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30 September 2010 Dr Roscoe Taylor Director of Public Health Tobacco

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30 September 2010 Dr Roscoe Taylor Director of Public Health Tobacco 30 September 2010 Dr Roscoe Taylor Director of Public Health Tobacco Control Public and Environmental Health Services Department of Health and Human Services GPO Box 125 Hobart TAS 7001 By email: [email protected] Re: Woolworths response to Building on our Strengths Discussion Paper Woolworths welcomes the opportunity to provide comments in response to proposed legislative changes to the Public Health Act set out in the Discussion Paper Building our Strengths. As a leading Australian retailer, Woolworths has 73 stores in Tasmania including 29 Woolworths supermarkets, 3 BIG W department stores, 5 Dick Smith Electronics outlets, 20 BWS liquor outlets and 16 Woolworths Petrol sites. Woolworths sells tobacco products in all its stores in Tasmania with the exception of Dick Smith Electronics outlets. Woolworths fully accepts and appreciates the responsibility of selling tobacco products and accepts it is quite unlike selling fresh food and other everyday needs products. Woolworths is therefore committed to working with the Tasmanian Government to ensure that the Government can achieve its tobacco control and overall preventative health policy objectives. Woolworths also acknowledges the ambitious objectives the Tasmanian Government has set out for reduction of smoking in its Tobacco Control Plan as part of the Tasmania Together project. Woolworths’ specific comments relate to Proposal Nine in the Discussion Paper – being the proposal to ban or restrict specialist tobacconists’ displays and/or phase out specialist tobacconists. As the Department would be aware, all Woolworths outlets in Tasmania selling tobacco products will be subject to a complete display ban from 2 February 2011. Woolworths therefore strongly supports Option One being the proposal to extend this total tobacco display ban so that it will also apply to specialist tobacconists. Woolworths does not support Options Two, Three or Four set out in Proposal Nine. From a public policy perspective, Woolworths has considerable concerns about exemptions from display bans being provided to specialist tobacco retailers. Providing an exemption to one class or format of retailer is not competitively neutral from either a sales or cost perspective– retailers who are subject to the forthcoming full display ban whilst others are not face a likely disproportionate impact on their sales. These retailers are also forced to spend significant resources (in terms of both time and money) to engineer and install full display cover solutions at their stores. In addition to these commercial issues, Woolworths is also concerned that providing an ongoing specialist tobacco exemption also undermines the overall policy intent behind the introduction of display restrictions. The policy intent behind in these bans is to decrease the incidence of impulse purchase, take-up by young smokers and to make it easier for currently addicted smokers to quit. Providing a display exemption for specialist retailers runs directly counter to these objectives. This is because, Woolworths understands, a significant proportion of problem or habitual smokers purchase the majority of their tobacco needs from the very specialist tobacco retailers who are can take advantage of the display exemption. Woolworths acknowledges that, to date, the intent of providing display exemptions has been to assist a small number of businesses who derive their income solely or significantly from tobacco products. If, however, this is the case and if the exemption is to be characterised as a genuine transitional measure it is imperative that it be time-limited in nature and be phased out as soon as possible. There are no sound policy reasons for allowing some specialist tobacco retailers or smaller general tobacco retailers to continue to display tobacco products more broadly than all other retailers on any ongoing basis. It is on this basis that Option Two, Three and Four set out in Proposal Nine therefore cannot be supported. Woolworths considers the most appropriate action is for the Public Health Act to be amended to provide that all retailers regardless of size must no longer display tobacco or tobacco products by a specified date with no exemptions. Taking this approach would clearly demonstrate the Tasmanian Government’s commitment to reducing tobacco-related harm in the community in the most effective and efficient way possible. I trust this information contained in this letter is of use. Should you have any questions or would like further information about please do not hesitate to contact me on 02 8885 9133 or at [email protected]. Yours sincerely, Charlie Beasley Public Policy Manager Woolworths Limited 2 .
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