The tobacco industry employs recurrent tactics to interfere with the implementation of policies designed to protect public health.

Research published by the Tobacco Control Research Group (TCRG), part of the University of Bath’s Centre for 21st Century Public Health, is the first to systematically examine and categorise how the tobacco industry responds after tobacco control policies are adopted. While extensive research has examined how the tobacco industry seeks to influence policy formulation and adoption, the literature on industry activity post-adoption remains more limited and fragmented.

The team of researchers analysed existing literature and identified five recurrent tactics, which together form the Policy Implementation Playbook. The five tactics are pre-emptive adaptation, disregard, token implementation, circumvention, and influence through intermediaries including retailers, hospitality actors, and enforcement agencies. The aim of these tactics is to shape how policy operates in practice, including whether policies can achieve their desired outcomes.

The Playbook builds on the Policy Dystopia Model, an evidence-based framework of how the tobacco industry responds to proposed tobacco control measures, to avoid, delay and weaken them before they get passed. The Policy Implementation Playbook extends this model by focusing on what happens after policies are adopted.

The authors hope this work could be of use for policymakers and regulators. Lead author Dr Britta Matthes, comments:

We often think of industry interference as something that happens before a policy is in place. But our findings show that policy adoption is not the end point. Anticipating how the tobacco industry may respond after policies are adopted could help policymakers and regulators strengthen regulatory design and implementation, including enforcement efforts.

While this study focuses on the tobacco industry, the patterns identified in it could reflect broader patterns also observed in other health-harming industries such as the alcohol, ultra-processed food and gambling industries. Analysing post-adoption tactics may therefore help strengthen understanding of how corporate actors exercise their power in ways that affect public health.

Professor Anna Gilmore, co-author of the Playbook and the Policy Dystopia Model, notes:

We anticipate this work can now be applied to other health-harming industries. Using our initial tobacco industry work, we have already shown that other health-harming industries use the same playbook as tobacco companies when attempting to influence the adoption of policies. Our new Policy Influence Playbook gives us the opportunity to see if they also do so after policy adoption. The likely answer is that they do so, but showing this will be vital in helping regulators design more resilient systems for policy implementation.

Please note, a pre-proof version of this paper was published on 12 June. There may be small changes between the current version and the final published manuscript.