Analysis of submissions to the EU's public consultation on tobacco traceability and security features

Background: The Protocol to Eliminate Illicit Trade in Tobacco Products requires all parties to establish a tobacco track and trace (T&T) system. In 2016, the European Commission held a public consultation on T&T implementation where parties were asked to respond online to 22 multiple-choice questions and were given additional opportunities to leave comments. In May 2019, the European Union's (EU) T&T system became operational. This paper explores tobacco industry influence over and policy positions within the consultation process. Methods: We identified consultation respondents and investigated any financial links with the tobacco industry and if these were transparent. Respondent's answers to the consultation's multiple-choice questions were collated to explore whether industry-linked respondents held the same policy positions as transnational tobacco companies (TTCs). Associations between policy positions and respondent's financial link status were tested using χ2 and Cranmer's V tests. Findings: Of the 197 consultation respondents identified, 131 (66.4%) had financial links to the industry; 29 (22.1%) were not transparent about these links. A large number of trade associations responded (87), the majority of which (74/87) had financial links to the industry. There was a clear divide in the policy preferences of respondents with and without a financial link. Collectively, respondents with a financial link supported an industry-operated T&T solution. Conclusions: There was an extensive lobbying effort by the tobacco industry over the EU's T&T system, with TTCs' interests being represented repeatedly through multiple trade associations. The transparency requirements regarding consultation respondents' affiliations with relevant stakeholders (eg, tobacco manufacturers) should be improved for future consultations.