Association of Convenience Stores
This page was last edited on at
The Association of Convenience Stores (ACS) is an organisation representing local shops in the United Kingdom (UK).1
In its own words:
“ACS’ core purpose is to lobby Government on the issues that make a difference to local shops. We represent the interests of retailers on a range of issues, including business rates, energy, regulation, planning, alcohol and many more.”1
Relationship with the Tobacco Industry
Tobacco Companies are ACS Members
British American Tobacco (BAT), Imperial Brands, Japan Tobacco International (JTI) and Philip Morris International (PMI) are “Premier Club” members of the ACS.2
Premier Club membership provides “unrivalled and invaluable access to senior decision makers across the UK convenience industry through market-leading digital and physical events focused on the future of the industry.”2
In a February 2014 letter to the UK Department of Health, ACS CEO James Lowman declared that the tobacco companies each paid GB£24,250 for ACS premier club membership that year.3
Japan Tobacco International Sponsored ACS Events
In addition to membership fees, Lowman’s letter revealed that JTI spent at least GB£10,000 on sponsoring the annual ACS Forecourt Seminar event, and had also sponsored the 2013 ACS Annual Conference.345 plain packaging6, an increase in cigarette excise,78 and measures imposed in the 2001 and 2014 European Union Tobacco Products Directive.910
Opposed to tightening rules on advertising vaping products
In September 2022 the Scottish Government published the results of its consultation on tightening rules on advertising and promoting vaping products. The ACS raised several objections, including the potential impact on retailers’ ability to promote products and services with leaflets, flyers and advertising hoardings, as well as potential difficulties for retailers with video display contracts.11
Opposed to making England Smokefree by 2030
In June 2022 the Office for Health Improvement and Disparities (OHID) published the Khan review into whether the government’s tobacco control policies would allow it to achieve its ambition of making England smokefree by 2030.12
Javed Khan, the author of the review, did not meet face-to-face with the tobacco industry as part of the consultation. However, he did meet with the ACS. At the meeting, the ACS stated that retailers could adapt to declining tobacco sales, but that they would need time to implement changes.13 Following publication of the Khan Review, there was a further meeting with the ACS, in which the organisation expressed concerns about Khan’s proposal to incrementally raise the age of sale of tobacco products, suggesting that such a measure would expose retailers to a risk of violence and abuse from members of the public.14 For details see Tobacco Industry Interference with Endgame Policies.
Below are details of ACS opposition against the introduction of plain packaging in the UK
Opposed UK Plain Packaging
Image 1. ACS Plain Packaging Operational Implications, accessed July 202415
In April 2012 the UK Department of Health launched a consultation on the plain packaging of tobacco products. In a press release, ACS CEO Lowman said: “We welcome the opportunity of this consultation to set out the reasons why plain packs will be a major burden to local shops across the UK.”16
In August the ACS submitted a response to the consultation.6 The submission argued that plain packaging would have a negative operational impact on retailers, that it would lengthen service times, would lead to a loss of retail margin, and had the potential to drive consumers away from the legitimate tobacco market into the illicit market (see image 1).15
Its arguments echoed tobacco industry arguments against plain packaging.
The ACS made no fewer than nine recommendations to the UK Government and the Department of Health, stating that they should:
1. adhere to the principles of better regulation when deciding on regulation so that unnecessary burden is not placed upon businesses
2. wait for an evaluation of plain packaging in Australia, the first country in the world to introduce this legislation
3. conduct a “detailed and reliable analysis of smokers’ response” to plain packaging
4. conduct a “consumer study on the likely impact of this policy on counterfeit tobacco products and cross-border sales”
5. give careful consideration to the impact plain packaging could have on making illicit trade more attractive, especially to young people and those in deprived communities;
6. allow time to assess the efficacy of recently introduced tobacco control interventions before introducing further burdens on business
7. conduct a full study of the efficacy of all existing tobacco control measures before introducing others
8. publish findings of on-going research in a timely manner to allow further consultation with stakeholders
9. commission research into the business impact of plain packaging
British American Tobacco quotes ACS in its Submission
BAT’s submission to the 2012 consultation cited ACS’ concerns, but did not disclose that the tobacco company paid membership fees to the ACS.
On page 51 of BAT’s submission, the company quoted the ACS:
“We also fear that consumers that are used to buying certain brands will react against plain packs and seek them out from the illegal trade. The result would be more consumers placed at the mercy of unscrupulous criminals that run the black market and further loss of trade for legitimate retailers.”17
PMI identified the ACS as an ‘Influencer’
PMI documents leaked in mid-2013 revealed that the tobacco company had planned a multi-faceted campaign to oppose the UK government’s plans to introduce plain packaging.1819
In the leaked presentations, PMI identified all those whom it considered to be major players in the UK legislative decision-making process.
PMI named “key committees” such as the Cabinet Office Behavioural Insight Unit, the Regulatory Policy Committee and the Government’s Department for Business Innovation & Skills (BIS) Reducing Regulation Committee (p15) which, among other things, strives to reduce the burden of regulation in accordance with the principles of Better Regulation.
PMI also detailed a model centred around UK Prime Minister David Cameron, the “decision maker” (see Image 2). Cameron, depicted at the epicentre, is surrounded by nine “formal/informal advisors” who in turn were surrounded by a large number of “influencers” including MPs, Lords, government departments and a series of non-governmental organisations, charities and lobby groups. Included amongst the lobby groups identified by PMI as influencers was the ACS.
For more information, see pages on PMI’s Anti-Plain Packaging Lobbying Campaign and PMI’s Anti-PP Media Campaign.
ACS Vocal Against Plain Packaging in Second UK Consultation
On 26 June 2014 the UK Government published its second consultation on plain packaging.
Later that day, Lowman (CEO of ACS) stated “Ministers have consistently failed to accept the evidence about how disruptive and burdensome recent tobacco control measures have been for the tens of thousands of retailers that have to actually implement them”.20
This serves as another example of the ACS representing themselves as an independent organisation communicating on behalf of the UK’s retailers without disclosing their links to the tobacco industry.
Affiliations
The ACS provided the Secretariat for the All Party Parliamentary Small Shops Group (now defunct).212223
TobaccoTactics Resources
- Third Party Techniques
- Plain Packaging in the UK
- Industry Arguments Against Plain Packaging
- EU Tobacco Products Directive Revision
- All Party Parliamentary Small Shops Group