In November 2013, the Government of Ireland produced a General Scheme on Plain Packaging – a referral document that is feeding into a consultation process on the issue. The Committee plan to hold public hearings on the Bill beginning 23 January. They will have eight sessions covering all aspects of the Bill – retailers, health professionals, tax and revenue, Health NGOs, lawyers specialising in IP and (despite protestation and highlighting of FCTC) the tobacco industry. EPHA contributed to the public consultation and issued an open letter supporting the General Scheme on Plain Packaging in Ireland.

Dear Mr Buttimer,

I am writing to you in response to the consultation on the draft Public Health Bill which intends to introduce standardised packaging in Ireland. On behalf of the European Public Health Alliance (EPHA), I would like to take this opportunity to congratulate Ireland for its willingness to take a bold step forward in the fight of the tobacco epidemic.

Like many European countries, Ireland is greatly affected by the deadly burden of tobacco consumption. Lung cancer is one of the most common cancers in Ireland and is a contributory risk factor in a number of other cancers (e.g. mouth, head and neck, stomach, pancreatic etc.). Approximately 1,500 people develop lung cancer each year and 90% of these cases are directly caused by smoking. [1] Lung cancer death has overtaken that of breast cancer in Poland, the UK and Ireland [2]. Smoking contributes to heart diseases and stroke: approximately 10,000 people die each year from cardiovascular disease (CVD) and each year, approximately 10,000 Irish people have a stroke and around 2,000 die. An estimated 30,000 people are living in the community with disabilities as a result of a stroke [3] . Smoking is also the main risk factor of Chronic Obstructive Pulmonary Disease (COPD), a common lung disease that obstructs the airways, making breathing difficult. COPD affects more than 440,000 people in Ireland. [4]

Based on the latest evidence available on tobacco packages as well as the WHO Framework Convention on Tobacco Control guidelines [5] , the European public health community strongly recommends the introduction of plain standardised packaging. Increasing the size of warning messages enhances the effectiveness of the warning amongst both young and adult smokers and non-smokers. A systematic review of the evidence shows that health warnings on tobacco packs are effective in discouraging young people from taking up smoking and in motivating smokers to think about quitting. In 2010, Uruguay implemented health warnings covering 80% of both front and back of tobacco packages. Since then, cigarette consumption decreased by an average 4.3% per year, while in its neighbouring country, Argentina, it decreased by 0.6%. Similarly, the prevalence of tobacco use in Uruguay has decreased by 3.3% a year; more than twice as much as Argentina [6]. Other countries like Canada [7] and Australia [8] with comprehensive tobacco control strategies in place including large pictorial health warnings have seen significant annual decreases in youth smoking [9] . On the contrary, Europe's youth has the highest smoking rates in the world, with higher rates among lower socio-economic groups and rising rates in the young female population. [10]

Ireland would be the first country in Europe to introduce plain packaging. This form of leadership in Europe is crucial in light of the ongoing revision of European legislation aiming at strengthening the European tobacco control policy. [11] As you know, the draft text of article 24 of the draft Tobacco Products Directive recognises the right of a Member States to maintain and introduce further requirements applicable to all products placed on its market in relation to standardisation of packaging of tobacco products, where it is justified on grounds of public health, taking into account the high level of protection achieved through this Directive. [12]

The flagship role of Ireland as regards introducing standardised packaging is essential to protect young people and future generations from addiction to tobacco products, reducing the take-up of smoking among children and encouraging current smokers to quit.

I can assure you that the European public health community is fully supportive of the standardised packaging proposal and attaches great importance to the timely adoption of that important law. We will be following the public hearings on the Bill beginning 23 January with great attention.
Yours sincerely,

Peggy Maguire

EPHA President

[EPHA Open letter] EPHA contribution to the consultation on the Public Health Bill - Support from the European Public Health Community to the General Scheme on Plain Packaging in Ireland

General Scheme of the Working Title Public Health (Standardised Packaging of Tobacco) Bill 2013

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[1] Irish Cancer Society - http://www.cancer.ie/reduce-your-ri...

[2] European Commission, DG Health & Consumers. 2009. Data and information on women's health in the European Union. http://ec.europa.eu/health/populati...

[3] Irish Heart Foundation - http://www.irishheart.ie/iopen24/fa...

[4] Irish Thoracic Society - http://www.livingwithcopd.ie/

[5] Parties should consider adopting plain packaging requirements to eliminate the effects of advertising and promotion on packaging”. (GL Article 13)

[6] Tobacco control campaign in Uruguay: a population-based trend analysis, Abascal W et al., Lancet 2012 Nov, 380(9853):1575-82

[7] Health Canada. Canadian Tobacco Use Monitoring Survey (CTUMS) 2011. http://www.hc-sc.gc.ca/hc-ps/tobac-... Accessed 3 March 2013.

[8] White, V. Bariola, E. Australian secondary school students' use of tobacco, alcohol, and over-the counter and illicit substances in 2011. Report prepared for: Drug Strategy Branch Australian Government Department of Health and Ageing. December 2012. http://www.nationaldrugstrategy.gov... Accessed 15 March 2013

[9] Smoke Free Partnership Mythbusting Briefing - http://www.smokefreepartnership.eu/...

[10] Kaiser S, Gommer AM. 2007. Smoking Summary. EUPHIX.http://www.euphix.org/object_docume...

[11] Tobacco Products Directive http://ec.europa.eu/health/tobacco/...

[12] Council approves compromise on tobacco directive. http://www.consilium.europa.eu/uedo...

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