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Institute for Social Marketing TGP96 Tobacco and Primary Medical Services (Scotland) Bill Institute for Social Marketing We appreciate the opportunity to contribute to this consultation. One of the primary purposes of the Bill is to control the display of tobacco products in order to reduce the attractiveness of cigarettes, which will be the exclusive focus of our submission. We demonstrate the need for the removal of point-of- sale (POS) tobacco displays via summation of the business literature, recent UK research and tobacco industry documents. Business case: Why a ban on tobacco displays will be good for small shops There has been a lot of misleading debate about the business impact of removing POS display. In reality, far from harming small shops, this legislation will help them move their businesses in a progressive and forward looking direction. Small shops succeed because they provide good, personalised service that meets the needs of their customers and local communities. Customers are important for obvious reasons, and getting plenty of them into the shop - increasing ‘footfall’ - is a key concern. Community support is equally important, however, because small shops draw most (60%) of their custom from people living within 440 yards of the outlet (Convenience Store, 2007). In deference to this local focus the Association of Convenience Stores has for years run a major promotional campaign to find stores that are ‘Community Heroes’, arguing that “more and more retailers are recognising the importance of being at the heart of their community” (ACS, 2009). The massive tobacco gantries that currently dominate many small shops, far from helping small shopkeepers meet these key objectives, actually hinder them. As far as footfall is concerned, POS displays cannot help because they only become visible once the customer is in the shop: a signpost is useless if you only see it once you reach your destination. Second, even in the shop a tobacco display serves little purpose because we know that less than 7% of smokers make their purchase decision in store (Cancer Research UK, 2008). Indeed a good local shopkeeper knows this, and their customers’ preferences, so well that they will have their usual brand out and ready for them by the time they reach the counter. This local knowledge and personal service is one of their key competitive advantages: here they can challenge the supermarkets. Large gantries also waste a good business opportunity because the margins on tobacco are relatively low when compared to other products. Smokers matter to small shops, therefore, not so much for their tobacco buying, as for their impulsive secondary purchases, such as the chocolate bars, batteries and newspapers, that are bought alongside the cigarettes. It therefore makes much better business sense to devote the premium sales space currently given over to tobacco (which, remember, the smoker decided to buy before they even came into the shop) to displaying these discretionary products. TGP96 Tobacco gantries also damage the shopkeepers’ drive to be at the heart of their community. The only tobacco purchases that displays are likely to promote will come from would-be quitters who fall off the wagon when confronted with an evocative array of their favourite drug; or from children tempted to chance their arm given the proximity of such a helpful visual aid. So they undermine good intentions and harm children. Small shopkeepers will do their reputations enormous harm if they become the cheer leaders for such unscrupulous marketing. Finally, any successful business has to look forward, to plan strategically for future opportunities and importantly not to cling on to outmoded needs and markets. The reality is that Britain is moving away from tobacco; a British Medical Association report predicts that the habit will vanish altogether in a generation (Hastings & Angus, 2008) and business has christened it a ‘sunset industry’ (Tsang, 1998). This is also recognised within the trade press, with reference to the fact that “we are investing heavily in non-tobacco areas, as frankly that is where the future is” (Convenience Store, 2008). Far from opposing this legislation, therefore, small shops should welcome it. It will increase their competitive advantage over the supermarkets, at a time when the market dominance of superstores threatens the very existence of independent retailers (Jones et al. 2005; Association of Convenience Stores, 2005) in not only Western but also Central and Eastern Europe as well (Juhasz & Stauder, 2005; Vranesevic et al. 2006; Parker et al. 2007). It also enhances their business efficiency and openly supporting it will reinforce their community credentials. Public Health case: UK research highlights the problem of POS tobacco displays Recent cross-sectional and qualitative UK research helps demonstrate young peoples’ awareness of, and attraction to, POS marketing, including display. The Youth Tobacco Policy Survey (YTPS) examines adolescents’ awareness of tobacco marketing (including at POS) from 1999 to 2006; prior to and following the implementation of the Tobacco Advertising and Promotion Act (TAPA). In 2008, the YTPS examines adolescents’ awareness of POS displays in shops and their views on moving cigarettes out of sight. Data comes from the first five waves of the YTPS (1999, 2002, 2004, 2006, 2008); employing a total of 5880 adolescents with a mean age of 13. The impact of tobacco marketing at POS is examined in relation to the changes, from 2002 to 2006 (pre-ban to post-ban), in awareness of tobacco marketing, relative salience of POS marketing and brands associated with POS. Changes over time are also examined in relation to brand awareness. In addition, the association between never smokers’ susceptibility to smoke and their awareness of tobacco marketing and cigarette brands is examined. At Wave 1 (1999) young people had high familiarity with tobacco marketing; with most aware of large posters/billboards (79%), signs/posters in shops or on shop fronts (73%), adverts in the press (52%) and free gifts associated TGP96 with cigarettes (56%) (Moodie et al. 2008). Awareness of most forms of marketing declined between 1999 and 2006. With the TAPA fully implemented in 2006, POS adverts in store or on shop fronts became the most salient form of tobacco marketing, with almost half (46%) of the sample aware of this (Hastings et al. 2008). Unprompted recall of cigarette brands decreased from Waves 1 to 4, from 3.09, 2.64, 2.42 to 2.24. Unprompted awareness of most brands decreased between Waves 2 and 4, with the exceptions being Silk Cut, which maintained its awareness, and Richmond and Mayfair, where awareness increased – all brands heavily marketed at POS (Hastings et al. 2008). Brand recognition of each brand also decreased between 2002 and 2006, although high levels of recognition were still evident in 2006 for Lambert & Butler (78%), Benson & Hedges (66%) and Marlboro (65%) – again brands often centrally positioned in the gantry. From 1999 to 2006, never smokers susceptibility increased with greater brand awareness (OR=1.09, p<0.01) and greater awareness of tobacco marketing (OR=1.07, P<0.01). In the 2006 survey, never smokers’ awareness of cigarette brands was positively associated with awareness of tobacco marketing at POS. Regression analysis, controlling for parental, sibling and peer smoking, gender, age and social grade, found that awareness of tobacco marketing at POS (t=2.294, P<0.05) and awareness of new pack design / size (t=3.312, P<0.01) were both positively associated with cigarette brand awareness (F9,673=23.3, P<0.001) (Hastings et al. 2008). In the 2008 survey young people were asked (i) whether they had seen cigarettes displayed in shops in the last month (ii) how often they pay close attention to cigarette packets displayed in shops (never, rarely, sometimes, often or very often) and (iii) whether they agree or disagree that cigarettes should be put out of sight in shops (agree a lot, agree a little, neither agree nor disagree, disagree a little, disagree a lot). Findings revealed high awareness of cigarettes displayed in shops, with 82% of participants having seen cigarettes displayed in shops in the previous month; irrespective of age, gender or smoking status. Almost a third (32%) of regular smokers pay close attention to cigarette packets displayed in shops compared with 4% of never smokers. Almost two-thirds (64%) of 11-16 year olds agreed (a lot or a little) that cigarettes should be put out of sight in shops; mostly never smokers (72%). The YTPS demonstrates that high awareness of POS and the brands most prominently displayed at POS remains, which normalises tobacco products among young people and undermines the TAPA (Brown & Moodie, in press), which has otherwise successfully reduced awareness of various other forms of marketing (Moodie et al. 2008). The YTPS also reveals that the vast majority of young people favour the removal of tobacco displays, and separate qualitative research helps to reveal why. Twelve focus groups, half comprising smokers (N=32) and half non-smokers (N=35), were conducted with adolescents (11-16 years) recruited from Glasgow and Lothian in 2008; each focus group segmented by age, gender and smoking status (Brown & Moodie, submitted). Young people were asked to discuss their views on anti-smoking ads, smokefree legislation, access to tobacco, health warnings and POS TGP96 tobacco displays. Young people commented that POS tobacco displays were ‘obvious’ within shops due to the ‘massive display’, and such displays appeared to be attractive to both male and female smokers, being described as ‘cool’ and likely to encourage smoking or stimulate purchase. Even non- smokers could see the appeal of cigarette displays, stating that ‘things like this attracts people to smoke’; which helps explain why so many youngsters in the YTPS favour their removal. See below for a sample of comments relating specifically to POS tobacco displays: ‘It’s obvious in shops’ (Male 15, C2DE, Smoker) ‘Cigarette displays in shops makes you think that it’s cool to smoke’ (Female, 13, C2DE, Smoker) ‘Say you enter into the shop you see this massive display over the counter.
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