Tobacco lobbyists all fired up ahead of key vote

For a PDF version of this article, with the Annexes, please click here.

On 10 and 11 July, the European Parliament’s environment, health and food safety committee (ENVI) votes on the 1,360 amendments that MEPs have tabled to the Commission's proposal for a new Tobacco Products Directive. The European Commission's proposal includes graphic photos and text warnings to cover 75% of the front and back of cigarette packs, restrictions on the sale of slim cigarettes, menthol and flavoured cigarettes and electronic cigarettes, and the regulation of Internet sales. New EU health Commissioner Tonio Borg says the ambition of the new Tobacco Products Directive is to make “tobacco products and smoking less attractive and thus discourage tobacco initiation among young people”.1 Commissioner Borg has publicly stated that legislation should be in force by 2016 at the latest, and that means getting it adopted before the current European Parliament’s term expires in summer 2014.

With the Tobacco Products Directive now in the hands of the European Parliament and European Council, this report offers a curtain-raiser on the intensity of tobacco lobbying towards MEPs whose support could help change the game. This report documents the experiences of some MEPs, their assistants, and political advisers, who have testified that the tobacco and electronic cigarette lobby are becoming more aggressive as the voting approaches. It comes just weeks after the European Parliament's committee on legal affairs and committee on trade, voted to weaken the tobacco law on key points that are remarkably in line with tobacco industry wishes. This gives the clearest sign yet that the strategically targeted tobacco industry lobbying of the Parliament is having effect. As MEPs in the ENVI committee, the lead committee on the tobacco law, prepare to vote this week, CEO wafts a breeze through the smoky conduct of one of the dirtiest industries in lobbying history.

Tobacco lobby targets European Parliament

A previous investigation by CEO found around 97 full time tobacco lobbyists working in Brussels, with an annual lobbying budget of around €5.3 million.2 These estimates were based on entries in the EU's voluntary lobby register - which is, by its nature, incomplete and partly inaccurate3 – and so are almost certainly underestimates. For this new report, we called and emailed dozens of MEPs, their assistants, political advisers and campaign groups during June 2013, in order to get a picture of the scale of tobacco lobbying in the run up to the European Parliament vote. (See Annex 1)

Karl-Heinz Florenz MEP from the European People’s Party (EPP) described how he had received numerous emails, letters, position papers and phone calls on the Tobacco Products Directive. He sent CEO a list of all the tobacco and electronic cigarette industry organisations who had contacted him in the last six months. This list shows that nearly 40 different tobacco industry actors, from individual companies and industry federations to lobby consultancies representing tobacco companies have contacted him in the last half year. (See Annex 2)

Various MEPs and assistants from different parties have confirmed a picture of heavy lobbying, particularly since last Autumn, with emails coming in multiple times a week and meeting requests cited from various tobacco companies and public affairs consultants representing them, from several different countries. One political advisor, on the topic of the tobacco lobby, said: “On a scale of 1 to 10, they’re 11... They’re lobbying us to death ”.

Lots of tobacco lobby contacts... when UN law says there shouldn't be

The United Nation's World Health Organisation (WHO)'s 2005 Framework Convention on Tobacco Control (FCTC) is premised on the basic fact that there is an irreconcilable difference between the interests of the tobacco industry (producing and selling as much of a substance as possible, in order to maximise profit) and that of public health regulators (reducing the consumption of that same substance as much as possible, in order to minimise cancers and other negative health impacts). This piece of international law (to which the EU, and all member states, is a signatory) not only requires transparency around all contacts between public health policy-makers and the tobacco industry but requires that they are avoided and limited only to contacts that are strictly necessary to regulate the industry.4 Or put another way, as the Smoke Free Partnership's Florence Bertelletti Kemp does, "If you want to resolve malaria, you’re not going to include the mosquito."

Thus, MEPs, as with all policy-makers involved in legislating on public health, should– as a matter of law - be having as few contacts with the tobacco industry as is strictly necessary to regulate them, and all interactions that do take place should be fully transparent. This is an industry unique in having international law that governs contacts between that industry and the people charged with regulating it, and this is because close ties between them have been shown to be so harmful in the past. Aggressive and deceptive lobbying and willful disinformation by the tobacco industry has been globally documented for over half a century.

Public health lobby: outnumbered, out-gunned?

The tobacco industry are not the only ones lobbying around the Tobacco Products Directive. Public health and anti-smoking groups are also active lobbying the Parliament in the run up to the vote on legislation which has the potential to impact the nearly 700 000 tobacco related deaths in the EU each year.5 But another distinction – beyond the rules in the FCTC - that should be made is that even though tactics may sometimes be similar (invitations to lobby meetings, sending briefings or amendments, or even e-campaigns from citizens), the tobacco industry dramatically outnumbers and out-guns those lobbying on tobacco regulation from a public health perspective. Compared to the 100 or so declared full-time tobacco industry lobbyists, there are only a handful of professional lobbyists active from the public health perspective.

Paul Murphy MEP, from the European United Left/Nordic Green Left (GUE/NGL), testified to this massive disparity between the level of tobacco lobbying and NGO campaigning around the Tobacco Products Directive:

“My understanding is that Smoke Free Partnership have two people working for them whereas the tobacco industry have 100 full time people... It's a massive disparity because tobacco have a lot of money - and its worth a lot of money to them - whereas NGOs might get some government funding... It's completely mismatched... And that makes it not a fair representative of opinion in society... People with money have a bigger voice.”

The Smoke Free Partnership is a Brussels-based NGO comprised of the European Respiratory Society, Cancer Research UK, the European Heart Network and Action on Smoking and Health UK. Florence Berteletti Kemp, the director of the group, re-emphasised the message that NGOs' lobbying is far outmatched by tobacco:

“Because this legislation would have an impact on their business, there are hundreds of tobacco industry lobbyists. It’s an army. ”

Not all MEPs' offices claimed to have experienced this vast disparity between industry and public health lobbying on tobacco. Indeed, two assistants for Socialist and Democrat (S&D) MEPs said they had received higher volumes of emails from NGOs and hadn’t noticed much material from the tobacco industry. This takes us to the heart of the tobacco industry's lobbying tactics. Knowing who to target.

Know your enemy: the lobbyist's art of political targeting

Part of the tobacco industry's lobbying strategy – as with any savvy industry or cause - is knowing who to target. A sensible tobacco lobbyist won't waste their time and reputation on lobbying those individual MEPs or parties that have a well-known interest in transparency (particularly those who know about WHO FCTC rules), or who are known to be public health champions or hostile to the tobacco industry (such as with most Greens, GUE/NGL and many S&D MEPs). Instead, they will target their lobbying towards MEPs who are known to be pro-industry or have a record of opposing trade barriers or limitations on intellectual property (of which you'll find a higher number in the EPP, ALDE, ECR, etc groupings). This message was confirmed by many of the MEPs' offices who've made it publicly clear that they will not be meeting with tobacco lobbyists, but are nonetheless surrounded by, and aware of, tobacco lobbying being directed at many of their colleagues.

For example, the assistant of an S&D MEP on the ENVI committee stated that:

"They [tobacco lobbyists] target opinion giving committees... They [the opinion giving committees] are a softer touch because everyone on the ENVI committee has been discussing this for months... All know the WHO guidelines... whereas the other committees aren’t dealing with it closely... It's easier to put it to MEPs who aren’t clued up..."

As we noted in our introduction, although the lead committee – the ENVI committee – will vote on the tobacco directive this week, two of 'opinion giving' committees, the legal affairs and trade committees, have in recent weeks voted to weaken the directive, in line with many of the tobacco industry's wishes. Wishes that have no doubt been expressed quite explicitly to these committee's members.

Similarly, another S&D MEP assistant remarked that:

"There is no point lobbying us because we’re very vocal about being anti-tobacco... They have lobbied our Romanian colleagues.. gave them copies of amendments... They hold events and give out free cigarettes, we know this from our Tory colleagues... they did one just before a committee... but we never get invited... "

An MEP from the GUE/NGL group noted that they “Don’t get lobbied because the GUE group are considered a waste of time," whereas the Green group's trade committee advisor remarked about an e-cigarette industry stunt, which involved putting sample e-cigarettes in the post boxes of MEPs, that “I didn’t get one through my pigeonhole... They focus on more promising people"

Burning questions: Are tobacco lobbyists applying undue pressure?

The testimony of these MEPs describing the targeting of tobacco lobbyists also gives a window into some of their activities – distributing freebies, offering amendments to table, inviting MEPs and staff to events. We have also repeatedly heard MEPs and Parliamentary staff describing tobacco lobbyists’ behaviour as “aggressive.” Aggressive lobbying – or more specifically, the use of dishonesty, undue pressure or inappropriate behaviour – is banned by the code of conduct for lobbyists.6 This code is agreed to by all lobbies that sign up to the Commission and Parliament's Joint Transparency Register. This voluntary register is currently under review,7 and one element that is under the spotlight for rectification is the code of conduct's vague wording and lack of implementation.8 Some tobacco industry lobbies have signed up to the register and are therefore covered by this code. If the register is made mandatory – as the European Parliament has long demanded – all lobby actors would be covered by this code of conduct.

One such example of undue pressure, if not outright dishonesty, was given to CEO by an MEP assistant who described their experience with one tobacco lobbyist: “He played the usual game of being all nice. But then half an hour before a vote was due, he sent an amendment to be submitted”. The lobbyist claimed he’d already agreed the amendment with another member of staff from the same office. But this later proved to be untrue, and was revealed to be a deception used by a lobbyist determined to get what he wanted, by hook or by crook.

Other examples of dubious lobbying techniques include using other groups – sometimes front groups – to push their agenda, without making it clear whose interests (the tobacco companies) are actually being represented. The not uncommon tabling of industry amendments has also been described as widespread, although here the onus is on MEPs to critically consider any amendments or suggestions they take from outside interests, be they from industry, civil society or other interests. The e-cigarette campaign has gone further, by distributing free products, orchestrating an aggressive social media offensive and even accusing MEPs reluctant to accept their viewpoint of 'questionable motives'.

The backdoor approach: using other groups to indirectly lobby MEPs

“Philip Morris representatives won’t lobby you,” one MEP assistant told CEO. “Instead it will be farmers’ groups, legal firms and groups discussing intellectual property rights”.

A number of assistants in the European Parliament told CEO that they had been contacted by local retailers, anti-fraud and anti-counterfeiting companies and trade unions. But these contacts had an eery similarity and political and legislative sophistication that marked them out as - very likely - originating from a particularly clever type of industry offensive.

One said the tobacco lobby was using a “backdoor approach”, lobbying them through organisations which seemingly had very little to do with tobacco interests, and thereby increasing the apparent credibility of the message and so the chances that MEPs will listen to them.

According to another MEP assistant, a small firm had contacted their office to say they were concerned about losing jobs. But, according to the assistant, when the company sent through suggested amendments for the Directive, their proposals covered a diverse range of tobacco interests, not just employment. Once again, the hand of big tobacco appeared to loom in the background.

Other MEPs’ assistants testified that a number of emails from constituents looked suspiciously similar and assumed they were part of a co-ordinated campaign instigated by the tobacco industry. This is not of course a tactic unique to tobacco; all kinds of interest groups – including public-interest environmental, development and human rights groups – use citizen email campaigns to try to influence policy-makers. CEO does not however find it cynical to see a difference between a company using citizens (who may themselves be harmed by that company's business) to promote its commercial interests and public-interest civil society groups garnering public pressure to convince policy-makers to act in the interests of the public.

Evidence of copy-pasted tobacco industry amendments

Opinion is divided over the normality and acceptability of interest groups suggesting amendments to MEPs, but what is clear is that only a critical approach by our law-makers over what they include in their own amendments to legislation is defensible.

Both the tobacco lobby and public health NGOs have been noted by MEPs as 'delivering suggestions' for amendments, and it is commonly accepted by many in Brussels that all stakeholders do this. But when a legislative proposal can be seen to have word-for-word sections that almost perfectly mimic the proposals for amendments of particular business or industry interests, especially those that are at odds with the public interest in strong health policy, there is very clearly a problem.

Some MEPs believe it is the sheer quantity of suggestions, particularly from the tobacco industry, that have amounted to a problem, though others disagree. One MEP assistant declared that, when attending a meeting of the trade committee on the tobacco directive, “it was very evident that the major groups were all singing from the same hymn sheet... There were multiple amendments that were the same.. .”

Paul Murphy MEP from GUE/NGL said: “It is a massive problem. Industry are trying to write legislation for themselves”.

In one particular example, MEPs have reported receiving an email from SWM, a producer of cigarette papers, asking them to support the deletion of paragraphs in Article 2 and 6 of the Tobacco Products Directive, and suggesting the addition of text to the amendments.

CEO has also seen three unmarked documents regarding the Directive, which according to MEP assistants, were handed to MEPs personally rather than emailed to them. Whilst none of the documents carry the name of an author or publisher, and so it is not possible to verify, several Parliamentary sources have testified to CEO that they are tobacco industry lobby documents. The amendments do, in any case, clearly represent the interests of the tobacco industry, such as a proposal to reduce the area of the package covered by health warnings from 75% to 50%.

CEO has analysed hundreds of the amendments to the Directive that have been tabled and compared them with the three lobby documents. Two MEPs in particular have tabled amendments that are remarkably similar to the alleged tobacco lobby amendments. Holger Krahmer from the Group of the Alliance of Liberals and Democrats (ALDE) tabled 36 amendments with a striking similarity to the amendments and to the justifications contained in documents seen by CEO. (See Annex 4)

Mr Krahmer has previously warned against “waging a crusade” against tobacco consumers. When former health Commissioner John Dalli was forced to resign last autumn, Mr Krahmer said he was pleased this meant the Tobacco Products Directive would probably be delayed: “It is good that we now have more time to reflect on the meaning of further sales restrictions on tobacco products”^.

9Christa Klass MEP from the EPP also tabled 12 amendments that almost completely resemble the amendments and justifications contained in the documents seen by CEO. (See Annex 5). Ms Klass said in an interview with CEO that she wrote the amendments herself, that she does not know why hers are the same as the apparent tobacco lobby amendments, but that “It could be the tobacco industry think the same way.” She furthermore stated that she had not seen any tobacco industry amendments, but that she does meet with tobacco lobbyists, as well as all stakeholders, including NGOs.10

CEO has asked Mr Krahmer for an interview about the similarities between his amendments and the proposed amendments contained in the seen documents. At the time of publishing, we have received no response.11

Electronic cigarettes: the next big thing?

It has already been reported in the media, in particular a recent exposé in the Wall Street Journal (WSJ),12 that the battle around the classification and restrictions on e-cigarettes in the Tobacco Product Directive has been intense. MEPs and their assistants have told CEO that they are most often contacted by the electronic cigarette lobby regarding this Directive.

Electronic cigarettes - also called ‘personal vaporisers’ - are battery-powered inhalers that vaporise a nicotine liquid solution. Electronic cigarette companies claim they are a safe alternative to cigarettes, but the World Health Organisation has warned that too little is known about the health risks of long term use. Moreover, the WSJ documented that e-cigarette makers are emulating tactics once used by tobacco companies, such as sponsoring medical studies and testimonials from doctors, and running television spots advertising the use of e-cigarettes indoors or in the presence of children. WSJ quoted a professor at the Research Center for Prevention and Health in Copenhagen as explaining that the e-cigarette industry “is really undermining all the progress we have made in de-normalizing smoking."

Under proposals in the Tobacco Products Directive, e-cigarettes would be classed as a medicine, subjected to intense testing and might only be available in pharmacies in some countries. The Directive also proposes they be reduced in strength. The Electronic Cigarette Industry Trade Association and the European Smokeless Tobacco Council are lobbying hard against these proposals. Individual electronic cigarette firms have also been directing intense fire at the Parliament, now it that the Directive is in MEPs' hands.

UK electronic cigarette manufacturer Skycig have urged users, their friends and family, to contact their MEPs, claiming that millions of people would turn back to cigarettes “effectively allowing 5 million people to die from smoking related illnesses”.13

Paul Murphy MEP explained that in the Parliament, MEPs “are subjected to a lot of astroturf campaigning in the sense that it is manufactured. We get emails from so-called ordinary constituents about electronic cigarettes. But they are really detailed about the Directive.”

‘Astroturf’ is the name given to seemingly grass roots campaigns, that have actually been established, encouraged and sometimes funded by companies and corporate lobby groups interested in their success. One MEP assistant told CEO: “They have organised online, created electronic cigarette forums. They’re quite an aggressive lobby”. Another said: “We get a lot of abuse on Twitter about calling for more legislation on electronic cigarettes.”

Totally Wicked, another UK electronic cigarette firm, sent every MEP an e-cigarette. One MEP commented incredulously that “They are sending addictive drugs to MEPs. It is quite incredible”. Jutta Haug MEP from the S&D said she had been “strongly lobbied by electronic cigarette users”. The rapporteur on the Tobacco Products Directive, Linda McAvan MEP, has also said that “There is a very aggressive attitude.”

Indeed, Ms McAvan was the center of a controversy around e-cigarette company Totally Wicked after their managing director stepped down at the end of June, after admitting sending “inappropriate” emails to Ms McAvan. In the emails, the former managing director called in to question her legitimacy and motivations.14

Varying degrees of transparency over MEPs’ contacts with tobacco lobbyists

We have already mentioned the UN FCTC and its rules governing contacts between public health policy-makers and the tobacco industry. These must be limited to those strictly necessary in order to regulate the industry and be conducted completely transparent, including ‘disclosure of records of such interactions to the public.’19 CEO has previously documented the lack of transparency between the European Commission and tobacco lobbyists.20 Whilst the Commission’s directorate for health and consumers (DG SANCO) lists meetings with tobacco lobbyists and publishes minutes (although omissions have been found), other directorates have been having meetings without any disclosure. But do MEPs fair any better?

Earlier this year, the Greens wrote to European Parliament president Martin Schulz arguing that a common approach was needed to implement the Parliament's obligations under the UN FCTC, in the form of joint transparency rules for contacts with tobacco lobbyists. This letter was discussed at a meeting of the chairs of the Parliament's committees, led by MEP Klaus-Heiner Lehne, where it was argued that the UN FCTC rules are not binding and that a common approach for all MEPs was therefore not needed. This is a problematic analysis, as the FCTC is itself a piece of binding international law. The guidelines that accompany it, and elaborate on how to implement the principles enshrined in the law, should – CEO believes - be considered to have a de facto binding character as well.

The European Parliament’s rapporteur on the Tobacco Products Directive, Linda McAvan MEP, has nonetheless publicly listed the meetings she has had with the tobacco and electronic cigarette industry, as well as NGOs and government agencies. She has included these as a legislative footprint to her draft report on the TPD for the ENVI committee, listing all the organisations she met with, received, or heard from representatives, as rapporteur.21 The footprint shows she had ten contacts with EU and National Regulatory Agencies, 7 with NGOs and 3 with industry. Participant lists and records of the two open meetings with industry (tobacco industry and suppliers,22 and the e-cigarette industry23) are also made available. The practice of having only public hearings with the tobacco industry is a very good one. Ms McAvan's approach not only meets the requirements of the FCTC but sets a good benchmark for the practice of a legislative footprint, and it is one that CEO would like to see followed by Commission and Parliament alike.

The political grouping in Parliament most serious about implementation of the WHO rules is the Greens, who have an online 'Registry of contacts between Greens/EFA and the tobacco industry'.24 This lists all contacts between Members and/or staff of the Greens/EFA group and the tobacco industry, and includes details of 17 meetings during the last three months.

The Greens are the only political group that has a coherent policy across all its MEPs, but there are also MEPs in other groups who are actively implementing the WHO rules. Rebecca Taylor, an ALDE MEP, states on her website that:

"The World Health Organisation Framework Convention on Tobacco Control requires policy makers to be as transparent as possible when meeting with representatives of the tobacco industry and other affiliated companies, and so details of all such meetings will be published below. In the interests of balance, I am also including details of meetings with all stakeholders on the tobacco directive."

Ms Taylor lists around 20 meetings over the last few months, March to June 2013, the vast majority of which appear to be with the tobacco or e-cigarette industry.25

The GUE/NGL has been very outspoken about being pro-transparency. For example, MEP Martina Anderson has stated that she “urges fellow MEPs to adhere to WHO conduct guidelines"26, but it is not clear whether the GUE group have actually had any tobacco industry meetings to declare.

Contrastingly, Christa Klass, the EPP MEP who tabled 12 amendments almost exactly the same as alleged tobacco industry amendments, stated in an interview with CEO that she does not publish or declare her meetings with the tobacco industry: “No, why should I?”. When informed of the FCTC requirement to do so, she replied “I have no time for this. I would need another secretary to do all this."

In an attempt to find out more about other meetings between MEPs and tobacco lobbyists, CEO wrote to 102 members (and their substitutes) on the ENVI committee to ask if they had met with tobacco lobbyists in the previous six months. We had very few responses from which to elaborate, with only six MEPs answering our questions. (See Annex 3)

It is perhaps worth noting however the variety of these responses. Karl-Heinz Florenz MEP listed seven meetings with representatives from e-cigarette firms and the tobacco industry since February 2013 (Annex 3). Jutta Haug MEP reported meetings with representatives from one tobacco company and one manufacturer. Anna Rosbach MEP said she had met with some tobacco lobbyists but had declined others because she was concerned that hey were not on the Transparency Register. Sandrine Belier MEP was invited to a meeting but declined. Tobacco company Swedish Match asked to see Rebecca Harms MEP but she refused. Nessa Childers MEP said she had not been invited to any meetings.

Conclusions

The tobacco lobby – and e-cigarette industry – has been intensifying its lobbying offensive towards the European Parliament. Their tactics and strategies have included frequent calls, emails and invitations for drinks and meals; the distribution to MEPs of product samples; turning up to MEP offices without prior arrangements; putting pressure on MEPs to table amendments that are in their interests; orchestrating email and social media campaigns; and, indirect lobbying through small retailers, anti-counterfeiting firms and farmers’ groups. All of this should be seen in the context of the UN FCTC – which prohibits contacts between public health policy-makers and the tobacco industry unless strictly necessary to regulate it, and then only under complete public transparency.

The bulk of our research, including contacts with MEPs, has indicated that:

• Many MEPs, their assistants and advisers have described an intense or even 'aggressive' lobby from tobacco industry representatives, particularly in regards to high numbers of telephone calls, emails and requests for meetings. Others seem to be less targeted, and note public health NGOs, although far fewer in number and resources, also have a prominent lobby presence.

• It is apparent that the tobacco lobby knows who to target to achieve the best results (for its interests), in particular targeting MEPs that they see as more receptive to their arguments as well as those on opinion giving – rather than the lead committee on the Tobacco Products Directive – committees.

• The electronic cigarette industry has in recent months represented a particularly vociferous lobby, notably using social media campaigns, ‘astro turfing’ tactics as well as the distribution of free samples.

• Only some political groupings, as well as certain individual MEPs – notably including the rapporteur on the Directive - are publicly disclosing meetings and contacts with tobacco industry representatives. There is not yet a consistent implementation of the UN FCTC rules on contacts with tobacco lobbyists by the European Parliament. There have even – very worryingly – been signals from the Parliament that suggest they do not consider the FCTC to be legally binding on them and consequently see no need for a consistent approach to transparency around tobacco contacts.

• There is evidence that industry-sourced amendments have made their way more or less word-for-word into the amendments proposed by some MEPs. Two MEPs in particular appear to have largely copy-pasted from the documents showing amendments in the industry's favour – and contrary to the strengthening of public health policy.

With a key European Parliament ENVI committee vote on new tobacco legislation taking place later this week, this report is a curtain-raiser on the scale and intensity of tobacco industry lobbying that has been going on in the Parliament in recent months. The tobacco industry has a long record of manipulation and disinformation, which has - uniquely - resulted in international law intended to minimise interactions between the tobacco industry and public-health policy makers. The lobby battle around the EU's new Tobacco Products Directive however shows considerable activity from traditional tobacco lobbyists as well as e-cigarette companies, resulting in numerous contacts between policy-makers and the tobacco industry, many of which are subject to little or no transparency. The concerns expressed by many MEPs about the apparent tobacco industry amendments tabled via their Parliamentary colleagues, indicates that the tobacco lobby is having significant success where it should not even be having significant access.

For the Annexes, please see attached PDF, or click here.

Photo by Rares M. Dutu,CC BY-NC-ND 2.0, via Flickr

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• 1. http://europa.eu/rapid/press-release_IP-12-1391_en.htm
• 2. http://corporateeurope.org/publications/mapping-tobacco-lobby-brussels-s...
• 3. For more details on the shortcomings of the Eu's voluntary approach to lobby transparency, and the current review of the register, see the ALTER-EU report 'Rescue the Register! How to make EU lobby transparency credible and reliable', http://www.alter-eu.org/sites/default/files/documents/Rescue_the_Registe...
• 4. UN WHO FCTC Article 5.3, and accompanying guidelines. See, for example, http://www.who.int/fctc/guidelines/article_5_3.pdf and http://www.smokefreepartnership.eu/documents/briefing-article-53-fctc-gl...
• 5. http://ec.europa.eu/health/tobacco/introduction/index_en.htm
• 6. http://ec.europa.eu/transparencyregister/info/about-register/codeOfCondu...
• 7. For more information, see ALTER-EU's June 2013 report, Rescue the Register! How to make EU lobby transparency credible and reliable http://www.alter-eu.org/sites/default/files/documents/Rescue_the_Registe...
• 8. ALTER-EU Briefing on the Code of Conduct for Lobbyists, http://www.alter-eu.org/sites/default/files/documents/ALTER-EU_Briefing_...
• 9. Quoted in the European Voice 18/10/12 http://www.europeanvoice.com/article/imported/the-invisible-hand-of-big-...
• 10. Interview with Christa Klass MEP, 3rd July
• 11. Holger Krahmer’s office was asked for an interview by phone and email on 26/06/13 and again on 01/07/13. Mr Krahmer did not respond.
• 12. Wall Street Journal, 18 June 2013, Battle Brewing in Europe Over E-Cigarettes, http://online.wsj.com/article/SB1000142412788732383650457855339088752479...
• 13. http://www.skycig.co.uk/ecita
• 14. http://www.totallywicked-eliquid.co.uk/news/2013/june/totally-wickeds-ma...
• 15. http://corporateeurope.org/sites/default/files/complaint_swedishmatch_lo...
• 16. http://corporateeurope.org/publications/ceo-submits-ombudsman-complaint-...
• 17. http://www.maltatoday.com.mt/en/newsdetails/news/world/Dalli-transferred...
• 18. http://corporateeurope.org/pressreleases/2013/european-commissions-petit...
• 19. http://www.who.int/fctc/guidelines/article_5_3.pdf
• 20. http://corporateeurope.org/news/commission-shabby-implementation-un-rule...
• 21. p. 46,http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-%2f%2fEP%2f%2fNONS...
• 22. Open meeting with the tobacco industry and upstream and downstream suppliers, participant list available athttp://www.mepheartgroup.eu/meetings-activities/item/52-the-battle-again... and record of the meeting available athttp://www.europarl.europa.eu/document/activities/cont/201303/20130320AT...
• 23. Open meeting with the electronic cigarette industry, Participant list available http://www.europarl.europa.eu/document/activities/cont/201303/20130320AT... and record of the meeting available http://www.europarl.europa.eu/committees/en/envi/events.html?id=other#me...
• 24. www.greens-efa.eu/revision-of-the-tobacco-directive-9319.html
• 25. http://www.rebeccataylor.eu/my-work-in-parliament/
• 26. http://www.derrysinnfein.ie/news/24041