June 11, 2001
Federal Trade Commission
Dear Chairman Muris:
We are writing to express our strong support of the continuation of the Federal Trade Commissions (FTC) reports on the cigarette and smokeless tobacco industries. These reports provide clear and consistent information on cigarette and smokeless tobacco marketing, sales, and promotions in the United States. As a result, they enable organizations that are concerned about these issues to conduct their important work. These include public health, academia, law enforcement, the news media, and federal and state government health agencies, as well as the general public. Due to the limited federal oversight of the tobacco industry in general, these two FTC reports provide vital information that is available to the public and to the federal government.
While the reports are a significant source of information to our organization, they can be improved by successfully expanding the range of information the FTC provides in these important publications. We urge that the following information be added to these reports:
We believe that expanding the scope of the FTC reports will benefit organizations like ours that utilize research to inform the public about important public health issues. Thank you for the opportunity to respond to this Federal Register notice. We look forward to using the reports in the future.
Diana Zuckerman, Ph.D.
Response to Specific Questions Posed By The FTC
1. Who uses the cigarette and smokeless tobacco reports? For what purposes do they use them?
Many types of organizations and individuals use the FTC cigarette and smokeless tobacco reports, such as:
These reports are used to educate and inform policy makers, elected officials, and the general public about how and where the tobacco industry is spending its advertising dollars. This is important information because advertising is very effective at encouraging children and adults to smoke.
2. What are the costs to the industries to provide the FTC with the data included in the cigarette and smokeless tobacco reports?
We do not know the costs, but we believe they are modest compared to the amounts spent on advertising.
3. Should the FTC continue to collect and publish data regarding cigarette and smokeless tobacco sales, advertising and promotion? Why or why not?
Yes. The data collected and published by the FTC regarding cigarette and smokeless tobacco sales, advertising and promotion is critical information that organizations rely upon to educate and inform a variety of audiences. The information contained in the FTC reports represents the only reliable and sustained effort by the federal government to collect and report information from the tobacco industry on its broad range of marketing, sales, and promotional activity. No other federal agency or entity has access to this specific information from the industry. In the absence of meaningful regulation of the tobacco industry by the federal government, it is critical from an accountability perspective to maintain the publication of these reports.
4. What data or other information contained in the reports are useful and should be continued in any future reports? Why? What data or other information in previous reports are of little or no use, and could be omitted in future reports? Why?
All of the data contained in the current FTC reports are essential and should be continued. However, the current reports include information by brand variety whereas it is reported by the FTC in the aggregate without any breakdown into basic subcategories (by state, by brand, by company). It would be more useful if it were more detailed.
5. Is there information about cigarette and smokeless tobacco sales, advertising and promotion that has not been included in the reports, but that would be of use? If so, what additional information would be of use, and why would it be useful?
Tobacco control like tobacco marketing, advertising and promotions is largely a local activity. As a result, getting more detailed information at a state-by-state level, by company, and by brand would be helpful. Also, since two of the FTCs existing reporting categories account for most of the spending by the industry (promotional allowances and retail value-added), it is important to get more details on what the constituent pieces are of these broad categories.
Also, providing access to researchers to the FTC report data in spreadsheet format so that data are searchable and can be plotted and analyzed further would be very helpful. Further, adding graphics to the report would be helpful.
6. If the FTC decides to continue issuing reports, how frequently should they be issued (e.g., annually, and biennially)? Why?
The current report frequency is sufficient. The only issue with respect to timing of the reports is the time lag in the information. For example, the cigarette sales report issued in 2001 was reporting on data for 1999. While the information is helpful, a two-year time lag makes the data less useful than it could be
7. What other information should the FTC consider in deciding whether to continue reporting on the sales and advertising and promotion of cigarettes and smokeless tobacco products? If the FTC decides to issue future reports, what formats would be useful?
We strongly encourage the FTC to continue reporting in a reliable and accurate format. This is virtually the only information available on the marketing, sales, and promotional spending patterns of the cigarette and smokeless tobacco industries collected by the federal government (with the exception of Securities and Exchange Commission filings). The public health community relies on this information.
Finally, improving the reports by formatting the data into spreadsheets, databases, and graphics would make it easier for organizations and agencies to utilize the information.