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Tobacco and a public consultation: NGOs versus NGOs

England Expects has written a blog post titled “Citizens versus NGOs“, quoting the summary of reponses of government agencies, NGOs and individual contributions from the recently published “Report on the public consultation on the possible revision of the Tobacco Products Directive (2001/37/EC)“.

With the majority of individual contributions (~82,000 in total) being against more restrictive measures against smoking and health NGOs being in favour, the conclusion of the blog post is:

Here we see it writ large. Those with cash and power want increasing control, those without it don’t. Those with cash and power want action before evidence, those without want to see evidence before action. Those with power and cash want legislation restrictions and bans, those without complain that there are too many controls already.

What is ignored on England Expects, on purpose I suppose, is the following details from the report:

The public consultation drew a wide response from citizens: 82 117 responses in total. While it is encouraging to see a great number of responses, it should also be noted that this volume appears to be a result, to a large extent, of several citizen mobilisation campaigns that took place in some Member States. One such campaign was organised by a group representing over 75% of Italian Tobacconists. This action was followed by submissions of personal signatures by over 30 000 tobacconists across Italy


Almost 2/3 of the contributions were from just two Member States: Italy and Poland.


When searching for duplicates and ‘form’ responses, 46 792 files could be identified8; about 57 % of all citizen responses.

In other words, while the majority of individual contributions was against more control, the majority of individual contributions were copy-pasted contributions initiated by pro-smoking NGOs, mainly in two member states. What we have seen is thus a fight “NGOs versus NGOs” with different methods, not a fight “citizens vs NGOs”.

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