From: Giorgi Kvirikashvili <gkvirikashvili@gov.ge>
Date: May 14, 2017 at 03:35:15 GMT+4
To: Maia Tskitishvili <mtskitishvili@gov.ge>, Dimitri Kumsishvili <DKumsishvili@mof.ge>, "ggakharia@economy.ge" <ggakharia@economy.ge>
Subject: Fwd: Introduction of Standardised ' Plain ' Packaging-- Tobacco Control Law

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-------- Original message --------

From: M RIDGWAY <mike.ridgway48@btinternet.com>

Date: 5/10/17 02:08 (GMT+04:00)

To: Giorgi Kvirikashvili <gkvirikashvili@gov.ge>

Subject: Introduction of Standardised ' Plain ' Packaging-- Tobacco Control Law

For the attention of ......
Mr Giorgi Kvirikashvili  the Prime Minister of Georgia

Dear Sir

I represent packaging manufacturing businesses ( not the tobacco industry )across the European Union and have been involved in putting forward the position of the supplying industries to regulators both within and outside Europe over the last number of 4/5 years.

The proposed introduction of a Brand Ban by the adoption of plain packaging has had a number of serious consequences involving all businesses operating within and supplying the sector.These are advanced manufacturing companies producing a range of products including pouches for Roll-Your-Own tobacco ; Sophisticated tear strips containing security information; Printed filter paper in addition to the well known and well used standard ' flip top' cigarette carton.

The cigarette  pack is a complex product and although disregarded by the consumer after use it is essential because of its complexity that acts as a barrier against the counterfeiter and those involved in the illicit trade of illegal tobacco dealing.Once complexity is eliminated the pack becomes simple and easy to reproduce and countries that have introduced the measure are seeing increases in the illicit trade eg Australia where now 15% of the market ( I cig in 7 ) is supplied via this trade.The trend in the UK is starting to follow this pattern resulting in very large losses of revenue to the Government of some £2.9 billion per annum.....or £8million per day.

The Packaging Industry and the Tobacco Industry have been subjected to a whole range of regulation over recent years as follows.....

2002 -- ban on all tobacco advertising and sponsorship
2007 -- ban on smoking in public places
2008-- introduction of graphic health warnings on cigarette packs
2011 -- ban of tobacco vending machines
2013-- ban on display of cigarettes in large retail shops
2014-- ban on smoking in cars when children are present
2015-- ban on displaying tobacco in all retail outlets including kiosks
2017-- introduction of plain packaging following a 12 month period of stock changeover.

One feature is common to all these regulations.......No studies have been made into these measures?......Who carried out any research ? What was the outcome?
We believe that there should be NO MORE REGULATION until further studies have been made and the conclusions examined.

What is an alternative?

The alternative strategy proposed and which has proved to be effective in Germany is a widespread education programme as organised by the German Federal Centre For Health Education ( Bundeszentrale fur gesundheitliche Aufklarung ( BZgA ) of Berlin who found that cigarette consumption by those aged between 12--17 years saw a reduction of 27.5% and those who never tried to smoke rose from 40.1% to 71.7% over a 12 year periods from 2001 to 2013.

Summary....the packaging industry has no problem with regulation and supports efforts to reduce smoking ...but the regulation must be based upon evidence and effectiveness and not as a result of pressure from NGO's no matter how well intentioned those are who seek to regulate without knowing the consequences.

I would ask you to postpone any introduction of plain packaging into the country of Georgia under the TOBACCO CONTROL LAW REF 07-3/592/8 until firm evidence exists that it works.In addition would be quite  prepared to visit Tbilisi to explain the matter further to your officials about the complexities involved in packaging manufacturing and the role it plays in combatting the illegal and counterfeit trade in tobacco products.

Yours sincerely

Michael Ridgway
Director
Consumer Packaging Manufacturers Alliance Limited
West Yorkshire
United Kingdom







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