Tobacco and Vapes Bill

Written evidence submitted by Scandinavian Tobacco Group A/S to the Committee’s call for evidence regarding The Tobacco and Vapes Bill 2023-24 (TVB10)

Public Bill Committee

UK House of Commons

Submitted via e-mail to: scrutiny@parliament.uk

Dear Members of the Committee:

(1) Scandinavian Tobacco Group A/S is a publicly listed Danish company and a world leader in the manufacture of cigars and pipe tobacco. We have sales in more than 100 countries, including the United Kingdom.

Executive Summary

(2) We are approaching you to express our views regarding the Tobacco and Vapes Bill 2023-24 and its proposed prohibition of the sale of tobacco to any citizen of the UK born after January 1st, 2009. Our submission notes that:

· The age restriction foreseen in the Bill should be understood for what it is – a ban that will radically broaden the already extensive reach of tobacco regulation in the UK.

· While Scandinavian Tobacco Group supports reasonable, proportionate, and evidence-based regulation of tobacco, we are deeply concerned that this ban will deprive adult consumers of tobacco of their right to make informed decisions about products they enjoy.

· The Bill, unfortunately, ignores the considerable differences among tobacco product categories and allows no room for what Scandinavian Tobacco Group believes should be a differentiated and nuanced approach to tobacco regulation, especially for niche categories like cigars and pipe tobacco.

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(3) First and foremost, while Scandinavian Tobacco Group acknowledges the health risks associated with smoking, we also believe that adults should have the freedom and autonomy to make informed decisions regarding their use of tobacco and are indeed fully capable of doing so. The proposed age ban in the Bill is a significant departure from responsible tobacco regulation in the UK, which until now has focused on allowing adult consumers access to legal tobacco products while ensuring they are aware of the risks of smoking.

(4) The proposed age ban will also, under any circumstances, be unwieldly in its implementation. Potential consumers would face the illogical situation where they might be otherwise old enough to vote, drive, serve in the military, marry, buy alcohol, and run a business, but be deemed "too young" to purchase a cigar or pipe tobacco. This inconsistency also undermines the rationale behind the legal age of adulthood and associated responsibilities and rights. Similarly, enforcing such a ban poses numerous challenges, and could easily have the unintended consequence of contributing to an increase in the illegal manufacture and sales of tobacco products.

(5) Additionally, regarding the question of precedent outside the United Kingdom, Scandinavian Tobacco Group notes that the new government in New Zealand recently reversed the decision to implement an age ban, leaving the UK isolated in adopting this extreme and untested measure. STG would consider it more effective to instead effectively enforce existing regulations, or at least consider an increase in the minimum age for legal purchase of tobacco, before embracing the radical step of an age ban.

(6) Further, Scandinavian Tobacco Group believes that, when regulating tobacco, it is important to fully consider the many and considerable differences among tobacco product categories and their diverse consumer profiles. Cigars and pipe tobacco differ from cigarettes in the amount, frequency, and demographics of how they are consumed. Scandinavian Tobacco Group sees this consistently across all the markets we serve globally.

(7) For example, in the European Union, cigars and pipe tobacco typically account for less than 2% of overall tobacco consumption [1] , while in Canada, cigars and pipe tobacco constitute only 2.7% and 0.1%, respectively, of total tobacco consumption. [2] Consumption of cigars and pipe tobacco is already in long-term decline, with consumption rates in most European markets as noted well under 2%.

(8) Cigars and pipe tobacco are also consumed less frequently than cigarettes by individual consumers. While some cigar and pipe smokers use these products daily, others might smoke only a few cigars per month, or enjoy their pipe once a week. A 2021 Eurobarometer report found that only 3% or fewer of smokers in the United Kingdom smoke cigarillos, cigars, or pipes daily and are more likely to smoke these on an occasional basis only or have tried these products only once or twice. [3]

(9) Cigars and pipe tobacco also generally appeal to and are used by more mature consumers, who Scandinavian Tobacco Group believes are well aware of the health risks associated with smoking. Cigars and pipe tobacco do not generally appeal to younger age groups, nor are they commonly associated with smoking initiation among younger people.

(10) A tobacco age ban that includes cigars and pipe tobacco is thus not only unnecessary, it ignores these well-established trends in consumption and demographics.

(11) In closing, Scandinavian Tobacco Group asks the UK government to approach this discussion with due consideration for consumer rights, with caution regarding unintended consequences, and at the very least, if insistent on moving ahead with this proposal, with nuance regarding the consumption and demographic patterns associated with different tobacco product categories.

(12) The simple fact is that many people derive pleasure from smoking cigars and pipe tobacco. This ban will deprive many consumers of that enjoyment, a simple but significant consideration and one that should not be dismissed lightly. There are many other proven ways to regulate tobacco and limit its consumption.

(13) Should the government proceed with the ban, then cigars and pipe tobacco should be exempted, given their fundamentally different status among tobacco product categories in relation to their consumption and demographic patterns, as well as lack of appeal to youth.

(14) While the health risks associated with smoking are undeniable, the approach to mitigating these risks should rest on regulation that is proportionate and balances public health objectives with personal freedoms and practical enforcement. Scandinavian Tobacco Group is convinced that the Bill and its tobacco age ban are, instead, legislative overreach that fails to address these nuances, with the potential for significant negative consequences.

Sincerely,

/s/

Regis Broersma

Chief Commercial Officer

Scandinavian Tobacco Group A/S

Copenhagen, April 26, 2024