Thank you for the opportunity to provide a submission in relation to the Plain Tobacco Packaging (Removing Branding from Cigarette Packs) Bill 2009.

Transcription

1 WA Tobacco Document Searching Program Health Research Campus GPO Box U1987 Perth WA 6845 Tel: Fax: April 2010 Community Affairs Legislative Committee Australian Senate Parliament House Canberra ACT Thank you for the opportunity to provide a submission in relation to the Plain Tobacco Packaging (Removing Branding from Cigarette Packs) Bill We strongly support this Bill as an important step forward in bringing Australia into line with international best practice in tobacco control. We are aware that other organisations with which we are associated are also making submissions in support of the Bill. It is not our purpose to replicate all the information in the other submissions you will have received. This submission will therefore focus on some preliminary issues, followed by a document prepared by the WA Tobacco Document Searching Program (WATDSP) addressing arguments presented by tobacco companies in Australia and internationally against legislative measures to protect the health of youth from the effects of product promotion. This document contains: a summary of industry arguments against actions to implement plain packaging taken from tobacco industry document archives and industry submissions to government; and public health information to address industry arguments. The aim of the WATDSP is to contribute to a reduction in the prevalence of smoking and disease and deaths caused by smoking through a tobacco industry document searching program which incorporates both research activity and principles of advocacy. The project gathers evidence from internal tobacco industry documents that are available for public viewing on the World Wide Web as a result of the 1998 Master Settlement Agreement. The WATDSP supports the Plain Tobacco Packaging (Removing Branding from Cigarette Packs) Bill The Proposal is consistent with the best international evidence and advice, recommended in recent major international and national reports. The World Health Organisation s (WHO) Framework Convention on Tobacco Control (FCTC) requires nations WATDSP Submission - Plain Labelling of Tobacco Packaging Bill 2009 Page 1

2 that have ratified the convention to ban all tobacco advertising and promotion (which includes promotion though branding and packaging); and the Australian Government Preventative Health Taskforce Report recommends that all tobacco products be sold in plain packaging. As a result of increased marketing restrictions on tobacco products, product packaging is now the key communication vehicle for cigarette promotion. 1, 2 Tobacco packaging creates a perception among young people that tobacco products are an ordinary consumer item. 3 Tobacco packs are designed by tobacco manufacturers to undermine the effectiveness of tobacco packaging laws mandating the display of health warnings and bans on misleading or deceptive information on the perceived strength of the product. 4 The main possible arguments against the Bill by the tobacco industry include arguments that: there is insufficient evidence to suggest that plain packaging will reduce consumption of cigarettes and that there are legal trademark and intellectual property restrictions. There is evidence that tobacco companies have fiercely and successfully resisted plain packaging implementation attempts in New Zealand (1989) and Canada (1994) arguing charter and trade agreement rights and lack of evidence. Past experience saw similar outcomes in Australia (1997). The type of tobacco control legislation that has been proposed for Australia is currently under discussion for Canada and the UK. TOBACCO INDUSTRY ACTION This section summarises the importance of product packaging and brand image to the tobacco industry in Australia (and other countries). It also provides evidence that the industry has taken the plain packaging proposal very seriously; whilst individual companies formed taskforces 5 to deal with the issue, international industry action saw the formation of a Plain Packs Group with members representing British American Tobacco, RJR Tobacco International, Rothmans, Gallaher, Reemstma, Imperial, and Philip Morris International. 6-8 Possible Arguments against the Bill Tobacco packaging is not a form of tobacco advertising No evidence of public health benefit Infringement of international trade mark and intellectual property rights Key Findings Research findings as outlined below present positive outcomes for plain packaging. Decrease use of packs as an advertising vehicle and means of promoting an image, brand personality and quality Youth are more influenced by tobacco marketing than adults Reduce brand appeal and the attractiveness of packs, particularly among youth Reduce tobacco consumption, uptake among young people, resulting in a reduction in tobacco related deaths and the social costs of smoking. Remove the packs ability to deceptively influence consumers perceptions of tobacco quality and sensory appeal, and false implications that products have harm reducing properties Enable graphic health warnings to be more prominent on packs, removing the industry using the pack to undermine graphic health warnings on packs Increase credibility and recall of health warnings WATDSP Submission - Plain Labelling of Tobacco Packaging Bill 2009 Page 2

3 Reduce misleading beliefs about the health risks of different brands According to the WHO FCTC (Article 11) tobacco package design is primarily used to reinforce brand imagery, minimise perceptions of risk, and communicate deceptive differences in the risk of different brands. Implementation of plain packaging will reduce brand appeal and the attractiveness of packs, particularly among youth, increase the credibility and recall of health warnings and reduce misleading beliefs about the health risks of different brands Tobacco packaging is not a form of tobacco advertising Evidence from Tobacco Industry Documents: As early as 1963 a document entitled Development of cigarette packaging : The cigarette market may be broken down into age brackets as follows the formative years; smoking starts and brand preferences are developed, The primary job of the package is to create a desire to purchase and try (US Tobacco Institute) 9 The increasing imposition of advertising restrictions on the tobacco industry inevitably results in the visual impact of the cigarette pack itself assuming more importance as a means of attracting consumer attention to the product acknowledging that the aesthetic aspect of pack design must still be regarded as the principle foundation for the development of brand imagery (British American Tobacco) 10 Legislative changes in Australia have led to the loss of print media, and restrictions on the other major above the line areas the net result is that we must now extend below the line programs to encompass the image building role. Retail marketing is therefore no longer the support mechanism, it is the primary communication vehicle (Philip Morris) 11 If there is no media advertising even a glimpse of a brand in the right context, can have great value (Author unknown in British American Tobacco documents) 12 we will need to become more creative, more imaginative and more self-sufficient in the skills of image-building, communications and persuasion, through the media still available to us and by unconventional means where necessary (Author unknown in British American Tobacco documents) 12 The most effective means Australia has had to get the consumer to notice something new post restrictions was a new/different packaging configuration (RJ Reynolds) 13 Opportunities in Packaging Innovation : Key lessons learned especially young adult consumers are ready for change in packaging ; Next steps in learning, 1. Which opportunities apply best to which brands? By brand image By brand need for new, refreshed image By user personality and relationship to brand image (Author unknown in Philip Morris documents) 14 Cigarettes have never been a logical product and brand choice has always been determined by images appealing on an emotional level rather than for rational choice (Author unknown in British American Tobacco documents) 12 WATDSP Submission - Plain Labelling of Tobacco Packaging Bill 2009 Page 3

4 Speech notes of a Brown and Williamson employee: a cigarette pack is one of the few things you use regularly that makes a statement about you. A cigarette pack is the only thing you take out of your pocket 20 times a day and lay out for everyone to see (Author unknown in Brown and Williamson documents) 15 Cigarettes are one of the few products purchased daily by the actual consumer. This habit plus the fact that the pack is with the smoker all day, brought out on 20 separate occasions for usage establishes a unique personal relationship between the smoker, their brand and their product This regular usage several times a day generates a brand loyalty relationship which is amongst the highest of any product category (British American Tobacco) 16 However, one of every two smokers is not able to distinguish in blind (masked) tests between similar cigarettes for most smokers and for the decisive group of new, younger smokers, the consumer s choice is dictated more by psychological, image factors than by relatively minor differences in smoking characteristics (Unknown in British American Tobacco documents) 12 Document explaining what a brand is: A personal statement of the user, the user s desires, values and aspirations, a cigarette brand must bond with its user and bond at multiple levels (RJ Reynolds) 17 The importance of personal taste, imagery, and the conspicuous consumption of the product result in a greater brand loyalty for cigarettes (RJ Reynolds) 18 Document outlining the new packaging for Salem: Significantly improves purchase intent among competitive smokers due to an increased overall appeal at a 3 to 1 margin versus the current packaging new packaging represents the key element in the overall restage the packaging is by far the most powerful and important symbol of the brand s new product message. It is also the packaging which will deliver the final impetus to try (RJ Reynolds) 19 Causes of initial brand selection relate directly to reason young person smokes User Image Young smokers wear their cigarette Brands whose product characteristics reinforce the desired user image sought are more likely than others to be selected as an initial usual brand they go on to state Package changes have historically been detrimental to established brands. (RJ Reynolds) 20 Public Health Evidence: Packaging serves as an integral component of tobacco marketing strategy. 21 There is a solid body of research demonstrating a strong correlation between the advertising and promotion of tobacco products and tobacco use. 22 Bereft of brand image cigarettes would lose their appeal. 1 Brand names and package design enable the communication of personal 3, 23 characteristics, social identity and aspirations. WATDSP Submission - Plain Labelling of Tobacco Packaging Bill 2009 Page 4

5 Study conducted with Australian smokers concluded that: Plain packaging policies that remove most brand design elements are likely to be most successful in removing cigarette brand image associations. 24 Experimental studies of plain packaging consistently show that compared to branded packs, plain packs are perceived as dull and boring, cheap looking and reduce the flair 25, 26 and appeal associated with smoking. Packaging is an important element of advertising and promotion. Tobacco pack or product features are used in various ways to attract consumers, promote products, and cultivate and promote brand identity. The effect of advertising or promotion on packaging can be eliminated by requiring plain packaging. 4 WHO FCTC Article 13 (Packaging and product features): Packaging and product design are important elements of advertising and promotion. The effect of advertising or promotion on packaging can be eliminated if plain packaging is required Packaging is necessary for brand promotion and brand switching among current smokers Evidence from Tobacco Industry Documents: Speech notes of a Brown &Williamson employee shows that the tobacco industry knew only a small percentage of smokers switched brands: There is strong brand loyalty among approximately 88% of cigarette smokers. These smokers will go into a store to buy a specific brand and if the retailer doesn't have it, the customer normally will go someplace else for the purchase (Brown & Williamson) 15 Our consumers or smokers are highly brand loyal because a cigarette brand is a highly personal purchase, Smokers want many things from their cigarette brand - familiarity, comfort from having the same brand with them day after day, the statement to their friends that they are a smoker of a particular brand and the reassurance that it will always be available unchanged tomorrow. Other products have some of these elements but a cigarette brand has them all, This regular ritual whereby the smoker has intercourse with or makes love to their cigarette several times a day from which they derive intense physical and mental satisfaction, makes the smoker: - Conservative Brand and Product Loyal Resistant to change (British American Tobacco) 16 Public Health Evidence: Smokers are intensely brand loyal with less than 10% switching brands annually No evidence of public health benefit Evidence from Tobacco Industry Documents: All four studies produced some evidence to support the hypothesis that plain and generic packaging made cigarettes less attractive and appealing. No comparable study providing contrary evidence is known to exist (RJ Reynolds) 25 WATDSP Submission - Plain Labelling of Tobacco Packaging Bill 2009 Page 5

6 The reason for this is that a lot of people that you would expect to buy generic cigarettes simply are not buying them (Brown & Williamson) 15 Plain Pack Group opportunities for action: promote international debate ; Publication & distribution of papers and materials ; and Provision of an expert bank (British American Tobacco) 7, 8 Public Health Evidence: Packs with a standardized appearance that only feature the name of brands on a plain background without brand imagery have been shown to reduce the attractiveness of 25, 26 packs and to increase the salience of health warnings. Health warnings on plain packs were seen as being more serious than the same warnings on branded packs, suggesting that brand imagery diffuses the impact of health warnings. 28 Students have enhanced ability to recall health warnings on plain packs, suggesting that 25, 26 imagery can distract from health warnings. 2.2 Packaging is for product differentiation and does not communicate health benefits Evidence from Tobacco Industry Documents: All work in this area should be directed towards providing consumer reassurance about cigarettes and the smoking habit. This can be provided in different ways, e.g. by claimed low deliveries, by the perception of low deliveries and by the perception of mildness. (British American Tobacco) 29 Lower delivery products tend to be featured in blue packs. Indeed, as one moves down the delivery sector then the closer to white a pack tends to become. This is because white is generally held to convey a clean healthy association (Philip Morris) 30 In regard to packaging supporting Parliament s image as a low tar, low nicotine cigarette: Blue & white connote lightness and is appealing (Philip Morris) 31 Document on marketing Marlboro Medium research findings: It may offer smokers of competitive full-flavoured brands, who are not yet ready to move to a cigarette designed as light but who are desirous of moving down the tar/nicotine ladder, with the perfect Marlboro alternative to lights. This entry might be a more psychologically acceptable alternative for them, under the heading Understanding its Proper Placement : Smokers realized that this new entry by Marlboro was designed to fit between Marlboro Reds and Marlboro Lights. The name, Medium, suggested so. Also, the brand s packaging supported this assumption. Marlboro Medium packaging is a combination of Marlboro Reds and Marlboro Lights packagings[sic] (Philip Morris) 32 Research indicated that smokers (particularly males) who were looking for a lighter smoke did not like the white filter or the white & gold packaging of Marlboro Lights, smokers of the Marlboro parent looking for a lighter smoke found the Lights white and WATDSP Submission - Plain Labelling of Tobacco Packaging Bill 2009 Page 6

7 gold packaging somewhat feminine. Medium was an opportunity to reinforce the Marlboro characteristics (masculine, full flavour and red) in a lighter cigarette. In the context of the global shift to lighter cigarettes and the declining share of full flavour brands, the already proven Medium product could eventually replace the Parent as the full flavour variant. The Medium branding would then be applied to a lower tar product with the rest of the family also moving down the delivery scale. Marlboro s key characteristic is flavour which is most clearly signified by the use of the colour red. But overall brand growth is now being driven by the gold/white Marlboro Lights. Medium offers the red but mild solution to the danger that the success of Marlboro Lights could eventually dilute the original brand message (Philip Morris) 33 The proposed design for Lights, Ultra Lights and Menthol Lights should be amended to have a red roundel with white lettering. This provides clearer differentiation from the parent and better communicates lightness (British American Tobacco) 34 Packaging brief on new design for Special Lights and Super Lights variants: Although the products will initially be launched in different markets, it is possible at some point in time, they will exist next to each other in one market. Therefore it is important that the two variants can easily be distinguished and positioned on the delivery scale. (British American Tobacco) 35 Between you and me, the reduction of deliveries has kept many smokers in the market who would otherwise have quit (British American Tobacco) 16 Advertising objective for package design: To communicate effectively that VICEROY is a satisfying, flavourful cigarette which young adult smokers enjoy, by providing them a rationalization for smoking, or, a repression of the health concern they appear to need (Brown & Williamson) 36 Public Health Evidence Market-testing studies show that package design through the use of varying colour and other design elements induces smokers to expect, and then actually experience, their cigarettes to be lower strength, lower in tar and lower in health risk than exactly 3, 37 the same cigarette presented without this packaging. Research examined the impact of brand imagery on consumer perceptions risk: Perceptions of risk were also associated with brand imagery. Packages with lighter colors, and packages with white versus gray symbols were rated as lower tar and lower health risk. 38 Seventy five percent of adult smokers incorrectly believed there was a difference in health benefits between brands. This was replicated in the sample of children who have grown up during an era when most forms of tobacco advertising have been banned. Both adult smokers and children were much less likely to perceive any difference in terms of health risk when the packs were plain. They were also much less likely to view the plain packs as attractive and something they would like to smoke. 21 WATDSP Submission - Plain Labelling of Tobacco Packaging Bill 2009 Page 7

8 2.3 Plain packaging could increase smoking among youth: Evidence from Tobacco Industry Documents: Document for Camel filter under the heading The Youth Market : Judgementally, a brand s ability to gain acceptance among younger smokers is an indication of its potential for future success. The size of the market is also large, introduce a new package design which will increase young adult appeal (RJ Reynolds) 39 Package design and marketing strategy: To communicate a young smoker image; flavourful, satisfying, high quality product image; and a modern attractive pack image (Brown & Williamson) 36 It recognizes that a cigarette pack is actually an item of apparel, and has a character of honesty, simplicity and timeliness which is unique in the industry. The pack has been created, named, packaged and produced with the sole objective of achieving an important and profitable share of Lo-fi cigarette sales by appealing with maximum personal impact to the more youthfully oriented members of this market segment, the strategy was to offer this target group a cigarette they can identify with a cigarette that suggests peer acceptance a cigarette that reflects changing times and tastes a cigarette that offers in its name/packe[sic] graphic entity a new and personal alternative to any other brand now available (Lorillard) 40 Public Health Evidence: Research shows that tobacco advertising and promotion increases uptake of smoking among adolescents. The move toward a plain or generic packaging would remove another form of advertisement and would therefore impact on the uptake of tobacco smoking in this younger population. 41 The evidence shows that youth are more influenced by tobacco marketing than adults, and there is evidence of a causal relationship between the advertisement and promotion of tobacco products and smoking initiation. 42 Research to date suggests that plain packages are less attractive and engaging and may 28, 38 reduce brand appeal, particularly among youth. Teens are much less likely to associate specific brands with specific types of people when packs are plain. 25 Consumer research indicates that decreasing the number of design elements on the package reduces its appeal and perceptions about the likely enjoyment and desirability 3, 24 of smoking. Plain and generic packaging of tobacco products (all other things being equal), through its impact on image formation and retention, recall and recognition, knowledge, and consumer attitudes and perceived utilities, would likely depress the incidence of smoking uptake by non-smoking teens, and increase the incidence of smoking cessation by teens and adult smokers. 25 WATDSP Submission - Plain Labelling of Tobacco Packaging Bill 2009 Page 8

9 3.1 Infringement of international trademark and intellectual property rights Evidence from Tobacco Industry Documents: Corporate Affairs Meeting: We don't want to see plain packaging introduced anywhere regardless of the size and importance of the market. It was agreed that we should try to improve our argumentation on the issue. A task force will be appointed to assist our efforts in this area. You all received at our meeting a document on legal arguments regarding plain packaging issued by Ken Schoenholz (Philip Morris International) 5 Pictorial warnings, and those occupying a major pack face or faces (front and back) or a disproportionately large area of advertising space, should be resisted, as should moves to plain or generic packs. Every effort should be made to protect the integrity of the company's packs and trade marks Objectives To minimise the damage to the Group's most valuable assets. Made marks, pack designs (British American Tobacco) 43 The industry should set the agenda in an effort to confine the argumentation to political, economic, international trade, and intellectual property issues (Tobacco Institute of New Zealand) 44 Initial Report and Backgrounder by the Tobacco Institute of New Zealand (TINZ) working closely with the Tobacco Institute of Australia (TIA) discusses the strategic value of shifting the debate from health to property rights: 44 Any initiative affecting cigarette packs be it for bigger warnings, repositioned warnings, wider declaration of constituents, more space for consumer information, inserts, quit information or a progression toward plain packs should not be contested as a health issue, a children's smoking issue, or a consumer information issue. It should be treated as expropriation of Intellectual Property and contested politically on that basis. If this strategy is followed the industry has a greater chance of both setting its own agenda and avoiding the need to critique anti-smoking proposals from a back foot position. The Plain Pack Group identifies opportunities for action focusing on: reviewing treaties and conventions, industry bodies with trademark protection interest, GATT/TRIPS as current conventions and treaties afford little protection and domestic political solutions needed (British American Tobacco) 7 Another document regarding the Plain Pack Group notes: Strong legal accent. The group were examining: Treaties & conventions ; industry bodies ; All with trademark protection interest ; GATT/TRIPS. It was reported that Current conventions & treaties afford little protection ; GATT/TRIPS little joy ; and Domestic political solutions needed (British American Tobacco) 8 The Company has also considered the issue of whether the proposed restrictions would be in breach of the Paris Convention on industrial property and the Australian Trade Mark Act. We are advised that there is no basis for any legal challenge against State and Territorial Governments on these grounds (WD & HO Wills Australia) 45 WATDSP Submission - Plain Labelling of Tobacco Packaging Bill 2009 Page 9

10 NB: In 1993 Wills and Rothmans wrote to the British Consulate General in Sydney claiming that altering cigarette packaging labelling was in contravention to Australia s GATT obligations. The response they received was that: I have consulted my colleagues in ITF and the Patent Office about these claims, as requested and their joint view is that these claims do not hold water and require several large imaginative leaps. In response to the tobacco industry argument on the Draft TRIPS Agreement, the consulate add: It would not be a breach of the TRIPS code for a country to have a complete ban on the sale of tobacco and the registration of a trade mark for tobacco cannot prevent the operation of other regulations. The consulate concluded that: ITP do not see that Wills have a case (WD & HO Wills Australia) 46 Public Health Evidence: General Agreement on Tariffs and Trade (GATT) contain health exemptions Concerns about precedent/efforts to engage other industries Evidence from Tobacco Industry Documents: No country anywhere in the world requires plain or unbranded packaging of tobacco products (British American Tobacco) 47 A 1994 Letter from John R McDonald regarding plain packaging initiatives and the Canadian tobacco industry: We are extremely concerned about these world precedent setting initiatives. We are under a very tight time frame (Rothmans) 48 If the use of cigarette company trade marks is banned, should the use of trade marks also be banned for products such as sugar and chocolate (they might tempt diabetics); fat products (bad for people with cardiovascular problems) and all products with preservatives or colorants (bad for hyperactive children)? (British American Tobacco) 49 Report by the TINZ and TIA strategise: The liquor industry will be encouraged to become an active third party (British American Tobacco) 44 Letter regarding GATT/TRIPS process: help to context the issue as a problem that other industries also face so as to eliminate the perception of tobacco industry isolation (British American Tobacco) 50 But Plain Pack Group documents reported: Other industry groupings little support 8 ; little support from other industry groupings 7 (British American Tobacco) WATDSP Submission - Plain Labelling of Tobacco Packaging Bill 2009 Page 10

11 WATDSP Recommendation In relation to the proposed action in the Bill to amend the Trade Practices Act 1974 and Trade Practices (Consumer Product Information Standards) (Tobacco) Regulations 2004 to ban advertising, logos or trademarks and specify the appearance requirements for cigarette packaging the WATDSP recommends that: Tobacco packs should be regulated as the key promotional vehicles that they are. Tobacco packages should be required to be sold in plain packaging. Plain packaging would limit the use of the pack as a promotional vehicle, increase the effectiveness of health warnings and will reduce the deceptive potential of packaging. As Wakefield, Morley, Horan and Cummings (2002) have summarised: if packs are effectively acting as advertisements for cigarettes, if their design characteristics make them more attractive to teenage smokers, communicate information about cigarettes that may be misleading (such as implying they are less strong or milder in some way), or minimise the salience of health warnings and contents information, then pack design ought to be subject to regulation. 22 Please find attached a selection of documents as cited in this submission. It should be noted that the tobacco industry documents used have been selected from those available over previous decades. Please do not hesitate to contact us if you have any further queries. With best wishes, Mike Daube Professor of Health Policy Curtin University Jaimee Coombs WA Tobacco Document Searching Program WATDSP Submission - Plain Labelling of Tobacco Packaging Bill 2009 Page 11

12 References 1. Cunningham R, Kyle K. The case for plain packaging. Tobacco Control. 1995; 4: Wakefield M, Letcher T. My pack is cuter than your pack. Tobacco Control. 2002; 11: National Preventative Health Taskforce. Australia: the healthiest country by Barton, ACT: Commonwealth of Australia; World Health Organisation. WHO Framework Convention on Tobacco Control. Geneva: WHO; Dangoor D. Philip Morris. PMI corporate affairs meeting, Rye Brook February 15 & 16, Mar Philip Morris Unknown. Plain packs group members. 7 Aug British American Tobacco Unknown. The public environment. 29 Jul British American Tobacco Unknown. DB presentation to GM's conference Thursday 21 July Jul British American Tobacco Little A. Development of cigarette packaging. 1 Oct Tobacco Institute Miller L. British American Tobacco Company Limited. Principles of measurement of visual standout in pack design. 23 May British American Tobacco Unknown. No Title Philip Morris Uknown. "The vanishing media". British American Tobacco Stockdale B. RJR. Australia trip topline learning (highly restricted market). 12 Feb RJ Reynolds Unknown. Opportunities in packaging innovation Philip Morris Unknown. No title. Brown & Williamson Bingham P. The cigarette market beyond British American Tobacco FCB/LKP. Where is Winston headed? 11 Jan RJ Reynolds Baroody G. Promotion learning and brand responsiveness. 24 May RJ Reynolds Leary E. First quarter 1988 Introduction of new SALEM family packaging. 13 Jul RJ Reynolds Hall L. Marketing Research Department. Early warning system input - Reasons for smoking, initial brand selection, and brand switching. 25 Oct Research Hammond D, Dockrell M, Arnott D, Lee A, McNeil A. Cigarette pack design and perceptions of risk among UK adults and youth. European Journal of Public Health. 2009: Wakefield M, Morley C, Horan J, Cummings K. The cigarette pack as image: new evidence from tobacco industry documents. Tobacco Control. 2002; 11: Scheffels J. A difference that makes a difference: young adult smokers' accounts of cigarette brands and package design. Tobacco Control. 2008; 17: WATDSP Submission - Plain Labelling of Tobacco Packaging Bill 2009 Page 12

13 24. Wakefield M, Germain D, Durkin S. How does increasingly plainer cigarette packaging influence adult smokers' perceptions about brand image? An experimental study. Tobacco Control. 2008; 17: Goldberg M, Kindra K, Lefebvre J, Liefield J, Madillmarshall J, Martohardjono N, et al. When packages can't speak: possible impacts of plain and generic packaging of tobacco products RJ Reynolds Goldberg M, Liefield J, Madill J, Vredenburgh H. The effect of plain packaging on response to health warnings. American Journal of Public Health. 1999; 89(9): Quit Victoria. Fact sheet 2: tobacco displays: myths vs facts. Available from: Rootman I, Flay B. University of Toronto Centre for Health Promotion. A study on youth smoking, plain packaging, health warnings, event marketing, and price reductions. Key findings Brown & Williamson Short P. [Note from PL Short regarding conference on marketing]. 28 Apr British American Tobacco Philip Morris, EEC Region, Product Innovation Group. Marketing new products in a restrictive environment. Philip Morris International Marketing Meeting. Naples, Florida, June Philip Morris Unknown. PARLIAMENT audit summary Philip Morris Bamundo Qualitative Research. A qualitative assessment oof smokers' reactions to and feelings about Marlboro Medium Philip Morris BATCo. Tools of the cowboy's trade Marlboro Medium British American Tobacco Hacking I. TSG briefing: progress of Lucky Strike packaging. 4 Mar British American Tobacco Unknown. Packaging brief Typhoon/Delight. British American Tobacco Unknown. Viceroy. Marketing strategy. Brown & Williamson Freeman B, Chapman S, Rimmer M. The case for plain packaging of tobacco products. Addiction. 2008; 103(4): Hammond D, Parkinson C. The impact of cigarette package design on perceptions of risk. Journal of Public Health [cited 31 Mar, 2010]; Advanced Access: Gaylan P. Excerpts from Camel filter and the young adult smoker. 19 Apr RJ Reynolds Marketing Corporation of America. MCA. Lorillard new prodcut development Zack consumer promotion plan. 9 Jul Lorillard The Royal Australasian College of Physicians. Plain tobacco packaging - all tobacco products: a policy position statement of the Royal Australasian College of Physicians. The Royal Australasian College of Physicians; 2009 [updated. Available from: DB93349D37F3E Pierce J, Choi W, Gilpin E, Farkas A, Berry C. Tobacco industry promotion of cigarettes and adolescent smoking. Journal of the American Medical Association. 1998; 279(7): WATDSP Submission - Plain Labelling of Tobacco Packaging Bill 2009 Page 13

14 43. Unknown key area paper: corporate affairs British American Tobacco Thompson M. The Tobacco Institute of New Zealand Limited. Protection of intellectual property: initial report and backgrounder. 10 May British American Tobacco Johnston A. WD & HO Wills (Australia) Limited. Tobacco sponsorship and labelling Australia. 6 Aug British American Tobacco Hughes P. [Note from PJ Hughes to Martin Riordan regarding cigarette package]. 26 Jul British American Tobacco British American Tobacco. Plain packaging. London: British American Tobacco; 2010 [updated 21 Jan, 2010; cited 20 Jan]. Available from: 690F0C12574BB00352BD5?opendocument&SKN= McDonald J. [Letter from John R McDonald regarding plain packaging initiatives and Canadian tobacco industry]. 5 Jul British American Tobacco Unknown. Industry response material. British American Tobacco Luik J. The Niagara Institute. [Letter from John Luik to Tony Wood regarding GATT/Trips process]. 31 Dec British American Tobacco. WATDSP Submission - Plain Labelling of Tobacco Packaging Bill 2009 Page 14