Wed, May 16, 2001 11:37 AM
Subject: tobacco advertising and marketing reports
Dear Mr. Berman,
You asked for comment on whether the FTC should continue to issue reports on the domestic sales and advertising and promotion expenditures for cigarettes and smokeless tobacco products. I am writing to encourage the FTC to continue with these reports.
In response to the questions you ask in the request for public comment: I am a tobacco control and cancer prevention researcher. I use the reports as part of my work looking at how the tobacco industry differentially targets individuals and communities of lower socioeconomic status. It is important for public health researchers, and consumers at large, to know how much money the industry is spending to market their product. I believe that the Commission should continue to collect and publish this data as it provides critical insight into the industry's practices. It is through this information that we are able to understand their practices, evaluate the truth in statements the industry makes about their marketing and promotion practices, and are able to make recommendations for actions by public health and at a policy level.
I believe it would be useful to know how much the industry spends, on what types of promotions, a geographic breakdown of spending, a seasonal breakdown of spending, and also to know how much money the industry pays to retail establishment operators for product and advertisement placement (part of their point-of-purchase advertisement spending). I think reports are needed on an annual basis at the bare minimum. Advertising and promotion practices change rapidly so up-to-date information is key to making policy recommendations. Finally, having the data available electronically would be very useful to allow for analysis of trends over time. I hope these comments are useful in your decision making process. Again, I encourage the FTC to continue to issue the cigarette and smokeless tobacco reports.