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Project SUN: a Study of the Illicit Cigarette Market in the European Union, Norway and Switzerland 2017 Results

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Project SUN: a Study of the Illicit Cigarette Market in the European Union, Norway and Switzerland 2017 Results Project SUN A study of the illicit cigarette market in the European Union, Norway and Switzerland 2017 Results Methodology and Appendices kpmg.com/uk Contents Chapter page Methodology Overview 1 KPMG EU flows model 5 LDS 7 EPS 9 Non-domestic legal analysis 19 Illicit Whites analysis 32 EU tax loss calculation 34 Appendices 1. Limitation of results 36 2. EPS results by country 40 3. Sources 57 4. Scope of work 60 © 2018 KPMG LLP, a UK limited liability partnership, and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative, a Swiss entity. All rights reserved. Methodology Overview KPMG has developed and The methodology has been tested extensively and refined to ensure that it delivers the most robust refined its methodology and justifiable results possible for quantifying counterfeit • Our approach integrated multiple sources and custom-built analytical tools and contraband incidence • In 2017, Project SUN was commissioned by the Royal United Services Institute (RUSI). RUSI across the 28 EU markets contracted this work with funding from British American Tobacco and Philip Morris International since 2006, with Norway and destined for its broader illicit trade work. As part of this, RUSI has also produced an Occasional Switzerland included in the Paper to shed light on some of the main organised crime dynamics accompanying the trends study since 2014 revealed by the KPMG data. In 2016, similarly, RUSI commissioned Project SUN with funding from British American Tobacco, Philip Morris International and Imperial Tobacco Limited destined to support its broader illicit trade research. Prior to this, between 2013-2015, Project SUN was commissioned jointly by the four major tobacco manufacturers (British American Tobacco plc, Imperial Tobacco Limited, JT International SA and Philip Morris International Management SA). KPMG LLP were previously commissioned by Philip Morris International Management SA to produce reports covering 2006 to 2012 (‘Project STAR’). This extension has provided access to previously unavailable data sources including Legal Domestic Sales data and proprietary consumer surveys owned by manufacturers who participated for the first time in 2013. These data sources have been used in the 2013, 2014, 2015 and 2016 reports The methodology is based The KPMG EU Flows Model is a dynamic, iterative model that is based on LDS and EPS results and primarily on objective is used to estimate overall manufactured cigarette volumes evidence from LDS and EPS • The KPMG EU Flows model has been developed by KPMG to specifically measure inflows and results, which are inputted to outflows of cigarettes between EU countries for the purpose of this report. It is an iterative data the bespoke EU Flows Model driven model that uses LDS and EPS results to estimate the volume of non-domestic outflows and inflows to and from each EU Member State, Norway and Switzerland • LDS are the starting point of the methodology, from which outflows of legal sales to other countries are then subtracted to estimate legal domestic consumption • Non-domestic inflows from other countries are then added in to give an estimate for the total consumption within a market • This methodology has been developed by KPMG for the manufactured cigarettes market specifically. For that reason, an assessment of the OTP market (both legal and illicit) is excluded from the scope of this report EPS results provide a robust EPS relies purely on physical evidence, avoiding the variability of consumer bias found in interview- indication of the incidence of based methods non-domestic and counterfeit • The EPSs were conducted by independent market research agencies on a consistent basis across packs and country of origin all the EU markets, Norway and Switzerland, allowing for direct comparison of data and the identification of inflows and outflows between all of the countries analysed • Over 500,000 packs were collected in 2017 as part of this research • Further detail regarding the reliability and validity of EPS, the sampling approach and results by country at a regional level are provided later in this document Tourism & travel trends are Tourism and travel data provided by publicly-available 3rd party sources are used to estimate used to quantify legal non- genuine, legal non-domestic tobacco purchases (including cross-border shopping) in each market domestic cigarette purchases based on inbound visitor inflows • United Nations World Tourism Organisation(1) data is the primary source used to identify travel trends, supplemented with other publicly available data • European Commission releases(2) are used to calculate changes in the weighted average price of a pack of cigarettes between countries. Where flows come into a country from a higher priced country they are assumed to be 100% legal (1) UNWTO (2) EC Excise Duty Tables, January 2018 (Part III – Manufactured Tobacco) © 2018 KPMG LLP, a UK limited liability partnership, and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative, a Swiss entity. All rights reserved. 1 Methodology – Overview There are some specific Given the complexity of measuring C&C, we recognise there are some limitations within the limitations in the Project methodology SUN methodology • There are broadly two types of limitations: scope exclusions and source limitations - scope exclusions include areas which cannot or have not been accounted for in our scope of work and approach, such as geographic, brand (non-participating manufacturer counterfeit), category exclusions (OTP) and legal domestic product flows out of the EU - source limitations include the availability of information and the potential errors inherent with any data sources such as sampling criteria, coverage issues and seasonality factors To help improve the accuracy Comparison of results from alternative sources identified a few markets where country-to-country of results, some minor flows required minor adjustment refinements were necessary • In nearly all instances, overall country results and flows from the KPMG EU Flows Model at a country level appeared reasonable, however, in a limited number of instances, specific adjustments were made to country-to-country flows where additional data provided by manufacturers allowed orf further refinement of the analysis Project SUN uses LDS, EPS results and other consumer research to estimate the volume of C&C cigarettes consumed in the EU Based on consumer survey results regarding cross-border purchases DOMESTIC CONSUMPTION * Non-domestic Non- (legal) *Outflows domestic Counterfeit and contraband Obtained by subtracting legal cross-border purchases from the total non-domestic volume Legal Domestic Legal Domestic Sales Consumption te consumption (cigarettes) Cigaret Based* on EPS results The Project SUN methodology was developed by KPMG. It has been deployed on a consistent basis since 2006, enabling comparisons to be made between counterfeit and contraband volumes from year to year. © 2018 KPMG LLP, a UK limited liability partnership, and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative, a Swiss entity. All rights 2 reserved. Methodology – Overview Counterfeit and contraband is allocated into three constituent parts: Counterfeit, Illicit Whites and Other C&C Counterfeit packets are identified by those manufacturers participating in the given wave of EPS research. Each manufacturer analyses their own packaging for packs collected and marks Counterfeit whether or not the pack is counterfeit Illicit Whites are defined as cigarettes which are usually manufactured legally in one country or market but which the evidence suggests have Counterfeit been smuggled across borders during their transit and to the destination market where they have limited Illicit or no legal distribution and are sold without contraband Whites the payment of tax. KPMG has an approach to determining Illicit Whites brand flows using specific criteria described on page number 32 ‘Other C&C’ comprises contraband which does not fall within the Illicit Whites definition. It is often Duty Paid product from both EU and non-EU Other C&C countries. There may also be counterfeit of brands that are not trademark-owned by participant manufacturers(a) Understanding the differences between OLAF seizure data and Project SUN results Over 50% of product identified within the SUN report is defined as ‘other C&C’. wHo ever, when compared to OLAF seizures data, ‘Other C&C’ accounts for 2%-3% of total seizures volumes(1) There are several possible explanations for the different findings: • Illicit Whites brand flows and counterfeit cigarettes tend to be transported in large volumes - Illicit Whites brand flows are not subject to the same high level of supply chain controls as those of genuine international brands. This means that product can be legally manufactured in one country, mainly outside of the EU, imported and distributed illegally in bulk within another country. This results in high volume seizures - Counterfeit cigarettes are usually seized within transport containers or are identified during law enforcement raids on the factories in which the product is manufactured. This often results in large volumes of counterfeit cigarettes being seized • The remaining ‘other C&C’ is generally only available through legitimate Point of Sale locations as a Duty Paid product in a country. This means it is generally not transported
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