Interference with Endgame Policies

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Background

The World Health Organization  Framework Convention on Tobacco Control (WHO FCTC) is an international treaty that aims to reduce the demand and supply of tobacco. It entered into force in February 2005, and as of 2023, there are 183 Parties to the treaty.1

Article 3 of the WHO FCTC establishes that “the objective of this Convention and its protocols is to protect present and future generations from the devastating health, social, environmental and economic consequences of tobacco consumption and exposure to tobacco smoke by providing a framework for tobacco control measures to be implemented by the Parties at the national, regional and international levels in order to reduce continually and substantially the prevalence of tobacco use and exposure to tobacco smoke”.2

What is The Endgame?

The tobacco ‘endgame’ is the concept of moving beyond a focus on tobacco control, towards implementing policies and strategies that could phase out tobacco products entirely.3 According to Cancer Research UK, among others, this would require systemic changes, including:

“initiatives designed to change/eliminate permanently the structural, political and social dynamics that sustain the tobacco epidemic, in order to achieve within a specific time an endpoint for the tobacco epidemic.”45

This could involve the reduction of prevalence of smoking to – or very close to – zero.

Policy Options

Research conducted into potential endgame strategies has identified plausible new policies for reducing smoking to minimal levels. These include:

  • A tobacco-free generation policy, which precludes the sale and supply of tobacco to individuals born after a certain year67
  • A ‘sinking lid’ strategy, which involves establishing steadily decreasing quotas on the sales or imports of tobacco products678
  • Substantially reducing the number of tobacco product retailers, which could include restricting retailer density, location, type, or licensing, or restricting tobacco sales to government run outlets67910
  • Mandating low-nicotine levels in tobacco products611
  • Banning the sale of one or more tobacco products610
  • Shifting control of the supply and distribution of tobacco products away from tobacco companies312

Implementation of Endgame Policies

National goals and policies

The first countries to propose tobacco endgame goals, and start developing legislation to achieve these targets, were Finland,1314 New Zealand,15 Ireland,16 Scotland,17 Sweden18 Canada,1920, Malaysia,21 Bangladesh,22 Denmark,23 and the Vatican City.23 Other countries that have more recently adopted endgame goals include the Netherlands,2425 Australia,26 France,2327and the UK.28

In 2004 Bhutan was the first country to ban the sale of tobacco products and smoking in public places. In 2010 the government imposed a comprehensive ban on tobacco sales in Bhutan.2930 However, the legislation was reversed in 2021 due to concerns that increased tobacco smuggling could result in cross-border transmission of COVID-19.29

The first country to introduce a generational ban on tobacco use was the Maldives.31 In May 2025, President Dr. Mohamed Muizzu of the Maldives ratified a landmark piece of legislation, the Second Amendment to the Tobacco Control Act, introducing a generational ban on tobacco use,31 a step forward towards a tobacco -free future.

Apart from in Bhutan, Bangladesh, France, the Vatican City, and the Maldives, the goal for the other countries has been to have a smoking prevalence of less than 5% of the population.23

Regarding the other measures, as of 2025, the Campaign for Tobacco Free Kids (CTFK) policy database shows that 13 countries have banned the sale of waterpipe tobacco products, and 20 countries have banned the sale of smokeless tobacco products.32 A review carried out in 2020 showed that 40 countries had active or pending flavoured tobacco product policies that ranged from banning flavoured tobacco, to banning flavour descriptors and images on packaging.1033 No countries have yet implemented mandatory de-nicotinisation, substantial retailer reductions or the sinking-lid strategy at a national level.

In 2004 Bhutan was the first country to ban the sale of tobacco products and smoking in public places. In 2010 the government imposed a comprehensive ban on tobacco in Bhutan.2934 However, the legislation was reversed in 2021 due to concerns that increased tobacco smuggling could result in cross-border transmission of COVID-19.29

Subnational policies

Several US jurisdictions have also implemented endgame strategies. Brookline, Massachusetts introduced a generational tobacco ban in 2021 which prohibited the sale of tobacco products and e-cigarettes to anyone born after 1 January 2000.3536 Despite litigation brought by retailers, the Massachusetts Supreme Judicial Court upheld the ban in 2024.37 Following the adoption of the policy, there was a domino effect, with other towns in the Greater Boston area considering or passing bans.38

Some cities in California have prohibited the sale of tobacco and nicotine products,39 and others have restricted the number or types of retailers permitted to sell tobacco products.40

However, a bill that would have banned sales across the state of California was put on hold, after objections from multiple organisations, some of which cited the risk of an increase in illicit tobacco trade.41

In 2016, Balanga City in the Philippines banned the sale and use of all tobacco and nicotine products to those born after 1 January 2000. It also expanded the coverage of an existing smoking ban in the city’s University Town to cover a wider radius. However, both measures were overturned in 2018 after the tobacco industry pursued litigation.4243

Tobacco industry interference

As of 2025, Malaysia, New Zealand, the UK, and Maldives are the only countries that have announced plans to adopt a generational endgame policy. New Zealand also proposed introducing mandated denicotinisation and substantial retailer reduction.

Tobacco industry interference to prevent, delay or undermine the legislation has been observed in each of these countries, and is detailed below, focussing on the actions for the ‘big four’.

Malaysia

Proposed legislation

In 2022, Malaysia proposed the ‘Control of Tobacco Products and Smoking Bill 2022’ which aimed to phase out tobacco products and e-cigarettes by introducing a generational endgame policy, prohibiting their use and sale to everyone born on or after 1 January 2007.44

However, when the latest version of the bill was tabled in 2023, the generational ban clause was omitted for all products.45

Interference from industry and associated organisations

Prior to the bill being tabled, several organisations lobbied against the inclusion of e-cigarettes in the generational endgame policy.464748 One of these organisations, the Malaysian Vapers Alliance (MVA), is a member of the World Vapers’ Alliance,49 which has received funding from the Consumer Choice Center and BAT. The MVA urged the government to exclude e-cigarettes from the generational ban, and stated that it had conducted a survey of 5000 adult vape users, 96.6% of which did not agree with the ban.50

When the generational endgame clause was removed from the bill, Malaysia’s former health minister stated that this was due to strong lobbying from tobacco companies.45 According to local advocates the bill had seen an “unprecedented level of industry interference, some of which have been done in clear violation of the WHO Framework Convention on Tobacco Control”.51

In March 2024, the deputy Health Minister revealed that the generational ban component was dropped from the bill because of lobbying by the tobacco and e-cigarette industries.52 This lobbying was confirmed by the Minister of Health, although he stated that the generational element of the bill was excluded due to a “constitutional issue”.

New Zealand

Proposed legislation

In December 2022, as part of its ‘Smokefree Aotearoa 2025 Action Plan’,53 New Zealand passed the ‘Smokefree Environments and Regulated Products’ Amendment Act’ into law, which would have implemented several tobacco endgame policies.54 The legislation included three key approaches: a ban on tobacco products being sold to anyone born on or after 1 January 2009, a significant reduction in the amount of nicotine permitted in tobacco products (an 0.8mg/g nicotine limit, compared to 15-16mg/g present in full strength cigarettes), and a huge reduction in the number of retailers allowed to sell tobacco products across the country (from 6000 to 600).5455

The legislation was due to be implemented progressively starting with the reduction in retailer numbers from July 2024, however in November 2023, as part of an agreement between parties forming a new coalition government, it was announced that all three endgame proposals would be repealed. The new finance minister stated that the additional tobacco tax revenues resulting from repealing the smokefree legislation would be used to finance tax cuts promised during the election campaign.5657 The repeal was later confirmed in February 2024.58 It was reported that health officials had urged the coalition government to maintain elements of the bill and suggested compromises such as introducing a purchase age of 25, however the Associate Health Minister, Casey Costello, rejected this.59

In February 2024, public health experts published a briefing pointing to channels of potential tobacco industry influence on the new coalition government.60 The briefing highlighted past connections between coalition politicians and tobacco companies or industry linked organisations, and noted that the arguments used by the coalition government against tobacco endgame policies aligned with those used by tobacco companies.60 It also called for all government members to declare any past and current industry connections.6061

In March 2024, the broadcaster RNZ published an investigation showing that notes were sent from Costello’s office to healthcare professionals bore a strong resemblance in to the language of the tobacco industry, sparking allegations of big tobacco influencing the government.62 RNZ pointed out that the notes had delineated a set of actions including removing tax on smokeless tobacco products and grouping heated tobacco products (HTPs) under the definition of ‘vaping’.6364

Interference from industry and associated organisations

In 2021, following the release of the Smokefree Aotearoa 2025 Action Plan, Imperial Brands, BAT and JTI all submitted responses to the government consultation opposing the major endgame policies.65 Industry linked organisations and individuals also submitted responses opposing the legislation. These included submissions from Centre for Research Excellence: Indigenous Sovereignty and Smoking (COREISS),66 which is funded by the Foundation for a Smoke Free World, and The New Zealand Initiative,67 a think tank whose members include BAT and Imperial Brands.68

In June 2021, BAT reportedly facilitated a protest amongst convenience store owners to contest the proposed tobacco product restrictions.69 BAT supplied the dairy owners with postcards which opposed the measures, including the comment “If nicotine is slashed, filters banned and price goes up, many people will go to the black market – these will badly hurt my business, increase risk of robbery to personal safety and could force store to close.” Thousands of these postcards were reportedly delivered to the New Zealand Parliament.69

In August 2023, the ‘Save our Stores’ campaign, another seemingly grassroots initiative supported by convenience store owners,70 called for users to sign a petition urging the government to repeal the latest Smokefree 2025 laws. The campaign website stated that it was “supported by” BAT New Zealand and Imperial Brands New Zealand. The campaign website argued that “A ban on normal strength cigarettes will just mean the illicit trade in tobacco products will boom and be controlled by criminal networks”. It also stated that the legislation would destroy small businesses, and that taking away the tax revenue raised by tobacco sales would “hurt families who are already struggling to make ends meet”.71 These narratives were repeated in a series of Facebook adverts published as part of the campaign between August and November 2023, with one advert also stating “tobacco taxes pay for 35,000 police officers”.72

This kind of astroturfing is a well-documented industry tactic. See also E-cigarettes: Tobacco Company Interests in Single Use Products for evidence of lobbying by industry-funded organisations in New Zealand and other countries.

UK

Proposed legislation

In October 2023, the UK Prime Minister Sunak announced plans to introduce a generational endgame policy. The Bill would prohibit the sale of tobacco products to anyone born on or after 1 January 2009. All tobacco products, cigarette papers, waterpipe tobacco and herbal smoking products were included in the proposal. The Bill also proposed to regulate the flavours, display, packaging of all e-cigarettes (vapes) and nicotine products.2873

Later that month, the Westminster government opened a four nations consultation on the tobacco endgame policy, as well as on potential measures to curb the rise in youth e-cigarette use.74

The consultation closed on 6 December 2023.75 In response to the submissions, the Westminster government confirmed its plans to introduce a generational tobacco ban, to ban disposable (single use) e-cigarettes and to bring forward new powers which would allow the government to restrict e-cigarette flavours, packaging and retail display.76 The Scottish and Welsh governments stated that they would also be introducing the new legislation.7778For more information, see Tobacco Industry Responses to Public Consultations in the UK.

After two readings at the House of Commons, on 17 April the government published a call for written evidence on the Bill,79 with oral evidence sessions on 30 April and 1 May.80

Also, in April 2024, Scotland introduced a Tobacco and Vapes Bill Legislative Consent Memorandum.81 Evidence sessions were held in May, and UKVIA and the Scottish Grocers’ Federation were invited to contribute.8283 UKVIA described the session as “constructive”.84 See below for more on these organisations.

With the 2023/24 Bill at Report stage,85 on 22 May, the UK Prime Minister announced a general election to be held on 4 July.86 Although Sunak said in his speech that ‘[w]e will ensure that the next generation grows up smoke free,’ the Bill was not among the legislation to be rushed through before the dissolution of parliament.878889 Documents released following FOI requests revealed that the ‘Big Four’ transnational tobacco companies had warned ministers of potential legal action. There was also lobbying and outreach to Conservative MPs by tobacco companies. Sunak subsequently dropped the Tobacco and Vapes Bill from the legislation he intended to push through before the election.90 Accordingly, the UK Bill was shelved.91

In November 2024, the Labour government introduced . The 2024/2025 Bill included new measures banning e-cigarette advertising and sponsorship, expanding smokefree areas to outdoor spaces such as playgrounds, and giving the power to legislators to introduce a licensing scheme for retailers to sell tobacco and nicotine products.92 As of June 2025, the 2024/25 Bill has passed the House of Commons and is in consideration at the House of Lords.93

Interference from the tobacco industry

After the generational policy was announced, tobacco control researchers outlined arguments that they anticipated the industry would use to in an attempt prevent or undermine the UK legislation, based on previously used tactics. These included invoking libertarianism and arguments around personal freedoms; claiming that the policy would be unworkable and impossible to police; and that it would have unintended consequences, such as increasing cigarette smuggling.94 Below is an overview of lobbying and interference by the tobacco industry and associated organisations in relation to the 2023/2024 and 2024/2025 Bills.

Lobbying to the 2023/2024 Bill

In December 2023, there were reports that the tobacco industry was lobbying the government to increase the age of smoking to 21, instead of introducing the new generational endgame legislation.95 An industry source quoted by The i newspaper stated that the generational ban was “unenforceable, and the inevitability of such a ban leading to a black market run by dangerous criminal gangs, there’s a large number of libertarian Tory MPs that do not like the idea the government is limiting people’s free choice…if the Prime Minister does cancel the plan, then [the industry] won’t object to him raising the smoking age to 21”.95 The illicit tobacco trade has often been used by tobacco companies to promote key misleading narratives that advance their own business goals. See also Arguments and Language.

The i also revealed that the tobacco industry had been “inundating MPs with lobbying material in a bid to persuade them to oppose the changes”. It also reported that a letter was sent to MPs, seemingly from constituents, but in fact drafted by employees of tobacco companies, which called the generational ban “ridiculous” and “impractical, illiberal and untested”.95 Andrea Leadsom MP, Parliamentary Under Secretary of State in the Department of Health and Social Care, warned that the industry was working behind the scenes to block the policy.96

Following the announcement of the plan to introduce a generational endgame policy in 2023 tobacco companies lobbied the UK Department of Health and Social Care (DHSC) directly, using many of the same tactics and arguments.

Legal threat from PMI

In November 2023, PMI sent a pre-action protocol (PAP) letter to the DHSC.9798 The PAP letter argued that the consultation outcome was predetermined and that it failed to give adequate reasons regarding the inclusion of HTPs in the proposed sales ban. It also argued that the consultation period was not long enough and did not allow the submission of sufficient additional evidence.97 In a preliminary response (December 2023), the government stated that it was already possible for organisations to upload supporting documents, but to make this clearer, this instruction had been added to the consultation landing page.99

The government’s full response a week later stated that the legal challenge was “misguided and wholly without merit” and would be “an unjustified attempt to delay or derail important legislative change”.100 With regard to HTPs, it stated that some of PMI’s claims were “highly subjective and lack supporting independent evidence”. The response concluded that:

“The Government does not intend to enter into any negotiations with the tobacco industry…and will not as you propose “discuss, on an urgent basis, the potential removal of HTP from the scope of the proposed legislation” …the proposed claim has no merit and your client is urged to reconsider its intention to pursue the claim”.100

The Telegraph newspaper reported that PMI later withdrew the threat, stating “We notified the government of procedural flaws in the consultation process. They subsequently amended the consultation procedure to allow substantive responses and answered other enquiries. As such, we withdrew the claim on 15th January”.98 PMI told the newspaper that it agreed with the UK’s smoke-free 2030 plans, but did “not believe that reduced-risk smoke-free products—including heated tobacco—should be included alongside combustible cigarettes in any potential legislation”.98 In December 2023, PMI reportedly held roundtable events with UK MPs to lobby for its heated tobacco products (HTPs) to be exempt from future smoking bans.95

In March 2024, the External Affairs Director for the UK & Ireland at Philip Morris International (PMI), called for collaboration with the government to support adult smokers switch to less harmful alternatives emphasising the importance of adopting science-backed solutions.101 Phillip Morris Limited (PML, PMI’s UK subsidiary) has created a website, undated, called ‘not a cigarette’ which states that HTPs and e-cigarettes(vapes) are not similar to cigarettes so should not be included in the ban. The site appears to be targeted at policy makers.102

Complaints from BAT

In November 2023, a law firm acting on behalf of BAT contacted the DHSC, arguing that the proposals would “materially impact the rights of our clients and others”. It also argued that there was not enough information “regarding the impacts and costs and benefits of the proposals to permit intelligent consideration”. It also contended – like PMI – that the consultation period was not long enough, and did not allow the submission of sufficient supporting evidence.103 BAT were reported to be sponsoring a roundtable due to be hosted by MP Graham Brady on behalf of the Centre for Policy Studies in December 2023 to “discuss the Government’s smokefree ambitions, what policies could support the goal, and what a Conservative approach to public health should look like.”95104 BAT stated that the proposed legislation would be difficult to enforce, and risked creating a new category of “under-age adults”.105 It also published briefing in response to the consultation, which outlined its stance on e-cigarette restrictions.106

JTI mobilises retailers

JTI encouraged retailers to respond to the government consultation in a feature in the magazine Talking Retail. Entitled ‘The Generational Ban: Explained’, the article described the ban as “an experimental policy not supported by evidence”.107 Previously, in November 2023, JTI carried out a survey of 1000 convenience retailers in the UK, and reported concerns that a smoking ban would harm business, increase illicit trade, make ID checks more complicated for staff and impact staff training around underage sales.108109

In March 2024, an article sponsored by JTI was published on Labour List (which is “supported by but independent of the Labour Party”)110 “as a contribution to public discussion”. Written by MP Virendra Sharma it criticised the generational smoking ban policy, it echoed industry arguments.111

Imperial criticises the process – and issues a legal threat

In December 2023, Imperial Brands wrote to the DHSC, arguing that the consultation was “materially deficient and unfair in several important respects”. As with PMI and BAT, Imperial stated that the consultation period was not long enough, and did not allow the submission of sufficient supporting evidence. It also argued that the evidence base for the proposal should be publicly shared.112 Imperial published a summary of its response to the government consultation. It said it opposed the generational ban, as it would be “unworkable and unenforceable, and would see an explosion of illicit trade in tobacco”. It also argued that it would not reduce smoking rates.113 Imperial’s UK head of corporate and legal affairs stated in the retail press in January 2024 that it was having “direct conversations with government” and talking to MPs “to make them aware of illicit trade that is already a problem in their constituencies” including highlighting “loss of revenue for the average retailer”. Imperial also stated that it did not support e-cigarette restrictions including plain packaging, device standardisation, or flavour bans.114

According to documents released following FOI requests, all four transnational tobacco companies have warned of potential legal challenges.115 In April 2024, Imperial issued a legal letter threatening a “judicial review” of the consultation process, naming BAT, JTI, and PMI as potential co-claimants. Although Imperial has not initiated court action, a spokesperson confirmed the company is “monitoring legislative developments”.115

A response letter by the government to Imperial indicated:

“[T]he Secretary of State considers that your proposed claim is outside the Court’s jurisdiction, misguided, and wholly without merit. The proposed challenge would be an unjustified attempt to delay or derail important legislative change.” Adding, “the proposed claim would have no realistic prospect of success and would be dismissed.”116

Imperial Brands also reportedly engaged with MPs and government officials regarding the proposals, with a spokesperson for Imperial Brands stating “We understand the Government’s desire for new tobacco control measures, because of the health risks associated with smoking. But, like any prohibition, the proposal to ban the legal sale of cigarettes over time threatens significant unintended consequences.”95

2024 – the lobbying continues

Ahead of the second reading of the 2023/2024 Bill on 16 April 2024, The Guardian reported tobacco industry lobbying activities to attempt to derail the bill.117 According to Cancer Research UK, the tobacco industry had been working behind the scenes on a variety of tactics, including direct e-mails to MPs from BAT. Arguments used included increasing the age of sale from 18 to 21 instead of a generational sales ban, excluding cigars from the ban, and adding a clause to allow future amendments.117 Chris Whitty, England’s Chief Medical Officer, urged MPs to ignore tobacco industry lobbying and to support the bill:

“[tobacco industry] talking points, usually introduced by paid lobbyists, need to be addressed head on. They try to link their products to ‘choice’ despite the fact their sales are based on addiction (taking choice away).”117

In total 56 submissions were made in response to the call for evidence for the 2023/24 Bill.118 Three of the ‘big four’ transnational tobacco companies expressed their support to the government  smokefree generation ambition but all along with the Scandinavian Tobacco Group raised various objections:

  • PML asked the government to consider excluding HTPs from the sales ban, deeming this measure “inappropriate” and accusing it of ignoring supporting evidence.119
  • BAT stated that ‘smarter regulations’, are needed. It also opposed the inclusion of HTPs and criticised the incrementally increasing age restriction of the sales ban, describing it as “ineffective”, unnecessary and impossible to enforce”. It suggested raising the age from 18 to 21 years instead, citing “[i]ndependent evidence” on its effectiveness. BAT also opposed restricting flavours to adults.120
  • Imperial Brands said that the bill will lead to increase in illicit trade and violence against retailers. Imperial also criticised the government for “grant[ing] significant powers to ministers to regulate the vape category”. It also argued for increasing the age from 18 to 21 instead of the sales ban, citing the “intrusion on the public’s freedom to make informed choices”. Imperial Bands opposed the inclusion of HTPs in the definition of tobacco products, and the restriction of flavours in electronic products .121
  • JTI argued that the Bill “fails the test of proportionality; it is deeply illiberal; it would be impractical to implement; and it would hand the UK’s tobacco market to criminals.” Opposing the age restriction JTI argued that “[t]he Government’s own data, released as part of the consultation process for the Bill, shows that raising the age to 21 would have a similar effect on UK smoking rates without the need for a generational ban and the associated impracticalities ”.122
  • The Scandinavian Tobacco Group submission opposed the inclusion of cigars and pipe tobacco arguing that consumption of these product is low in the UK and restricted to specific demographics.123124 However, recent evidence from a nationally representative cross-sectional survey examining adult smoking in England revealed a significant increase in pipe, cigar, or waterpipe from approximately 150,000 in 2013 to over 770,000 in 2023. Cigars were the most popular of the three.125

A list of the organisations and individuals that have submitted written evidence to the Public Bill Committee can be found on the UK Parliament website.126 A TCRG study examined consultation submissions from tobacco and nicotine industries and related organisations, in response to the UK government call for evidence for the 2023/24 Tobacco and Vapes Bill127 introduced by the Conservative government.128 The study revealed industry use of tactics long employed by tobacco companies to oppose regulation.128

Interference persists under the new government

PMI lobbying for exemptions

In September 2024, following the formation of the new government, but before the introduction of the 2024/2025 Bill, PMI sent a letter to the Parliamentary Under-Secretary and Secretary of State for Health and Social Care, expressing its support for the prospect of a smoke-free generation. However, it argued that adults should be given the opportunity to choose ‘less harmful alternatives’.129

In June 2025, The Guardian reported that PMI had paid for Lord Vaizey to visit PMI’s research facility in Switzerland at the end of March.130 Lord Vaizey had declared this overseas visit in his register of interests.130131 As reported by The Guardian, the trip was six weeks before Lord Vaizey proposed an amendment to delay the government’s plan to include HTPs in the generational ban.132 Lord Vaizey argued there was a need for further research into the health impact of HTPs compared to cigarettes.130132

BAT lobbies on e-cigarette regulation

In August 2024, BAT sent a letter to the Parliamentary Under-Secretary, requesting to consider measures in the 2024/2025 reintroduced Bill to ensure that e-cigarettes are not sold or promoted to young people. It suggested to restricting flavours such as cotton candy and the use of cartoon characters or youth culture-related imagery.133 BAT’s stated position was to maintain fruit flavours to support adults to transition away from smoking.134 Then, in September 2024, a BAT representative criticised the forthcoming Bill, stating that the government should focus on cracking down on illegal e-cigarettes rather than implement “redundant policies on cigarettes”.135

In March 2025, BAT said that the Bill “continue[d] to be strong in theory and weak in practice,” arguing that it would lead to delays in implementing a retail licensing system. It also proposed a mandatory 20mg cap on nicotine pouches, and pre-market testing of nicotine products.136

In September 2025, BAT UK announced the launch of its “Vapers Deserve Better” campaign, calling for “robust, enforceable regulations”. BAT repeated its demands for mandatory pre-market testing, a retail licensing scheme, and stricter penalties for non-compliance, claiming that without these measures the UK would be “in serious danger” of not achieving its smoke-free 2030 goal.137138

In October 2025, the managing director of BAT in the UK and Ireland stated in a BBC interview that allowing adult-focused e-cigarette advertising could help adults switch from cigarettes and become aware of alternative products. This proposal conflicts with the Tobacco and Vapes Bill, which contains a complete ban on such advertising.139

In October 2025, The Guardian reported that Lord Strathcarron had proposed an amendment to the Bill, suggesting that the legal purchasing age be raised from 18 to 21 instead of the generational ban. The Lord also revealed to The Guardian and The Examination that he had discussed the Bill with a family member, whom he described as “very high up” at BAT, though without revealing their name.140

Imperial says Article 5.3 does not apply for e-cigarettes

In July 2024, Imperial sent a letter to the Secretary of State for Health and Social Care asking for a meeting to discuss the bill components and to provide their perspective on how “a balance must be struck between tackling youth vaping, and encouraging adult smokers to transition away from tobacco to potentially less harmful alternatives”. The letter concluded with a note indicating awareness of provisions in Article 5.3 on interaction between policy makers and the tobacco industry, but suggesting they do not apply in the case of e-cigarettes regulations.141 The text reads:

“Imperial Brands plc is fully committed to all industry-Government interactions being transparent and accurate. The treaty, a subsequent European Court of Justice ruling, and the UK Government’s own guidance on Article 5.3, do not warrant legitimate stakeholders being excluded from opportunities to contribute and consult on relevant regulations. It also does not preclude policymakers – elected or unelected – from engaging with parties with links to the tobacco industry. An open dialogue is crucial to help policymakers make objective recommendations, particularly on matters unrelated to public health”.141

In March 2025, Imperial joined JTI in urging the government to drop its plan for a generational smoking ban, arguing for a shift in focus towards stopping illegal tobacco sales.142143 JTI’s manager said “The government needs to acknowledge the scale of the problem and to crack down on illicit tobacco sales as a priority rather than implementing a generational smoking ban which will simply allow the black market to flourish.”142

In November 2025, Imperial encouraged UK retailers to respond to the Government’s call for evidence on the Tobacco and Vapes Bill.144A. Marino, Imperial Brands: retailers should respond to gov consultation on Tobacco and Vapes Bill, Asian Trader, 03 November 2025, accessed November 2025[/ref]145 The company’s UK Market Manager described the process as an opportunity for retailers to engage with policymakers and contribute to discussions affecting their businesses.144

JTI refers to Northern Ireland, crime, and illicit trade

In July 2024, JTI wrote a letter to the Secretary of State for Health and Social Care, querying the legality of the implementation of the proposed Bill in Northern Ireland in light of the EU Tobacco Products Directive (TPD2). On this basis, JTI suggested raising the tobacco purchasing age to 21, indicating it would have a similar long-term effect as the generational endgame but without the practical implementation complications.146

In November 2024, JTI argued that the updated Bill, would harm small businesses and retailers calling the government’s approach inconsistent with the chancellor Rachel Reeves’s budget plans to reduce retail crime.147

In February 2025, the public affairs manager of JTI reiterated the company’s position on prioritising illicit trade stating “[t]he government needs to acknowledge the scale of the problem and to crack down on illicit tobacco sales as a priority rather than implementing a generational smoking ban which will simply allow the black market to flourish.”142

Activities around the two bills

The use of third parties is a long-standing industry tactic. Some of the organisations lobbying for industry interests, and with a history of links to tobacco companies, are detailed below.

  • The Institute of Economic Affairs, a British think tank with a history of tobacco industry funding, published a briefing paper in November 2023 titled ‘Prohibition 2.0: Critiquing the Generational Tobacco Ban’.148 The report echoed the industry narrative that a smoking ban would drive illicit trade and “bolster criminal gangs”. It also stated that a ban would “lead to a grey market in sales between friends” and that it “infantilises one cohort of adults, discriminates on the basis of age and raises issues of intergenerational unfairness.”148 The report disregarded figures published in a review commissioned by the UK’s Department of Health in 2022 relating to the cost of smoking to the NHS, and stated “The reality is that smokers pay far more in tobacco duty than they cost the state in healthcare, while nonsmokers cost the state more, on average, in both healthcare and social security payments”.148 Action on Smoking and Health (ASH) published an analysis in December 2023 which found that smoking costs England £49.2 billion each year in lost productivity and service costs, plus an additional £25.9 billion lost quality adjusted life years due to premature death from smoking – far outweighing the money brought in from tobacco taxes.149 The IEA published another report in February 2025, “The People vs. Paternalism”, advising consumers to “fight back” against the “nanny state”.150 The IEA Director also stated that the licensing scheme in the reintroduced Bill “could be the death of the law-abiding corner shop”.151 The IEA has also criticised the UK ban on single-use e-cigarettes.
  • The Consumer Choice Center (CCC), a US lobby group with a history of tobacco industry funding and links to the Atlas Network, launched a campaign titled ‘No2Prohibition’ which urged the public to contact their MP to oppose the new legislation.152 The campaign used the argument that the legislation would result in an increase in illicit trade and stated “Discriminating against adult consumers, depending on what year they were born, is unheard of and would set a dangerous precedent for future regulations. What’s next? Alcohol? Sugar? Fat? We can only imagine”.152 The campaign included a series of social media adverts centred on messages of freedom of choice and prohibition.153 These ads were removed by Meta as they did not include verified “paid for by” disclaimers.153
  • CCC set up and funds the World Vapers Alliance (WVA), which has also received funding direct from BAT. WVA has criticised the generational smoking ban, arguing that the UK should instead be “doubling down on its harm reduction strategy”.154 WVA also urged the public to respond to the government consultation to oppose e-cigarette flavour restrictions, the disposable e-cigarette ban and inclusion of HTPs in the generational smoking ban.155 See also E-cigarettes: Tobacco Company Interests in Single Use Products for more detail on WVA lobbying.
  • CCC’s US tax return showed that in 2023, it also paid US$300,000 to Mark Oates Consulting.156 Oates is the UK director of the campaign group ‘We Vape’, the ‘Snus and Nicotine Pouch Users Alliance’, and a fellow at the Adam Smith Institute.157158 We Vape has also run a ‘Save Flavours’ campaign, urging consumers and retailers to write to their MPs and engage in government consultations, and has commissioned its own market research. See We Vape for details.
  • Another CCC platform called ‘Clearing the Air’, which is run by ex-JUUL lobbyist Peter Beckett and lobbies in the EU, has published articles undermining the 2024/2025 Bill and urging readers to submit to views and evidence.159 See Consumer Choice Center for more information.
  • Adam Smith Institute (ASI) is a think tank with funding from tobacco companies JTI and Imperial and a history of close collaboration with the tobacco industry, as detailed on the page: ASI: History of Close Ties with the Tobacco Industry. In February 2025, ASI commissioned JL Partners, the same polling company previously commissioned by BAT (see above), to conduct a poll on Great Britain adults’ perception of the 2024/25 Bill. The findings from the poll indicated that around 6000 adults perceived Bill as not a priority, and ASI urged the government and the DHSC to focus on apparently more pressing issues.160161In August 2023, ASH surveyed over 12,000 adults in Great Britain showing that the majority of people support the government’s smokefree ambition.162 Also, a study on children and young people’s perceptions on the generational endgame policy, which used focus groups of 36 participants aged 12–21, showed that most participants supported the Bill.163 In May 2025, ASI sent email invites to a roundtable focused on discussing harm reduction regarding the 2024/25 Tobacco and Vapes Bill. The email indicated that this is event would be hosted by Lord Mendelsohn of Finchley (Labour) and would also be attended by Lord Davies of Gower (Conservative).164
  • Forest, a UK-based smokers’ rights group with a history of tobacco industry funding, stated that it had urged the government not to introduce a generational ban, ahead of the government consultation deadline in December 2023. It also commissioned a consultancy to carry out a survey, which it states found that “58% of respondents think that if a person can vote, drive a car, buy alcohol, or possess a credit card at 18, they should also be allowed to purchase tobacco”.165 In March 2025, Forest commissioned a new survey which claimed that majority of people aged 18-24 would prefer to raise the smoking age to 21 instead of implementing the generational ban.166 In October 2025, Forest commissioned another survey, which claimed that only two in five UK adults see the Bill as “important”.167
  • The Association of Convenience Stores (ACS) is an organisation that represents local stores in the UK. Its “Premier Club” members include BAT, JTI, PMI, Imperial Brands, and JUUL.168 ACS stated in December 2023 that it had responded to the government consultation, and in its submission “set out a number of concerns about the practical implications of the [generational endgame] policy”. See also E-cigarettes: Tobacco Company Interests in Single Use Products for further examples of ACS and its members arguing against regulation.
  • Tobacco Manufacturers’ Association (TMA), a trade association for tobacco companies that operate in the United Kingdom. In December 2023, an industry source quoted by The i newspaper stated that TMA engaged with MPs and government officials about the proposal to raising the smoking age to 21 instead of a generational ban.95
  • In April 2024, ahead of the 2023/2024 Bill’s second hearing, the ACS, along with the TMA spoke out against the Bill. They argued that age restrictions could lead to anti-social behaviour against retailers, who would have to deal with an increase in aggressive behaviour from customers.169170 The TMA said that any age ban should be fixed, rather than changing every year, so that that retailers would be able to credibly enforce it.170
  • The Scottish Grocers Federation (SGF), a trade association for convenience stores with tobacco company members, published an article opposing several possible new retail regulations, which included the generational tobacco policy and restrictions on the sale and visibility of e-cigarettes, stating that it would harm retail businesses.171 SGF also protested its exclusion from the government’s response to the consultation, due to SGF’s connections with the tobacco industry.172 SGF has also opposed the Scottish proposed tobacco free ban, stating that the policy could potentially harm public health and contribute to the growth of illicit trade.172 However Action on Smoking and Health (ASH) polling showed that most small retailers in England and Wales support a smokefree generation policy.173 In February 2025, the SGF told ministers that the generational smoking ban could be the “breaking point” for small retailers unless stringent enforcement cracks down on illicit trading.174 See E-cigarettes: Tobacco Company Interests in Single Use Products for further evidence of SGF lobbying against product regulation.
  • C-Talk is a UK convenience-retail platform founded by Paul Cheema.175 It lists the “brands” it works with, which include PMI and JTI.175 Cheema leads a “Protect Your Store, Have Your Say” campaign,176 which, in October 2025, described the Tobacco & Vapes Bill as a risk to the convenience sector.177 C-Talk commissioned a survey of 500 corner shops and reported that more than three quarters of retailers view the Bill as an “unprecedented threat” to their business.178179 The C-Talk website provided a pre-written open letter for shop owners to submit online, to be delivered to the Business & Trade Secretary.178180 In November 2025, Cheema was awarded a “Responsible Retailer of the Year” award, which was supported by Imperial Brands.181 In 2023, Cheema, among other retailers, was quoted in a JTI advertisement feature opposing the generational ban.107
  • The UK Vaping Industry Association (UKVIA), of which the ‘Big Four’ tobacco companies were members until 2023, published a press release opposing the e-cigarette regulations, stating “the tobacco industry and illicit markets will be the only winners from bans on disposables and flavoured vapes”.182 ( See also E-cigarettes: Tobacco Company Interests in Single Use Products) UKVIA also sent a letter to the Prime Minister urging the government to reconsider.183 (UKVIA stated in September 2023 that all of its tobacco company memberships had ended. For details see the UKVIA page). UKVIA, has also criticised the 2023/24 Bill Committee for not inviting the industry to provide evidence to the bill describing the process as ‘fundamentally undemocratic’. UKVIA said it have submitted two amendments to the committee, but both have been ignored. The UKVIA said that ”[i]f the government ignores our warning, we will ensure we hold them to account for the impacts of an out-of-control black market, as they are now seeing in Australia.”184 On May 16, 2024 UKVIA sent a letter to the Prime Mister demanding an apology from the Public Health Minister Andrea Leadsom, who said that she would not consider a licensing scheme for e-cigarette retailers. This had been suggested by the e-cigarette industry, paid for by the industry, with funds passed to Trading Standards to “police underage and illicit sales”.185186 In July 2024, UKVIA sent letters to the Secretary of State for Health and Social Care, the Minister for Public Health and Prevention and the shadow health secretary requesting a meeting to discuss the future of vaping. The letter underscore there is ‘conclusive evidence that vaping is the most effective way to help adult smokers quit’. The letter also noted that the UKVIA has no members from the tobacco industry, so ‘ no barriers preventing your Department from engaging with us’.187
  • Others with previously documented links to the tobacco industry have lobbied against the bill, including the e-cigarette retailer VPZ, which received a loan of GB£12.5 million (around US$15 million) from Philip Morris International, though it states it has since repaid the loan and ended all financial ties.188 In December 2024, the company launched a survey asking people to indicate “how important flavours have been to[them]” and “explain how vaping has improved [their] health”.189 In January 2025, VPZ wrote to MPs about the 2023/2024 Bill and initiated a programme in stores to raise concerns, recommend measures, and inform the public on cigarettes vs e-cigarettes.190 VPZ has also launched an “educational” campaign called “Vaping Saves Lives”.191 In March 2025, VPZ launched a petition “[d]o not restrict vape flavours”: indicating “[w]e want the Government to not give Ministers powers to restrict vape flavours in the Tobacco & Vapes Bill, as we believe it will undermine efforts to help smokers quit”.192 In March 2025, VPZ also lobbied outside the Scottish Parliament to reconsider the regulation on e-cigarettes and warned about the danger of what it called “big puff” e-cigarettes.193
  • In April 2024, UK publication The New Statesman released a podcast episode about the UK generational smoking ban, sponsored by and featuring PMI.194 In December, The New Statesman sent out invitations to a PMI-sponsored roundtable event called “Beyond the generation ban: What can we do to support the UK’s existing 6m smokers to leave cigarettes behind?”. Its stated purpose was to “bring together policymakers, experts and other senior stakeholders” for a “frank and open discussion.”195 The invitation stated that speakers included PMI’s Director External Affairs UK & Ireland, and invitees included representatives from UK think-tanks and public health organisations.195 In 2020, PMI sponsored a New Statesman event run alongside the Labour Party Conference. For details see We Vape.

Maldives

Proposed legislation

The legislation ratified in May 2025, is set to come into force in November 2025.196 It prohibits the sale, purchase, and use of tobacco products for individuals born on or after January 1, 2007; bans people under 21 from taking part in any commercial activities linked to tobacco products, their sale and distribution; prohibits the import, possession and use of production machinery for tobacco products, e-cigarettes and associated devices and accessories; and prohibits all forms of tobacco advertising, sponsorship, and promotional activities (TAPS). In addition, it establishes a system to confiscate and dispose of prohibited tobacco products, e-cigarettes and associated accessories.31

Interference

Following the announcement of the legislation, the Consumer Choice Centre(CCC) warned that it risked opening the island to the black market, corruption and organised crime, and claimed it would put both tourism and public safety at serious risk. CCC alternatives included prioritising youth education, stronger cessation programmes, and adopting a harm reduction approach.197

Relevant Links

Tobacco Tactics Resources

Tobacco Control Research Group (TCRG) Research

The UK Tobacco and Vapes Bill (2023/4): framing strategies used by tobacco and nicotine industry actors faced with an endgame policy (a generational sales ban of tobacco products) and nicotine product restrictions, B. Matthes, T. Legg, R. Hiscock, A Gallagher, K. Silver, H. Alaouie, D. Thomas, A. Gilmore, Tobacco Control, Published Online First: 24 March 2025, doi: 10.1136/tc-2024-059207

Sunak’s smoke-free generation: spare a thought for the tobacco industry, G. Hartwell, A.B. Gilmore, M.C.I . van Schalkwyk, M. McKee, BMJ, 2023; 383 :p2922 doi:10.1136/bmj.p2922

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