UICC Tobacco Control Fact Sheet No. 14

Freedom Issues, Advertising and Tobacco

"If either a public officer or any one else saw a person attempting to cross a bridge which has been ascertained to be unsafe, and there was no time to warn him of his danger, they might seize him and turn him back, without any real infringement of his liberty, for liberty consists in doing what one desires, and he does not desire to fall into the river."
J. S. Mill, On Liberty

Freedom is:

  1. a word that enshrines a basic human value;
  2. a cigarette brand name;
  3. an emotive word used by the tobacco industry to oppose any form of regulation, and
  4. a word used to rally tobacco industry support.

    Article 19 of the International Covenant on Civil and Political Rights (ICCPR) states, in part:
  5. Everyone shall have the right to freedom of expression; this right shall include the freedom to seek, receive and impart information...
  6. The exercise of the rights provided for in paragraph 2 of this article carries with it special duties and responsibilities. It may therefore be subject to certain restrictions, but these shall only be such as are provided by law and are necessary…for the protection of national security or of public order (ordre public), or of public health or morals.

Freedom of expression is not an absolute right in any society. It is conditional upon national legislation and international human rights treaties. Freedom of expression must be interpreted in the light of com-peting and co-existing human rights.

The freedoms outlined in the ICCPR are important. They apply to human beings, not commercial organizations.

In the context of tobacco, commercial freedom is related (almost exclusively) to the economic interests of the tobacco companies, and supporting agencies or industry, including media, manufacturing, and production. Commercial organizations do not have an international right to freedom of expression under the ICCPR.

The rationale for limiting commercial freedom, by restricting or prohibiting the advertising and promotion of tobacco products, is clear and overwhelming:

Individuals have a right to be protected from known or unwarranted promotions that will negatively impact their health.* [* Article 12 of the International Convention on Economic, Social and Cultural Rights (ICESCR).]Governments also have a responsibility to ensure the best possible health outcomes both for individuals and communities. This requires that all governments act co-operatively with health, consumer, civil rights, and other organizations to reduce the effects of tobacco on the health of people.

The freedom of the smoker to use tobacco is rarely the subject of claim. Most smokers are rarely zealous to defend their right to smoke publicly, in view of the wealth of scientific information showing harm to others from environmental tobacco smoke. Claims for "smokers' freedom" are those of the tobacco industry advocating what they maintain are "smokers' rights". Civil liberties organizations have generally recognized that an individual's liberty should only be curtailed when it impinges on the liberties of others, a liberty that is lost when a non-smoker is exposed to any environmental tobacco smoke.

The legitimate smoker's interest is outlined by a former US Federal Trade Commissioner:

"There's a recognizable smoker's freedom at stake in this debate: a genuine, recognizable freedom: the freedom of consenting, mature adults, spared the psychological manipulation of...[advertising agencies] during adolescence, fully informed by a free and responsive media, to chose to smoke in the privacy of their homes. That's a freedom worthy of some respect. The rest is grotesque propaganda." (1)

Conflicting interests

The four leading concerns in tobacco control policy are:

* The public interest in improving public health by reducing smoking;
* The interest of governments and authorities in reducing the negative effects of tobacco products;
* The commercial interest of the tobacco industry, manufacture, and trade; and
* The financial interests of the states and governments in taxes on production, distribution, and consumption.
* A fifth interest, proposed by the industry, is the smokers' desired benefit from freedom to smoke according to their wishes.

The legitimate question is: how should society balance these competing interests? In reviewing the Finnish government's efforts to restrict advertising, Häyry states:

"With regard to adult smokers...we contend that the infringements of their individual liberty are too small to deserve serious justification at all. Or, from another angle, perhaps the protection of the young is a serious enough reason to override any inconvenience caused by it to their parents and other adults. On the other hand, as regards manufacturers and dealers, by distributing tobacco products and information about them in a way that encourages smoking among minors, they are inflicting harm on those of the young who start or continue smoking because of their commercial efforts. Harm to others is, in this case, ground for justifiable coercion". (2)

It is, therefore, the valid prerogative of governments to restrict opportunities for smoking, to ban promotion of tobacco in all forms, and to ensure adequate regulation, including prohibition of advertising.

Protecting the rights of children

Children are of particular importance. The 1959 United Nations Declaration on the Rights of the Child and the 1989 Convention on the Rights of the Child outline clear global concerns for the health and well-being of children. They have the right to grow up in an atmosphere which is most conducive to health. Governments have a responsibility to implement such policy.

The Royal College of Physicians (RCP, UK) has helped define the legal rights of the child. According to the RCP, these include the right to:

* be free from the effects of tobacco when in their mother's womb;
* be brought up in a home that is smoke-free;
* expect that doctors, teachers and all those caring for them will set a good example by not smoking;
* be taught about the impact of smoking on health and well-being;
* be taught how to recognize and resist pressures to smoke;
* not be sold cigarettes and other tobacco products;
* be helped to remain non-smokers by the high cost of cigarettes;
* be free from any form of tobacco advertising and promotion;
* live in a community where non-smoking is the normal way of life for all age groups; and
expect that public policy will reflect these rights. (3)

Eliminating the bias and glamour of tobacco advertising can enhance the ability of children and young people to make intelligent and informed decisions.

"... a ban on advertising [is] an enhancement, not a diminution of autonomy. By eliminating existing powerful and pervasive commercial messages encouraging smoking, individuals will be able to make choices about smoking based on more relev-ant and accurate information. Our assumption is that this will lead to a deep and sustained reduction in smoking over time, resulting in significant benefit to health...". (4)

Freedom of information and misleading conduct

Tobacco companies are very selective in their use of information, providing only that which will least restrict promotion and sale, (e.g. an often quoted report is a tobacco-funded advertising study by Boddewyn, without acknowledging its invalidities. (5)

An internal document providing information for the international industry stated:

"Key lobbying actions need to be undertaken...[that] discredit the often imported activists of the coalition-ideally through third parties". (6)

Other secret documents of the tobacco companies recently revealed a knowledge of the effects of their products 30 years in advance of the medical and scientific community.

"...the documents show that B & W (Brown and Williamson) and BAT (British American Tobacco) recognized more than 30 years ago that nicotine is addictive and that tobacco smoke is «biologically active» (i.e. carcinogenic)". (7)

A 1963 memo from B & W's then Vice President and General Counsel, Addison Yeaman, states it bluntly:

"Moreover, nicotine is addictive. We are, then, in the business of selling nicotine, an addictive drug effective in the release of stress mechanisms". (8)

The tobacco industry has sought to silence many who have previously worked for major international companies and who have questioned the companies' action and public statements. Far from experiencing freedom of speech, former employees have been pressured by industry to suppress their evidence and views on the knowledge and behaviour of their former employers.

Other instances of censorship by tobacco companies include pressures on famous athletes to prevent them from promoting non-smoking messages.

Commercial advertising and free speech

Tobacco and advertising industry statements:

"The industry will continue to lobby and fight against advertising bans because commercial free speech is essential for a market traditionally highly competitive."

"Advertising is an essential part of any real democracy which is always based on freedom of choice. Democracy recognizes and respects the ability of each individual person to assimilate information and to make well-informed choices. Advertising is also the voice of free enterprise. It is therefore anathema to zealous regulators everywhere, and to all who believe that society needs to be planned in a top-down way."

"...the action [Morling judgment on deceptive tobacco advertising] demonstrated a clear threat to freedom of commercial expression... The World Federation of Advertisers and the International Advertising Association have resolved to promote and defend advertising and commercial freedom of expression."

Freedom to advertise has been one of the issues most vigorously defended by the tobacco industry. Newspaper, television and other media advertising has focused on the importance of tobacco advertising being inseparable from the principle of "free speech". Opposition to a ban lies in the legality of the tobacco product. Once governments start to control communication, the tobacco industry claims, individuals are likely to lose personal and political freedoms.

Support of this claim has sometimes arisen from fear of commercial loss by the advertising and media industry. Experience from countries where advertising has been banned has shown revenue loss to be minimal. Some of the most democratic societies where freedoms are prized, are those who now have the most stringent legislation on tobacco advertising.

Governments have a responsibility to ensure the maintenance of free speech for individuals, but are also obliged by national and international law to regulate and ban the sale of hazardous products. The marketing of goods has to be balanced in an increasingly consumer conscious society with regulation to protect individuals from the hazards of a free market.

The tobacco industry often seeks alliances with civil libertarians, the media and advertising industry to argue that a tobacco advertising ban would violate the constitutional right to free expression. However, international law specifically includes public health as a ground for limiting freedom of expression.

"Given what the cigarette industry does portray, what it fails to say, and the vast public ignorance of the dangers and addictive quality of smoking, particularly among young persons, it is plain to us that this kind of advertising can be described as deceptive and misleading". (9)

The tobacco industry has been found to be deceptive and misleading in their advertising practices. (10) A ban on tobacco advertising enhances the ability to make healthy decisions as individuals and within populations.

The choices for governments

Governments have a responsibility to maintain the rights to clean air, free from environmental tobacco smoke, for all citizens.

Governments should tax cigarettes and tobacco products heavily to minimize use and to provide dedicated funds for public health initiatives. Politicians and political parties must resist
tobacco company pressures, especially the often duplicitous and covert contributions that buy resistance to legislative change.

Legislation should be enacted which protects children from exposure to advertising.

Individuals should be free to smoke in private where it is consented by other adults while ensuring that there is no involuntary exposure of other individuals.

Acknowledgement

This fact sheet has been prepared for the UICC by Dr. Harley Stanton, Australia. The text has been reviewed by Dr. Eric LeGresley, Legal Counsel, Non-Smokers' Rights Association, Canada.

References

Pertschuk, M., "Strategy and Tactics". Conference on Smoking and Reproductive Health, San Francisco, CA, 14 October, 1985.

Häyry, H., Häyry, M. , Karjalainen, S., "Paternalism and Finnish Anti-Smoking Policy", Soc Sci Med 1989; 28: 293-297.

Royal College of Physicians of London, "Children's Right to Freedom form Tobacco", A Charter.1994.

Gostin, L.O., Brandt, A.M., "Criteria for Evaluating a Ban on the Advertisement of Cigarettes: Balancing Public Health Benefits with Constitutional Burdens", JAMA, 1993; 269: 904-909.

Boddewyn , J. J., "Cigarette Advertising: Where should Articles on the Link Between Tobacco Advertising and Consumption be Published?", J of Advertising, 1993; 22: 105-109. Pollay, R. W., "Pertinent Reserach and Impertinent Opinions: Our Contributions to the Cigarette Advertising Policy Debate". J of Advertising 1993; 22: 110-117.

Anonymous, "A Guide for Dealing with Anti-Tobacco Pressure Groups", Infotab, October 1989, Item 3.2.5-6.

Glantz, S. A., Barnes, D. E., Bero, L., Hanauer, P., Salde, J., "Looking Through a Keyhole at the Tobacco Industry: The Brown and Williamson Documents." JAMA 1995; 274: 219-224. Slade, J., Bero, L.A., Hanauer, P., Barnes, D. E., Glantz, S. A., "Nicotine and Addiction: The Brown and Williamson Documents". Idem: 225-233. Hanauer, P. Slade, J. Barnes, D. E., Bero, L., Glantz, S. A., "Lawyer Control of Internal Scientific Research to Protect Against Product Liability Lawsuits: The Brown and Williamson Documents". Idem: 234-240. Bero, L., Barnes, D. E., Hanauer, P. Slade, J., Glantz, S. A., "Lawyer Control of the Tobacco Industry's External Research Program: The Brown and Williamson Documents". Idem: 241-247. Barnes, D. E., Hanauer, P., Slade, J., Bero, L., Glantz, S. A. "Environmental Tobacco Smoke: The Brown and Williamson Documents". Idem: 248-253.

Slade, J. Bero, L. A., Hanauer, P., Barnes, D. E., Glantz, S. A., "Nicotine and Addiction: The Brown and Williamson Documents". Idem: 228.

AmericanMedical Association House of Delegates Resolution 96, Interim Meeting: 3-6 December, 1989, Honolulu, HI. Blasi, V., Monaghan, H. P., "The First Amendment and cigarette advertising". JAMA. 1986; 256: 502-509. Dr. S. T. Han, World Health Organisation, Regional Director, Office of the Western Pacific Region, Action Plan on Tobacco or Health, 1995-1999, January 1995.

Everingham, R., Woodward, S., Tobacco Litigation. The Case Against Passive Smoking: AFCO v TIA - An Historic Australian Judgement. Legal Books, Sydney, 1991.

Tobacco and Cancer Programme, International Union Against Cancer
3, Rue du Conseil-Général, 1205 Geneva, Switzerland
Tel: (4122) 809 1830, Fax: (4122) 809 1810
E-mail: tobacco-control@globalink.org, Web Site http://www.globalink.org/