Scottish Grocers' Federation

The Scottish Grocers’ Federation (SGF) is a trade association for convenience stores in Scotland. It has campaigned against several public health measures, despite being a member of the Scottish Government’s Ministerial Working Group on Tobacco Control, which is “…a forum for the development of policy to reduce the impact of tobacco on Scotland’s health”.

Relationship with the Tobacco Industry

Image 1: SGF Gold Membership Benefits (screenshot from SGF website, May 2014)

SGF Members: JTI, Imperial, PMI, and BAT

SGF is primarily funded through two types of membership: retail membership and corporate “supplier” membership. There are four levels of corporate membership: Platinum, Gold, Silver and Bronze. In 2014, Gold corporate membership was worth £9,999 per year (see Image 1).

As of January 2020, SGF listed 94 corporate members on its website. Four were tobacco companies: Japan Tobacco International (JTI); Philip Morris International (PMI); British American Tobacco (BAT); and Imperial Tobacco. JTI was a Platinum member; PMI and Imperial Tobacco were Gold members; and BAT was a Silver member. JUUL Labs, in which Altria owns a 35% stake, was listed in 2020 as a Bronze member, as was the UK Vaping Industry Association (UKVIA), another trade organisation of which all these companies are members. Imperial Tobacco’s e-cigarette brand blu had previously been listed as a Gold member.

In 2012, when SGF had only 37 corporate members (including Imperial, BAT and PMI), the total tobacco contribution accounted for 9.7 per cent of total SGF income derived from corporate memberships. The current proportion of tobacco contribution to SGF corporate membership revenue is unknown.

Despite significant corporate interests, SGF has stated in the past that "policy decisions, campaigning work and lobbying activities are wholly determined by our National Executive, which is comprised solely of our retail members. Corporate members are not represented on the National Executive”.

Attempted to Set Up Parliamentary Group on Tobacco Harm Reduction

The Federation has consistently worked to develop relations with members of the Scottish Parliament. That includes sponsoring Community MSP of the year as part of The Herald’s Scottish Politician of the year awards. Dr Pete Cheema OBE, chief executive of Scottish Grocers Federation, said: “We are proud to be sponsoring the Community MSP of the Year Award. This is the first time we have been involved as a sponsor and we are delighted to be associated with such a high-profile event.”

In 2018, the SGF and PMI unsuccessfully tried to set up a Scottish Parliamentary Cross-Party Group (CPG) on Harm Reduction and/or e-cigarettes. Richard Lyle, Member of Scottish Parliament (MSP), was asked to convene the CPG due to his personal experience as a long-term smoker turned vaper. In 2017, the MSP had visited PMI’s Swiss Research and Development facility to be briefed about the company’s heated tobacco products, a trip paid for by the tobacco company.

SGF Interest in Harm Reduction

In April 2018, John Lee, SGF’s Head of Policy and Public Affairs, wrote to Lyle explaining SGF’s interests in setting up the CPG:

“Whilst it goes without saying that we all support a reduction in smoking, there is no question that their replacement on the shelves with a less harmful alternative is good not just for the nation’s physical health, but also for the health of our sector”.

He added:

“potentially E-cigarettes and reduced risk products could be a very important sales category for small retailers”.

“Frustrated” that Tobacco Companies Could Not to be Involved

Lee's letter to Lyle refers to an earlier discussion between Lee and Lyle about the role of tobacco companies in the CPG, stating that both had agreed, yet were “frustrated”, that it was “critically important that tobacco manufacturers are not included on, nor invited to, the proposed CPG”:

“Whilst we are both frustrated that we cannot get all stakeholders around the same table to discuss an issue of such national importance, we are equally clear that many of the MSPs and organisations we wish to be involved in the CPG would not participate were ‘big tobacco’ to be involved”.

Lee continued:

"We have shared with one another that we intend to continue to engage with those companies in separate dialogue recognising the role that they are playing in the provision of such new harm reduction technology in respect to scientific research alongside the widespread commercialisation of such products”.

Public Relations Firms Engaged to Garner Support

Two Edinburgh-based public relations firms were engaged to gain support for the CPG proposal: Halogen Communications, which has worked with PMI to oppose the Scottish Government’s plan to implement plain packaging, and Message Matters, which counts SGF as one of its clients.

Public records of the Scottish Lobbying Register document that PMI and Halogen Communications met with Lyle on 19 April 2018, to brief the MSP on “the latest developments relating to heated tobacco products, e-cigarettes and smoking harm reduction in Scotland and the UK”, and “to discuss the possible formation of a Cross-Party Group on vaping at the Scottish Parliament”. Lobbying Register records also show that Message Matter’s Andy MacIver, on behalf of the SGF, met with Lyle that same date to discuss the CPG. It is unclear whether two separate meetings occurred, or whether PMI, Halogen, and Message Matters attended the same meeting with Lyle.

Lobbying Register records also suggest that Message Matters was responsible for generating CPG support from MSPs and public health organisations. Yet in June 2018, the SGF and Message Matters abandoned the proposal to form a CPG on harm reduction in Scottish parliament, with Message Matters citing a reluctance of public health organisations to take part in the CPG.

Secretarial Support to Parliamentary Group on Independent Convenience Stores

In September 2016, the inaugural meeting of the Cross Party Group on Independent Convenience Stores (ICS) took place in the Scottish Parliament. Pete Cheema and John Lee from the SGF spoke at the meeting with Cheema proposing Gordon MacDonald MSP as the convenor. The SGF provides secretarial support with Lee given as a contact. As of 2019, MacDonald remained the convenor.

The ICS group has ten MSPs as members and 29 organisations as members including the Scottish Wholesale Association which has tobacco industry members. The group aims to “inform MSPs of the issues and challenges facing independent convenience stores and to highlight the contribution local neighbourhood shops make to Scotland’s communities.” At the 2019 autumn conference of the Scottish National Party, Japan Tobacco International sponsored a fringe meeting called “Where next for vaping in Scotland?”. Dr John Lee was the chair and the speakers were Emma Harper MSP, a member of various cross party health groups, John Mason MSP from the ICS group, Andy Morrison from New Nicotine Alliance, and Doug Mutter from Edinburgh-based vaping company Vaporized (VPZ). Mutter previously worked for Imperial Tobacco e-cigarette subsidiary Fontem Ventures from 2012-2015.

Campaigned Against Tobacco Plain Packaging

Image 2: Media Messengers, PMI Corporate Affairs Update, 2012

In May 2016, the United Kingdom (UK) introduced plain packaging legislation. The SGF was one of several trade associations that actively opposed plain packaging legislation proposals in the UK.

• Also see: Plain Packaging in the UK: Tobacco Industry Built Alliances.

PMI Identified SGF as a “Media Messenger”

Leaked 2012 PMI documents reveal that the tobacco company planned a multi-faceted campaign to oppose the government’s proposal to introduce plain packaging. As part of its strategy PMI outlined key third-party “messengers”, seemingly independent third parties like retail groups, business associations, think tanks, anti-counterfeiting groups, researchers and international organisations, to push its message in the media (see Image 2). One of the ‘Retail Media Messengers’ listed was the SGF.

2012 and 2014 UK Consultations: Arguments Mirror Those of Tobacco Industry

The SGF submitted detailed responses to the 2012 and 2014 UK public consultations on plain packaging. In its submissions, the SGF claimed that its nearly 2,000 retailer members employ approximately 32,000 people across Scotland, with annual sales in excess of £3.2bn. It added that "Tobacco constitutes an important part of this economic output accounting for approximately 21 per cent of turnover for the average convenience stores with profits ranging from 5% (economy brands) to 8% (premium brands)".

One key argument against plain packaging voiced by the SGF in both submissions was that the policy would make it easier to counterfeit tobacco products, which is also an tobacco industry argument against plain packaging. In its 2012 submission to the UK consultation, SGF claimed that illicit trade “which is more prevalent in lower income, price sensitive and disadvantaged areas - will drive smokers out of legal and responsible premises selling regulated products to an illegal, irresponsible and unregulated market”. The SGF further claimed that the world-wide illicit trade was growing and within the European Union had increased from 2007 to 2010, a claim not supported by UK data from Her Majesty’s Revenue and Customs (HMRC) which showed a decline in illicit trade of cigarettes between 2003/4 and 2011.

SGF’s other arguments against plain packaging also closely mirrored those promoted by the tobacco industry:

• The evidence base supporting change is neither robust nor unequivocal;
• Packaging is not why young people smoke, the reasons are more deep rooted and more intractable: family background and socio-economic situations are far more significant than brand awareness;
• Smokers will down trade to cheaper brands, which will lead to a loss of profits;
• Cross-border shopping will increase among those who wish to continue smoking branded products;
• Legality of plain packaging is unclear.
• Transaction times will increase because packaging will have fewer distinguishing features. Note: a simple study conducted by Australian researchers found that similar claims made by the Alliance of Australian Retailers when opposing plain packaging in Australia were likely to be incorrect;
• Plain packaging will make cleaning, replenishing and stocktaking more arduous thereby requiring additional resources form retailers to compensate. Note: This argument has been refuted in a research letter published in the BMJ; and
• Not enough time has been given to allow other legislative and price-based tobacco control measures to take effect.

Tobacco industry arguments were supported by evidence that was either funded by them, or not actually relevant to plain packaging. Click here for counter arguments.

Image 3: BAT UK Consultation submission cites support from SGF that plain packaging is burdensome (Source: Talking Retail, Independent Newsagents fear boost to illicit trade from plain packaging. 16 April 2012)

SGF Cited in BAT’s Submission to Plain Packaging Consultation

In its submission to the 2012 UK Consultation on plain packaging, BAT argued, among other things, that the policy was an example of Burdensome over-regulation. The company argued that retailers had already suffered the significant costs of compliance with point of sale display ban regulations and that plain packaging legislation would require retailers to spend even more on training and security to comply with yet another type of regulation. To support its ‘burdensome’ argument BAT cited a quote from the SGF (see Image 3).

SGF Submitted Evidence to Chantler Review

In November 2013, the UK Government announced that it had commissioned pediatrician Sir Cyril Chantler to review the most recent evidence for plain packaging. In its submission to the Chantler Review, the SGF reiterated many of the tobacco industry arguments against plain packaging, including that the policy would breach intellectual property of the tobacco companies, and increase the threat of illicit tobacco trade.

Like the tobacco companies, the SGF attacked the independent scientific review, commissioned by the Department of Health, which had systematically reviewed 37 studies that provided the evidence base for plain packaging. It also criticised an Australian peer-reviewed study carried out by the Centre for Behavioural Research in Cancer, which showed that after the introduction of plain packaging some smokers had “perceived their tobacco to be of lower quality and less satisfying” and were thinking about quitting.

Opposed Tobacco Display Ban

In 2010, SGF called the Scottish proposed tobacco display ban as “the most inflexible and burdensome approach in the world”, calling it “ineffective”.

Ahead of the Scottish parliamentary elections, in 2011, the SGF attempted to mobilise retailers to put pressure on MSPs to drop the display ban.

TobaccoTactics Resources

• Plain Packaging Opposition in Scotland
• Scotland Plain Packaging: Scaremongering over Illicit Tobacco
• PMI’s “Illicit Trade” Anti-Plain Packaging Campaign
• PMI Mobilised Support from Retailers
• Scottish Wholesale Association
• Countering Industry Arguments Against Plain Packaging: It will Cost Small Businesses
• Richard Lyle MSP
• Halogen Communications

Relevant Link

• Scottish Grocers’ Federation website