Select Committee on Health Minutes of Evidence

Memorandum by Imperial Tobacco Group PLC




  30.  From the mid 1950s, some scientists had expressed the view that a reduction in the tar yield of cigarettes would reduce the reported incidence of lung cancer among cigarette smokers. However, it was not until after the RCP stated in the early 1970s that there was evidence that cigarettes with a lower tar yield "may be less dangerous" that the Government required the publication of tar yields and established the ISCSH which recommended a strategy of tar yield reduction. Imperial and the other UK tobacco companies worked closely with the Government and the ISCSH in an open and constructive manner to agree and implement product modifications which achieved reductions in tar and nicotine yields.


  31.  By the end of the 1950s Imperial had begun, as part of its overall research effort, to investigate the factors which affect tar yields. This work was continued throughout the 1960s.

  32.  In April 1967, Imperial and the other UK tobacco companies, through the TRC, sought the views of the RCP's Committee on Smoking, Atmospheric Pollution and Health on modifications of cigarettes to reduce tar yields. The Committee was concerned that components of the smoke other than tar may be more important and that, although reductions in tar yields might be beneficial, further research was needed to discover what effects such reduction in tar yields might have. The Committee said that information about tar and nicotine yields should only be made available to researchers for this purpose. The companies reported this discussion to the Minister of Health who accepted the Committee's advice.

  33.  In 1969, the Central Health Services Council stated:

    "Efforts by the tobacco industry to reduce the tar content of cigarettes or to produce a tobacco substitute are welcomed; but it cannot be assumed that they will produce a safer product nor that tipped cigarettes are safer than others. It is doubtful if anything is to be gained by including on cigarette packets a warning about the chemical content and possible harmful effects of cigarettes, like that adopted in the United States; but the industry should notify a Government Department of the nicotine and tar content of cigarettes, and of alterations when changes are made or new types of cigarettes introduced and this information should be available to research workers."

  34.  Tar and nicotine yields in brands have been made available to Government by UK tobacco companies since 1968.


  35.  In 1971, the RCP published its Second Report on Smoking and Health in which it stated that there was evidence that cigarettes with a low tar and nicotine yield "may be less dangerous" and that "the amounts of these in all marketed brands should be published and a public statement made on the possible effects on health of smoking them". This was a change to the view expressed in 1967 by the RCP's Committee.

  36.  Following the publication of the Second RCP Report, the Government established the Standing Scientific Liaison Committee on the Scientific Aspects of Smoking and Health (known as the "Cohen Committee") with terms of reference to advise the Secretary of State for Social Services on the scientific aspects of smoking and health. This Committee was made up of scientists and doctors appointed by the Department of Health and Social Security and representatives from each of the main UK tobacco companies, including Imperial. Specifically, the Committee was asked "to advise on the significance to health of tar and nicotine yields of cigarettes and how information on the yields and their significance to health could best be made available to the public . . . ".

  37.  The Committee recommended that:

    —  "The tar and nicotine yields of all important brands of packeted cigarettes sold in the UK should be published twice a year."

    —  "Analyses should be undertaken by the Laboratory of the Government Chemist."

    —  "The published figures should be accompanied by information which will educate the public about the effects of tar and nicotine and encourage smokers to change to brands with a lower tar yield. Advice should be sought from publicity experts on the best method of presenting this."

    —  "The published figures should be divided into broad groups according to their tar yield and agreement should be sought with the tobacco manufacturers for a description of these groups to be indicated on packets of all brands included in the table."

  38.  The Government accepted these recommendations and, in 1972, announced its intention to publish tables of tar and nicotine yields. This required a standardised procedure to enable tar and nicotine yields of different cigarettes to be measured in different laboratories and to produce consistent results. This, in turn, required:

    —  a standardised procedure for gathering samples of each brand of cigarettes;

    —  standardised smoking equipment;

    —  an agreed protocol for measuring tar and nicotine yields; and

    —  agreed statistical procedures for analysing the results.

  39.  The Laboratory of the Government Chemist ("LGC") and the UK tobacco companies co-operated to develop a protocol to meet these requirements. The resulting protocol has enabled the LGC to measure and report tar and nicotine yields for major brands in what are known as the "league tables". The LGC and the UK tobacco companies regularly review and update the operation of the protocol and discuss the results produced.

  40.  From April 1973, the league tables were published by the Department of Health and Social Security. These league tables were produced by the LGC and ranked brands according to tar and nicotine yields using standardised measurements and techniques. These standardised procedures and the resulting league tables were never claimed to quantify the yield of a cigarette for an individual smoker. Rather, they were designed to provide consumers with a basis for comparison between brands or "to rank brands and allow comparison of one with another under a standard test procedure".[148]

  41.  The league tables were readily available to consumers and retailers in poster and leaflet form, were published by newspapers and were given wide publicity by the Health Education Council and others.

  42.  All press and poster advertising from September 1974 and all cigarette packs from late 1975 stated the particular brand's tar yield group. The tar groups were:
"Low tar" less than 10mg
"Low to middle tar"11mg-16mg
"Middle tar"17mg-22mg
"Middle to high tar"23mg-28mg
"High tar"29mg and over.


  43.  In 1973, the Government established the ISCSH "to provide unbiased and objective advice to health ministers (who appointed the members) and, where appropriate, to the tobacco companies, on the health aspects of smoking tobacco"[149]. Its terms of reference were:

    "To advise on the scientific aspects of matters covering smoking and health, in particular: . . .

    (b)  to review the research into less dangerous smoking and to consider whether further such research, including clinical trials and epidemiological studies, needs to be carried out; and

    (c)  to advise on the validity of research results and of systems of testing the health effects of tobacco and tobacco substitutes and on their predictive value to human health."

  44.  From its inception, there were regular meetings between its Chairman (initially Dr R B Hunter who later became Lord Hunter of Newington and then Dr Peter Froggatt) and the TAC. There were also regular discussions held between the Chief Scientific Adviser to the ISCSH, Dr F A Fairweather, and Imperial. Topics discussed at these meetings included product design, reduction of tar and nicotine yields, smoking behaviour and NSM.

  45.  The strategy recommended by the ISCSH, adopted by the Government and supported by Imperial and other UK tobacco companies in a series of voluntary agreements, was to continue to reduce tar yields of cigarettes (in what came to be known as "the product modification programme") and to identify the tar yield group on the packet, thereby providing consumers with a choice between products.

  46.  The actions of Imperial and the other UK tobacco companies were recognised by Dr Hunter in a paper presented to the Royal College of Physicians, Edinburgh, on 21 April 1976, when he said:

    "In justice it has to be recognised that over the last decade there has been substantial voluntary reductions by the industry of the tar and nicotine levels—the introduction of filters and ventilated paper. It may be that it was commercial competition and the desire to improve the safety image which produced this—but it was not legislation. It was a voluntary effort."

  47.  In March 1977, Imperial and the other UK tobacco companies entered into a voluntary agreement with Government under which they agreed not to introduce new brands of cigarettes with a tar yield greater than 22mg and not to raise existing tar yields above this level (ie no more new "middle to high tar" or "high tar" brands).

  48.  In the Second Report of the ISCSH, the Committee said that strenuous efforts should continue to be made to develop "lower risk" cigarettes for those smokers who wanted to continue smoking. It acknowledged that "Notable progress has been made by the tobacco industry over the past decade to reduce tar yields . . .".

  49.  In a letter to the Secretary of State in December 1979, Lord Hunter said "My Committee and I attach great importance . . . to the need to secure reduction in tar yields". Achievement of this would depend on Government and industry working together, and he added "it will be necessary to have a constant dialogue between the scientists in industry and those who serve on my Committee".

  50.  Imperial and the other UK tobacco companies agreed with the Government to ensure that no "high tar" brands appeared in the tar tables after 31 March 1979. Between 1973 and 1979 the number of Imperial cigarette brands tested by the LGC in the "high tar" category decreased from four to none. In the "middle to high tar" category, the number of Imperial cigarette brands decreased from seven to one. On the other hand, "low tar" category Imperial cigarette brands increased from six to 11. By 1980, the average sales weighted tar yield of cigarettes sold in the UK had been reduced to approximately 16.5mg.

  51.  In 1980, Imperial and the other UK tobacco companies voluntarily agreed with Government to reduce sales weighted average tar yields to approximately 15mg by 31 December 1983. This represented a similar percentage reduction (12 per cent) to that achieved between 1972 and 1979. Progress in tar yield reduction was to be reviewed annually with the ISCSH and the DHSS. The UK tobacco companies also agreed to introduce new brands only in the two lower tar yield categories and that no new brand would be introduced giving a tar yield exceeding the sales weighted average of the "middle tar" group.

  52.  In June 1983, when representatives of the UK tobacco companies met with the ISCSH to discuss their Third Report, Dr Froggatt congratulated the industy on "achievements so far" and said that he was "pleased to say that we maintain a fruitful working relationship with the industry and derive great benefit from our continuing discussions with the industry as a whole and with individual companies".[150]

  53.  In 1983, the ISCSH in its Third Report noted that:

    "With the reduction in tar yields, the numbers of cigarette brands appearing in each of the tar groups defined by the Government have become very unequal with the greatest number of brands now appearing in the Middle Tar group. We recommend that the definition of tar groups be reconsidered".

  54.  In 1984, a further voluntary agreement was entered into with the Government under which Imperial and the other UK tobacco companies agreed to adopt a revised tar group structure to take effect from 1 January 1985. They also agreed to set a sales weighted average tar yield target of 13 mg by December 1987 and not to introduce new brands with tar yields above the sales weighted average for the "low to middle" and "middle tar" bands. The revised tar yield group structure, which resulted in the virtual elimination of the original two highest tar yield groups, was:
"Low tar"—    Less than 10mg
"Low to middle tar"—    10mg-15mg
"Middle tar"—    15mg-18mg
"High tar"—    18mg and above

  55.  Both Imperial and the ISCSH recognised that the rates of reduction in tar and nicotine yields had to take account of what was acceptable to consumers.

  56.  In its Second Report, the ISCSH observed that:

    "There is a limit to how much tar yields can be reduced without rendering cigarettes unacceptable to the smoker".

  57.  By its Third Report in 1983,

    ". . . the Committee realised that it would be impossible to follow the same path of the tar reduction indefinitely because of consumer resistance . . . . [A]lthough tar and nicotine yields of new brands were subject to an agreed ceiling, smokers were free to switch to existing higher yielding brands if they found their current one unacceptable."[151]

  58.  The reduction of sales weighted average tar yield was a complex task which could not be instantly achieved. Imperial contributed to the reduction through a range of measures including the application of product modification technologies and the use of marketing techniques outlined in successive voluntary agreements with the Government, such as differential advertising of new low tar yield brands.

  59.  Product modification included the development of increasingly efficient filters, more porous and faster burning cigarette papers, tobacco blend selection and ventilated tippings. A combination of these were used to achieve gradual reductions in tar yields for both Imperial's existing brands and new low tar yield brands. For example, the tar yield of Imperial's Embassy Filter brand was reduced from 20mg in 1972 to 11mg in 1998. In parallel, Imperial has launched at least 24 new low tar yield brands since 1972. Overall, UK sales weighted average tar yields have fallen from 20.8mg in 1972 to 10.28mg in 1997. In general, nicotine yields have fallen in line with tar yields.


  60.  The EC has pursued a similar strategy by requiring Member States to enact legislation requiring reductions in tar yields. From 1 January 1992, the Tobacco Products Labelling (Safety) Regulations 1991 required tar and nicotine yields to be printed on all packets of cigarettes. Subsequently, the Cigarettes (Maximum Tar Yield) (Safety) Regulations 1992 came into force. These enacted EC Directive 90/239/EEC which limited tar yields in the Member States and adopted testing methods which were essentially those which were already employed in the UK. Specifically, it provided for a maximum tar yield of 15mg until 1 January 1998 and 12mg after that date.

  61.  Writing in 1996, Robert Waller (Department of Health) and Sir Peter Froggatt said:

    "the 1980 Agreement specified a SWAT [Sales Weighted Average Tar] target of 15mg/cigarette by the end of 1983—which was completely met—and of "approximately" 13mg/cigarette by the end of 1987—which was nearly met. This policy was fortified by re-defining tar bands, by restricting tar yields of new brands to 13mg and setting progressively reducing tar limits for existing brands. This latter method has become the major thrust of product modifications in the 1990s as regulatory controls implementing EU Directives replace, in the UK, the voluntary agreements and bring the other EU countries under regulation based on this cornerstone of UK practice. Currently, there is an upper limit of brand tar yield of 15mg/cigarette, set to become 12mg by the end of 1997, though with some derogation for one member state. The UK is among the leaders with a SWAT now of only some 11mg/cigarette."

  62.  As a result, prior to the 1992 and 1998 effective dates, Imperial had to make only minor adjustments to its non-filter cigarettes to comply with these new regulations. The UK is now amongst the countries in the EU with the lowest sales weighted average tar yield.


  63.  In parallel to its other product modification work, Imperial made a massive investment in developing, manufacturing and marketing a tobacco substitute.

  64.  Imperial started research into tobacco substitutes in the mid 1960s and in 1965 entered into a joint venture with Imperial Chemical Industries ("ICI") to develop a smoking material capable of wholly or partially replacing tobacco in smoking products.

  65.  NSM, which was the product that was eventually developed, was an unflavoured, nicotine free, smoking material intended for use in existing cigarette manufacturing machinery to replace a proportion of the tobacco in cigarettes. NSM consisted of a combustible base—largely modified cellulose derived from wood-pulp—and inert inorganic filler materials. (Cellulose, which is present in all plants, is a major constituent of tobacco.) The yield of tar from NSM was reduced by combining heat treated cellulose with a relatively high proportion of incombustible inert inorganic fillers.

  66.  Comprehensive chemical and biological testing of NSM was undertaken from the late 1960s through the mid 1970s. The work was largely carried out at the laboratories of ICI, Imperial and Huntingdon Research Centre. The results of the research, which covered both smoke from the pure substitute and smoke from blends of NSM with tobacco, were reported to Government, independent experts and the ISCSH.

  67.  In 1975, the ISCSH published its First Report in which it set out guidelines for the testing of cigarettes containing substitutes. The Report indicated that the Committee would raise no objection to the marketing of cigarettes containing tobacco substitutes providing:

    (i)  the results of certain smoke chemistry, biological and clinical tests had been examined by the Committee and regarded as satisfactory; and

    (ii)  the tobacco companies arranged long term studies to monitor the health of people smoking the product and reported periodically to the Committee on these studies.

  68.  Imperial committed substantial resources to meeting the ISCSH's requirements but it was not until April 1977 that the Committee gave tobacco substitutes limited endorsement stating that they "are certainly no worse than tobacco and there is some evidence that they will make smoking cigarettes containing them safer".

  69.  On 1 July 1977, six brands of cigarettes containing 25 per cent NSM and 75 per cent natural tobacco were launched by Imperial. However, there proved to be a lack of consumer demand for cigarettes containing NSM and they were subsequently removed from the market. Their failure can be attributed to a number of reasons including:

    —  The Government refused to reduce the duties levied on products containing NSM, and as a result there was no price advantage when compared with conventional cigarettes;

    —  Sale of cigarettes containing substitutes were adversely affected by Government-sponsored Health Education Council's campaigns;

    —  Cigarette smokers preferred conventional cigarettes.

  70.  It is estimated that between the period 1966 to 1977 Imperial committed approximately £22 million to the research, development and production of tobacco substitutes.


  71.  Imperial has always acted responsibly in the marketing of its products. Its policy since the early 1950s has been not to make any health claims for its products. Imperial has not marketed its products on the basis that modifications it has made have brought health benefits or have resulted in a "safer" cigarette.

  72.  In 1962, Imperial and the other UK tobacco companies voluntarily agreed to an Independent Television Code of Advertising Standards ("ITCAS") which classified as unacceptable advertisements that greatly overemphasised the pleasure to be obtained from cigarettes, advertisements featuring the conventional heroes of the young, and advertisements appealing to pride or general manliness. Under the subsequent 1964 Code, cigarette advertisements were unacceptable if they tended to "state, suggest or imply, without valid evidence, that it is safer to smoke one brand or type of cigarette than another". In 1965 ITCAS was extended to apply to the other advertising media of press, cinema and posters.

  73.  Under the 1975 British Code of Advertising Practice, advertisements

    "may claim that it is safer to smoke one brand rather than another only if the claim can be supported by valid evidence ie, evidence which has been accepted by the health authorities. Thus, for example, without such evidence no new filter should be described in terms which could be construed as implying any health advantage".[152]


  74.  Although some scientists had recommended a reduction in tar yields in the 1950s, there is still a debate over whether a reduction may be beneficial.

  75.  From the early 1970s, after the RCP stated that there was evidence that cigarettes with a lower tar yield "may be less dangerous", the Government required the publication of tar and nicotine yields and established the ISCSH which recommended a strategy of tar yield reduction.

  76.  Imperial, which had researched the factors affecting the tar yield of cigarettes during the late 1950s and throughout the 1960s, has co-operated with both the ISCSH and Government in the implementation of this strategy and has made enormous efforts to assist the Government in achieving its objectives of lowering tar yields in cigarettes. The targets which have been agreed with Government as part of the product modification programme have consistently been met by Imperial and the tar and nicotine yield information made available by Imperial to the consumer has consistently been confirmed as accurate by the LGC

  77.  A major aspect of Imperial's commitment was the vast amount spent on the development of NSM as a tobacco substitute.

  78.  In the 1990s the EC also pursued a strategy of reducing tar yields in cigarettes by imposing maximum limits on tar yields although all but two of Imperial's cigarette brands already fell within the maximum limits which were initially set by the EC in 1992.

  79.  As can be seen from the graph below, Imperial and the other UK tobacco companies have achieved a substantial reduction in tar yields since they were first published in 1973. It has not, however, marketed its products on the basis that the modifications it has made have brought health benefits.

  80.  Imperial continues to improve the existing methods of tar yield reduction and to develop new methods.

148   Darrall, LGC, "Science of the Total Environment" 74, p 263, 1988. Back

149   C Swann and P Froggatt TPRT; 1996: Preface, page 1. Back

150   Third Report of the ISCSH 1983, page iv. Back

151   Fourth Report of the ISCSH 1988, para 6. Back

152   The British Code of Advertising Practice, 1975 para 4(a) Back

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