costs to produce and place inserts in their tobacco products
• Outlining penalties to manufacturers if a pack does not include an insert
• Outlining the responsible body to enforce pack inserts, which would be local trading standards

Article 11 of the WHO FCTC outlines the obligations for parties relating to the packaging and labelling of tobacco products. The UK government and devolved governments used this article and accompanying guidelines to help formulate a series of questions on conditions for UK pack inserts should they be introduced.

For this question, respondents could select multiple conditions, resulting in a higher number of responses than the number of respondents. To assess respondent support for applying these conditions, we analysed the proportion of respondents who supported each proposed condition rather than the share of responses.

The most popular conditions selected were:

• ‘Defining the specific information to use on where to seek more help to quit’, with 121 respondents selecting that this condition should apply (57% of respondents)
• ‘Ensuring that industry cover the costs to produce and place inserts in their tobacco products’, with 118 respondents selecting that this condition should apply (55% of respondents)
• ‘Outlining penalties to manufacturers if a pack does not include an insert’, with 114 respondents selecting that this condition should apply (54% of respondents)

Some respondents (21%) selected that all of the available conditions should apply to pack inserts.

The most popular responses from respondents with links to the tobacco industry were:

• ‘Allowing a suitable transition period for when inserts must appear on the UK market’, with 7 respondents selecting that this condition should apply (54% of tobacco industry respondents)
• ‘Defining which tobacco products pack inserts should be used in’, with 5 respondents selecting that this condition should apply (38% of tobacco industry respondents)

Question

If you agree that there should be a suitable transition period for suppliers for inserts to appear on the UK market, what do you think that transition period should be?

• 3 months
• 6 months
• 12 months

Of respondents who answered this question about a suitable transition period for suppliers for inserts to appear on the UK market:

• 40% thought 3 months was appropriate
• 37% thought 6 months was appropriate
• 24% thought 12 months was appropriate

There were 6 respondents with links to the tobacco industry that answered this question. They all chose 12 months for a transition period.

However, some respondents with links to the tobacco industry uploaded additional documents where they expressed that 12 months was a minimum for a transition period. Some said they would need a transition period of at least 24 months, as new equipment may be required for the introduction of pack inserts, or to allow supply chains to adapt to new legislation.

Question

Are there any other conditions that you think could be applied if the government were to mandate pack inserts?

Please explain what conditions you think should be applied.

Several respondents requested that there are clear penalties for manufacturers and retailers who do not comply with the pack inserts requirements. Some advocated for it to be an offence to sell or supply tobacco products, as well to manufacture or import products without inserts.

Respondents flagged that there should be strict requirements on the information that should be included on the pack inserts, with a clear focus on quitting. Some also advised that the information should include links to local stop smoking services and pharmacies. They also thought that the smoking cessation advice should be applicable and suitable for the services provided in all 4 nations.

Also, some respondents noted that the form in which pack inserts are implemented should be environmentally friendly, for example printed on recycled paper that can biodegrade, and not separate from the rest of the packet to prevent littering.

We received 6 responses to this question from respondents with links to the tobacco industry. The main theme among these responses was that there should be longer transition times to allow time to prepare and adapt to pack insert requirements. Other responses from this group were that pack inserts should only be present in certain tobacco products, with exemptions for pipe smoking, cigars and cigarillos, and that there should be an exemption for travel retailers.

Government response to how pack inserts could be implemented in the UK

The UK government and devolved governments understand that respondents supported a range of conditions to be applied to the introduction of pack inserts.

The most popular responses provided were to:

• define the specific information to use on where to seek more help to quit
• ensure that industry cover the costs to produce and place inserts in their tobacco products
• outline penalties to manufacturers if a pack does not include an insert

OHID commissioned research from the University of Stirling on the messages that should be included on the pack inserts. We will include the following topics on pack inserts:

• mental health, focusing on dispelling the myth that smoking reduces stress and anxiety
• physical health
• conception and pregnancy
• financial benefits
• stop-smoking aids
• quitting in older age
• perseverance
• cravings

The exact wording of the proposed inserts, images of the proposed inserts and the rotation scheme for alternating the themes of the inserts, and other specific details will be subject to a further consultation before bringing forward the final regulations. Subject to this consultation, industry will then be mandated to include these inserts in the specified products.

We will ensure that tobacco companies and manufacturers are responsible for the costs associated with the introduction of pack inserts, in line with previous tobacco packaging changes. We will also work with the appropriate government departments and trading standards to ensure that offences for the future draft regulations are appropriately defined. There will be clear penalties for non-compliance.

Respondents believed that the transition period for the changeover of tobacco packaging to include pack inserts should be short, with a transition period of 3 months being the most common response. We recognise that manufacturers will need an appropriate amount of time to adapt their packaging and for retailers to sell any existing stock. We will consider the length of the transition period based on the steps required by industry and other relevant stakeholders to amend the packaging to ensure that it is compliant. We will not include any exemptions for any particular retailers.

The UK government and devolved governments will consult on the detailed requirements that will apply to tobacco pack inserts including the contents and appearance of the inserts.

Scope and location of pack inserts

Question

If the government makes pack inserts mandatory to help smokers quit, what products do you think it should be applied to?

• None (do not introduce pack inserts)
• Cigarettes and hand rolling tobacco
• Cigarettes only
• Hand rolling tobacco only
• All tobacco products (smoked and smokeless)

Of all respondents who answered this question:

• 65% said ‘All tobacco products (smoked and smokeless)’
• 7% said ‘Cigarettes and hand rolling tobacco’
• 1% said ‘Cigarettes only’
• 27% said ‘None (do not introduce pack inserts)’

There were 8 respondents with links to the tobacco industry that answered this question. Among this group, the most popular opinion was ‘None (do not introduce pack inserts)’, with 75% of respondents choosing this option.

Question

Where do you think the messages to quit smoking should be placed?

• Insert cards in tobacco packs
• Information messages printed on the inside of the tobacco packaging
• Information messages that are part of the flap design when a pack is opened

Of all respondents who answered this question:

• 55% said ‘Information messages that are part of the flap design when a pack is opened’
• 36% said ‘Insert cards in tobacco packs’
• 9% said ‘Information messages printed on the inside of the tobacco packaging’

Only 3 respondents linked with the tobacco industry answered this question.

Question

If you have any other ideas about how to include information inside tobacco packaging, to help more smokers quit, please explain your ideas.

Free text responses raised themes such as the importance of ensuring that the pack inserts are clearly visible. Some respondents were in favour of including the positive health information messages inside the packet in a location where they are visible each time someone opens the packet to access cigarettes. Others supported adding QR codes on the pack inserts as these can be used to provide additional information that would not be suitable for the smaller space.

Another popular response was to introduce dissuasive cigarettes. These include unattractively coloured cigarettes and cigarettes with warnings on the paper.

There were 7 responses to this question from individuals with links to the tobacco industry. The main themes from these were that pack inserts must be clearly visible and that QR codes should be used.

Government response to scope and location of pack inserts

As outlined above, current packaging requirements apply differently to different tobacco products with cigarettes and hand rolling tobacco having the most stringent restrictions.

There is no safe level of tobacco consumption. When smoked, tobacco kills up to two-thirds of its long-term users, and all smoked tobacco, including products like cigars and shisha, is harmful. Tobacco smoke has been classified as a group 1 carcinogen, and tobacco smoke from smoked tobacco leads to the same types of diseases as cigarette smoke.

Also, use of smokeless tobacco raises the risk of mouth cancer and oesophageal (food pipe) cancer. These products widely used in the South Asian community cause serious harm to health including a sevenfold increased risk of oral cancer in some products. They are commonly used by non-smokers including by South Asian women, making health inequalities worse. So, we think it is appropriate to explore extending pack inserts to all of these products.

The consultation feedback showed support for pack inserts for all tobacco products.

As a first step, we will implement pack inserts on cigarettes and hand rolling tobacco, as both products are currently subject to standardised packaging requirements. We intend to incorporate pack inserts into the internal packaging of these products, through a slide and shell design for cigarettes packets and on the flap of hand rolling tobacco products.

The proposal to introduce new slide and shell packaging for cigarettes received support from a majority (55%) of respondents.

The slide and shell design alleviates environmental concerns raised about separate pack inserts. We will mandate industry to include pack inserts to cigarettes, and we intend for this to be through a slide and shell design. This has proven to be effective in other countries and will allow for the introduction of pack inserts to the internal packaging of cigarettes.

In the short term, we will also work to understand how to best introduce pack inserts for hand rolling tobacco. We will ensure that the environmental impact of these packaging changes is minimal, for example by printing on the inner flap.

As this will have implications for the packaging design on cigarettes and hand-rolling tobacco, we will engage with relevant stakeholders and consult on the final specifications before laying the legislation in Parliament. We will then work with the devolved governments to extend the legislation on pack inserts to cover:

• all tobacco products
• tobacco-related devices
• cigarette papers
• herbal smoking products

To do this, we will first consider introducing more stringent packaging requirements for the different product types, wherever possible.

To do this, we are running a call for evidence on current packaging provisions, expanding them and considerations for introducing pack inserts. This will allow us to gather information on tobacco packaging for other tobacco products to help us consider the specific policy proposals to consult on. After we have gathered this evidence, we will publish a further consultation on standardised packaging and expanding pack inserts for the products listed above.

We will incorporate digital information inside tobacco packaging such as including QR codes, wherever relevant and possible.

We will continue to monitor the evidence on dissuasive cigarettes and whether the evidence supports their introduction in the future.

Other considerations for mandating pack inserts and further information on pack inserts

Question

Do you think insert cards in tobacco products could affect the quality and taste of tobacco products?

• Yes
• No
• Don’t know

Of all respondents who answered this question:

• 13% said ‘Yes’
• 65% said ‘No’
• 23% said ‘Don’t know’

There were 9 respondents with links to the tobacco industry that answered this question. Among this group:

• 44% said ‘Yes’
• 22% said ‘No’
• 33% said ‘Don’t know’

Question

If you have environmental concerns about the use of inserts, please explain these and how you think we could mitigate any environmental problems.

Respondents had concerns about the potential for increased littering from pack inserts, with many noting that cigarette butts are one of the most commonly littered items. Other respondents raised concerns about the use of additional materials, ink and the manufacturing process involved and the potential negative impacts of this.

Respondents suggested a number of solutions to mitigate the environmental concerns. The most popular theme was to ensure that either the material used to create the pack inserts is made from recycled material or to ensure that the pack inserts can be recycled, composted or biodegraded. Also, many respondents were in favour of the pack inserts remaining attached to the wider tobacco packaging as this could help reduce separate littering of pack inserts. Some respondents said that although pack inserts would constitute additional packaging, the environmental benefits provided by smokers quitting could outweigh this.

Some respondents used the free text box to express their dissatisfaction with the proposal to introduce pack inserts in general.

There were 9 responses to this question from respondents with links to the tobacco industry. Among this group, the main theme was that pack inserts could result in increased litter. Other responses included that pack inserts create additional packaging and waste and the suggestion that they should form part of the current packaging.

Question

Do you think anything should be left to the discretion of the tobacco industry when introducing pack inserts?

• Yes
• No
• Don’t know

Please explain what you think should be left to the discretion of the tobacco industry.

Of all respondents who answered this question:

• 23% said ‘Yes’
• 68% said ‘No’
• 8% said ‘Don’t know’

Most respondents did not think anything should be left to the discretion of the tobacco industry. Of the few respondents who were in favour of tobacco industry discretion, they thought it should be related to the assembly of tobacco packaging and the location of the pack inserts.

A small number of respondents used the free text box to express their dissatisfaction with the proposal to introduce pack inserts in general.

Six respondents with links to the tobacco industry answered this question. Of those:

• 83% said ‘Yes’
• 17% said ‘No’

There were 4 responses from people with links to tobacco industry that gave more details on what should be left to the discretion of the tobacco industry. The themes from these responses were that the assembly of pack inserts, production materials and the design of messaging should be at the discretion of producers.

Question

Do you agree or disagree that if the inserts were mandatory, that the tobacco industry should pay for the costs to print these and put them in their tobacco products?

• Agree
• Disagree
• Don’t know

Of all respondents who answered this question:

• 71% said ‘Agree’
• 24% said ‘Disagree’
• 5% said ‘Don’t know’

Nine respondents with links to the tobacco industry answered this question, with the most common response being ‘Agree’.

Question

If you have further information for us to consider on mandating pack inserts, please provide this.

Many responses to this question repeated issues raised previously, expressing either support for or dissatisfaction with the proposal. No substantial new issues were raised.

There were 7 responses to this question from respondents linked to the tobacco industry.

Government response to other consideration on pack inserts

The environmental concerns associated with pack inserts were mentioned several times by respondents across the range of questions asked. We will minimise the environmental impact of pack inserts by incorporating the messages to the internal packaging of the products, wherever possible. We intend to achieve this through the slide and shell design for cigarettes and the most appropriate form for hand rolling tobacco.

We are undertaking a call for evidence that explores current packaging and introducing pack inserts for all other tobacco products, tobacco-related devices, cigarette papers and herbal smoking products. This will help to provide evidence on the most appropriate form of pack inserts for these products.

In line with previous changes to tobacco packaging, tobacco companies and manufacturers will be responsible for the costs associated with the changes.

Details of the expected costs to manufacture the new packaging were provided in the draft impact assessment. We will update the impact assessment to incorporate pack inserts to the packaging of cigarettes and hand rolling tobacco. It will be further updated for other tobacco products, tobacco-related devices, cigarette papers and herbal smoking products after the call for evidence, as appropriate.

Draft impact assessment

The consultation included a draft impact assessment on the proposal to introduce pack inserts. This impact assessment presented several options for implementing pack inserts in a range of smoked tobacco products.

The consultation asked a number of questions about the draft impact assessment. Given the policy decisions outlined above, the draft impact assessment will be updated and will accompany the future consultation on tobacco pack inserts for cigarettes and hand rolling tobacco products.

Question

If you have any evidence to inform the estimated loss in profits for retailers and/or wholesalers, please provide details.

Common themes in response to this question included the view that fewer people smoking may result in former smokers having more money they can spend on other goods available at retailers. Some respondents thought that pack inserts will have a minimal impact on retailers’ profits but could result in a minimal short-term impact for wholesalers.

For wholesalers, the main theme across all respondents was that they expect a reduction in profits.

We received very few responses from respondents with links to the tobacco industry for this question. These responses noted that retailers may face a loss in profits if prices increase due to pack inserts, potentially causing decreased footfall or increased competition for small retailers. Other responses from people with links to the tobacco industry said that pack inserts may reduce wholesalers’ profits due to higher manufacturing costs. No evidence was provided to suggest the scale of expected loss in profits for retailers and wholesalers.

Question

If you think there will be an impact on retailers and/or wholesalers and/or small and micro businesses that we have not currently accounted for (such as reduced footfall in shops) please provide details.

The main theme across all respondents was that there may be wider impacts on hospitality and entertainment industries and increased litter outside premises.

There were differing views about footfall. Some respondents suggested footfall would decrease, while others thought that footfall would not be significantly affected by pack inserts.

No additional information or evidence was provided on the impact on small and micro businesses.

There were very few responses from respondents with links to the tobacco industry. These responses noted that pack inserts may decrease footfall or increase competition for small retailers.

Question

If you have any evidence to inform the estimated loss in profits to manufacturers and/or the impact to manufacturers by mandating pack inserts, please provide details.

Across all respondents, common themes were that pack inserts would increase production costs to manufacturers and their costs would have minimal impacts on large manufacturers’ profits. There was a response that provided a specific cost estimate per pack insert.

Some respondents believed that small manufacturers would face increased costs for equipment and machinery and that there would be technical challenges. As noted in the draft impact assessment, the UK does not currently produce cigarettes or hand rolling tobacco. Respondents thought that the evidence from countries that have already implemented pack inserts should be reviewed.

There were very few responses from respondents with links to the tobacco industry. The responses raised concerns that smaller manufacturers will face increased costs for equipment and machinery. They also highlighted the specific technical challenges of pack inserts in the production process for hand rolling tobacco products. There was also a suggestion of alternative measures, such as QR codes, to support smoking cessation.

Question

If you think there are any other stakeholder groups that would be impacted by introducing pack inserts, please explain who these groups would be.

From the answers to this question, a main stakeholder group we identified was consumers of tobacco products. Respondents suggested that pack inserts would affect the price of tobacco products. They also thought that pack inserts may have a positive impact on people’s health and finances, and a negative impact due to the inconvenience of having to dispose of pack inserts if they were loose.

Many respondents also thought that local public services may be affected by pack inserts. They thought this would include increased demand for:

• stop smoking services
• community pharmacies
• local waste services to remove litter

Other affected stakeholders identified by respondents included:

• wider society
• taxpayers
• enforcement bodies such as trading standards
• the NHS

There were very few responses from respondents with links to the tobacco industry, with just 2 responses from this group. These responses highlighted enforcement bodies, such as trading standards, and consumers of tobacco products as the stakeholders that would be impacted by pack inserts.

Question

If you have any data or evidence on the prevalence of use of other tobacco products (OTPs) (such as oral and pipe tobacco), please provide details.

Of all responses to this question, the main theme was that OTPs have much lower prevalence than cigarettes, hand rolling tobacco, some cigars and cigarillos.

Some respondents gave evidence on the proportion of OTPs in the tobacco industry. Other responses indicated that all tobacco products are harmful and there should be no exemptions to pack insert regulations.

There were very few responses from respondents with links to the tobacco industry, with just 2 responses from this group. Both responses outlined that OTPs have low use levels and provided some evidence on use of OTPs.

Question

If you have any evidence on whether pack inserts will affect different groups of people in different ways, please provide details.

There were only 12 responses to this question across all respondents. From these responses, a theme was that there may be language barriers which could be solved with QR codes that lead to a website with many language options. There was also a response that provided evidence of research showing how different sociodemographic groups have different attitudes to pack inserts.

Question

If you have any evidence on the impact on competition of mandating pack inserts, please provide details.

There were only 3 responses to this question across all respondents. In these responses, some indicated that competition would be reduced because some imported products would not be available. Others thought that there would be no impact to competition. No additional information or evidence was provided.

Question

If you have any evidence on the environmental impact of mandating pack inserts, please provide details.

Limited evidence of the environmental impact of pack inserts was provided. However, the main themes in responses were that pack inserts are expected to increase litter, and could result in more deforestation. Some also thought that the positive environmental impact of people quitting may be greater than the environmental issues caused by pack inserts.

Government response to the draft impact assessment

We will update the draft impact assessment to account for any new evidence provided to this consultation. We will publish this updated draft impact assessment alongside the next consultation on pack inserts for cigarettes and hand rolling tobacco.

Next steps

After considering the responses to this consultation, the UK government will work with the devolved governments to legislate to mandate pack inserts in cigarettes and hand rolling tobacco in the first instance. This will have implications for the packaging design, so there will be further engagement with relevant stakeholders. We will update the impact assessment based on this design work and we will publish this alongside a subsequent consultation on the details of pack inserts for cigarettes and hand rolling tobacco needed for the legislation.

As a second phase of work, we will look to extend pack inserts to:

• other tobacco products
• tobacco-related devices
• cigarette papers
• herbal smoking products

We have launched a call for evidence seeking views on the current packaging of these products and considering requiring pack inserts for these products. Once this evidence has been gathered, there will be further consultation on standardised packaging and expanding pack inserts for all tobacco products, tobacco-related devices, cigarette papers and herbal smoking products.

The UK government and devolved governments will work together on regulations that all administrations can consent to, with the aim of continuing to regulate packaging under a single UK wide regime.

1. Estimated using Fingertips Smoking Profile for England, the Smoking in Wales tool, Smoking attributable deaths data for Scotland and the 10 year tobacco control strategy for Northern Ireland. ↩