Scottish Grocers' Federation

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The Scottish Grocers’ Federation (SGF) is a trade association for convenience stores in Scotland.[1] It has campaigned against several public health measures, despite being a member of the Scottish Government’s Ministerial Working Group on Tobacco Control, which is “…a forum for the development of policy to reduce the impact of tobacco on Scotland’s health”.[2]

Relationship with the Tobacco Industry

Image 1: SGF Gold Membership Benefits (screenshot from SGF website, May 2014)

SGF Members: JTI, Imperial, PMI, and BAT

SGF is primarily funded through two types of membership: retail membership and corporate “supplier” membership. There are four levels of corporate membership: Platinum, Gold, Silver and Bronze. In 2014, Gold corporate membership was worth £9,999 per year (see Image 1).[3]

In July 2018, SGF had 92 corporate members. Five were tobacco companies: Japan Tobacco International (JTI), Philip Morris International (PMI), British American Tobacco (BAT), Imperial Tobacco, and Imperial Tobacco’s e-cigarette brand blu.[4] JTI was a Platinum member, PMI, Imperial Tobacco and blu were Gold members, and BAT was a Silver member.[4]

In 2012, when SGF had only 37 corporate members (including Imperial, BAT and PMI), the total tobacco contribution accounted for 9.7 per cent of total SGF income derived from corporate memberships.[5] The current proportion of tobacco contribution to SGF corporate membership revenue is unknown.

Despite significant corporate interests, SGF has stated in the past that "policy decisions, campaigning work and lobbying activities are wholly determined by our National Executive, which is comprised solely of our retail members. Corporate members are not represented on the National Executive”.[6]

Attempted to Set Up Parliamentary Group on Tobacco Harm Reduction

In 2018, the SGF and PMI unsuccessfully tried to set up a Scottish Parliamentary Cross-Party Group (CPG) on Harm Reduction and/or e-cigarettes.[7] Richard Lyle, Member of Scottish Parliament (MSP), was asked to convene the CPG due to his personal experience as a long-term smoker turned vaper.[7] In 2017, the MSP had visited PMI’s Swiss Research and Development facility to be briefed about the company’s heated tobacco products, a trip paid for by the tobacco company.[8]

SGF Interest in Harm Reduction

In April 2018, John Lee, SGF’s Head of Policy and Public Affairs, wrote to Lyle explaining SGF’s interests in setting up the CPG:

“Whilst it goes without saying that we all support a reduction in smoking, there is no question that their replacement on the shelves with a less harmful alternative is good not just for the nation’s physical health, but also for the health of our sector”.[7]

He added:

“potentially E-cigarettes and reduced risk products could be a very important sales category for small retailers”.[7]

“Frustrated” that Tobacco Companies Could Not to be Involved

Lee's letter to Lyle refers to an earlier discussion between Lee and Lyle about the role of tobacco companies in the CPG, stating that both had agreed, yet were “frustrated”, that it was “critically important that tobacco manufacturers are not included on, nor invited to, the proposed CPG”:

“Whilst we are both frustrated that we cannot get all stakeholders around the same table to discuss an issue of such national importance, we are equally clear that many of the MSPs and organisations we wish to be involved in the CPG would not participate were ‘big tobacco’ to be involved”.[7]

Lee continued:

"We have shared with one another that we intend to continue to engage with those companies in separate dialogue recognising the role that they are playing in the provision of such new harm reduction technology in respect to scientific research alongside the widespread commercialisation of such products”.[7]

Public Relations Firms Engaged to Garner Support

Two Edinburgh-based public relations firms were engaged to gain support for the CPG proposal: Halogen Communications, which has worked with PMI to oppose the Scottish Government’s plan to implement plain packaging,[9][10] and Message Matters, which counts SGF as one of its clients.[11]

Public records of the Scottish Lobbying Register document that PMI and Halogen Communications met with Lyle on 19 April 2018, to brief the MSP on “the latest developments relating to heated tobacco products, e-cigarettes and smoking harm reduction in Scotland and the UK”, and “to discuss the possible formation of a Cross-Party Group on vaping at the Scottish Parliament”.[12][13] Lobbying Register records also show that Message Matter’s Andy MacIver, on behalf of the SGF, met with Lyle that same date to discuss the CPG.[14] It is unclear whether two separate meetings occurred, or whether PMI, Halogen, and Message Matters attended the same meeting with Lyle.

Lobbying Register records also suggest that Message Matters was responsible for generating CPG support from MSPs and public health organisations.[15][16] Yet in June 2018, the SGF and Message Matters abandoned the proposal to form a CPG on harm reduction in Scottish parliament, with Message Matters citing a reluctance of public health organisations to take part in the CPG.[17]

Campaigned Against Tobacco Plain Packaging

Image 2: Media Messengers, PMI Corporate Affairs Update, 2012

In May 2016, the United Kingdom (UK) introduced plain packaging legislation. The SGF was one of several trade associations that actively opposed plain packaging legislation proposals in the UK.

PMI Identified SGF as a “Media Messenger”

Leaked 2012 PMI documents reveal that the tobacco company planned a multi-faceted campaign to oppose the government’s proposal to introduce plain packaging.[18] As part of its strategy PMI outlined key third-party “messengers”, seemingly independent third parties like retail groups, business associations, think tanks, anti-counterfeiting groups, researchers and international organisations, to push its message in the media (see Image 2). One of the ‘Retail Media Messengers’ listed was the SGF.[18]

2012 and 2014 UK Consultations: Arguments Mirror Those of Tobacco Industry

The SGF submitted detailed responses to the 2012 and 2014 UK public consultations on plain packaging.[5][6][19] In its submissions, the SGF claimed that its nearly 2,000 retailer members employ approximately 32,000 people across Scotland, with annual sales in excess of £3.2bn.[5][6] It added that "Tobacco constitutes an important part of this economic output accounting for approximately 21 per cent of turnover for the average convenience stores with profits ranging from 5% (economy brands) to 8% (premium brands)".

One key argument against plain packaging voiced by the SGF in both submissions was that the policy would make it easier to counterfeit tobacco products, which is also an tobacco industry argument against plain packaging. In its 2012 submission to the UK consultation, SGF claimed that illicit trade “which is more prevalent in lower income, price sensitive and disadvantaged areas - will drive smokers out of legal and responsible premises selling regulated products to an illegal, irresponsible and unregulated market”.[5] The SGF further claimed that the world-wide illicit trade was growing and within the European Union had increased from 2007 to 2010, a claim not supported by UK data from Her Majesty’s Revenue and Customs (HMRC) which showed a decline in illicit trade of cigarettes between 2003/4 and 2011.[20]

SGF’s other arguments against plain packaging also closely mirrored those promoted by the tobacco industry:

  • The evidence base supporting change is neither robust nor unequivocal;
  • Packaging is not why young people smoke, the reasons are more deep rooted and more intractable: family background and socio-economic situations are far more significant than brand awareness;
  • Smokers will down trade to cheaper brands, which will lead to a loss of profits;
  • Cross-border shopping will increase among those who wish to continue smoking branded products;
  • Legality of plain packaging is unclear.
  • Transaction times will increase because packaging will have fewer distinguishing features. Note: a simple study conducted by Australian researchers found that similar claims made by the Alliance of Australian Retailers when opposing plain packaging in Australia were likely to be incorrect[21];
  • Plain packaging will make cleaning, replenishing and stocktaking more arduous thereby requiring additional resources form retailers to compensate. Note: This argument has been refuted in a research letter published in the BMJ[22]; and
  • Not enough time has been given to allow other legislative and price-based tobacco control measures to take effect.

Tobacco industry arguments were supported by evidence that was either funded by them, or not actually relevant to plain packaging.[23] Click here for counter arguments.

Image 3: BAT UK Consultation submission cites support from SGF that plain packaging is burdensome (Source: Talking Retail, Independent Newsagents fear boost to illicit trade from plain packaging. 16 April 2012)

SGF Cited in BAT’s Submission to Plain Packaging Consultation

In its submission to the 2012 UK Consultation on plain packaging, BAT argued, among other things, that the policy was an example of Burdensome over-regulation.[24] The company argued that retailers had already suffered the significant costs of compliance with point of sale display ban regulations and that plain packaging legislation would require retailers to spend even more on training and security to comply with yet another type of regulation. To support its ‘burdensome’ argument BAT cited a quote from the SGF (see Image 3).

SGF Submitted Evidence to Chantler Review

In November 2013, the UK Government announced that it had commissioned pediatrician Sir Cyril Chantler to review the most recent evidence for plain packaging. In its submission to the Chantler Review, the SGF reiterated many of the tobacco industry arguments against plain packaging, including that the policy would breach intellectual property of the tobacco companies, and increase the threat of illicit tobacco trade.[25]

Like the tobacco companies, the SGF attacked the independent scientific review, commissioned by the Department of Health, which had systematically reviewed 37 studies that provided the evidence base for plain packaging. It also criticised an Australian peer-reviewed study carried out by the Centre for Behavioural Research in Cancer, which showed that after the introduction of plain packaging some smokers had “perceived their tobacco to be of lower quality and less satisfying” and were thinking about quitting.[25]

Opposed Tobacco Display Ban

In 2010, SGF called the Scottish proposed tobacco display ban as “the most inflexible and burdensome approach in the world”, calling it “ineffective”.[26]

Ahead of the Scottish parliamentary elections, in 2011, the SGF attempted to mobilise retailers to put pressure on MSPs to drop the display ban.[27]

TobaccoTactics Resources

Relevant Link


  1. Scottish Grocers’ Federation, About SGF, SGF website, undated, accessed July 2018
  2. Scottish Government, The Scottish Ministerial Working Group on Tobacco Control, last updated 14 September 2017, accessed July 2018
  3. Scottish Grocers Federation. Gold Membership Benefits, SGF website. Screenshot taken on 27 May 2014
  4. 4.0 4.1 Scottish Grocers’ Federation, Corporate Members, SGF website, undated, accessed July 2018
  5. 5.0 5.1 5.2 5.3 Scottish Grocers’ Federation, Standardised packaging of tobacco products. Consultation response from the Scottish Grocers’ Federation, 2012, accessed July 2018
  6. 6.0 6.1 6.2 Scottish Grocers’ Federation, Consultation on the Introduction of Regulations for Standardised Packaging of Tobacco Products, August 2014, accessed July 2018
  7. 7.0 7.1 7.2 7.3 7.4 7.5 J. Lee. Letter to Richard Lyle MSP, subject: Smoking Harm Reduction. 30 April 2018
  8. R. Armour, SNP MSP criticised for taking hospitality from ciggie giant, Third Force News, 21 August 2017, accessed August 2017
  9. Halogen Communications, Illicit Tobacco Trade Endemic in Scotland, Press Release, 21 November 2013, accessed July 2018
  10. Halogen Communications, Clients, 2013, accessed July 2018
  11. Message Matters, Clients: Who they are, Message Matters website, undated, accessed July 2018
  12. Scottish Parliament Lobbying Register, Entry Philip Morris Limited 19/04/2018, accessed July 2018
  13. Scottish Parliament Lobbying Register, Entry Halogen Communications 19/04/2018, accessed July 2018
  14. Scottish Parliament Lobbying Register, Entry Message Matters 19/04/2018, accessed July 2018
  15. Scottish Parliament Lobbying Register, Entry Message Matters 10/05/2018, accessed July 2018
  16. Scottish Parliament Lobbying Register, Entry Message Matters 08/05/2018, accessed July 2018
  17. Message Matters, Fwd: Update on tobacco harm reduction CPD. Email to redacted recipient, dated 28 Jun 2018 00:51
  18. 18.0 18.1 Philip Morris International, UK Corporate Affairs Update, February 2012. Powerpoint leaked to Action on Smoking and Health, 2013
  19. Department of Health Tobacco Programme, Consultation on standardised packaging of tobacco products: Summary report, July 2013, accessed July 2018
  20. HMRC, Measuring tax gaps tables, 2012.
  21. M. Bayly, M. Scollo, M. Wakefield, No lasting effects of plain packaging retrieval time in small Australian retails outlets, Tobacco Control, 2015; 24:e108-e109
  22. O. Carter, M. Welch, B. Mills, et al, Plain packaging for cigarettes improves retail transaction times, BMJ, 2013; 346:f1063
  23. K.A. Evans-Reeves, J.L. Hatchard, A.B. Gilmore, ‘It will harm business and increase illicit trade’: an evaluation of the relevance, quality and transparency of evidence submitted by transnational tobacco companies to the UK consultation on standardised packaging 2012, Tobacco Control, 2015; 24:e168-e177
  24. British American Tobacco, UK standardised packaging consultation: Response of British American Tobacco UK Limited, 8 August 2012
  25. 25.0 25.1 J. Lee, The Independent Review on Standardised Packaging of Tobacco Products, Scottish Grocers’ Federation, January 2014, accessed July 2018
  26. Scottish Grocers’ Federation, Consultation on Tobacco Display and Sale regulations. Scottish Grocers’ Federation (SGF) Submission, 20 July 2010, accessed July 2018
  27. R. Manning, SGF seeks retailer views ahead of election, 12 January 2011,, accessed July 2018