Thu, May 17, 2001 5:02 PM
Subject: Cigarette and Smokeless Tobacco Reports
This is an individual comment being submitted to the Federal Trade Commission in response to the Request for Public Comment on the Cigarette and Smokeless Tobacco Reports.
I am an associate professor in the Boston University School of Public Health, and have been researching tobacco health and policy issues for the past nine years.
This comment responds to the following question posed in the Request for Public Comment: "Is there information about cigarette and smokeless tobacco sales, advertising and promotion that has not been included in the reports, but that would be of use? If so, what additional information would be of use, and why would it be useful?"
There are two areas of information about cigarette and smokeless tobacco advertising and promotion that I feel should be included in the reports that would be of great use to the public as well as to lawmakers, government officials, and policy makers:
1. Reporting of Tobacco Company Expenditures for Corporate Sponsorship:
Corporate sponsorship of events and organizations is a well-recognized marketing tool. Sponsorship enhances a corporation's image, associates the name of a sponsoring company with causes that are important to a particular target group, offers effective product exposure, targets specific populations including groups that are difficult to reach through more traditional forms of advertising, and provides publicity for a company through highly visible activities. Tobacco companies are increasingly using corporate sponsorship as an important component of their marketing mix. For example, from 1995 to 1999, cigarette company spending on sports sponsorship increased from $83 million to $113.6 million.
The attached manuscript, which is in press at the journal Tobacco Control, summarizes my research on tobacco industry sponsorship. From this research, I have concluded that tobacco corporate sponsorship serves as an important marketing tool for tobacco companies, serving both a sales promotion and public relations function.
Because sponsorship serves an important marketing function for tobacco companies, expenditures for sponsorship must be viewed as promotional expenditures. For this reason, such spending should be monitored and reported by the FTC in its reports on cigarette and smokeless tobacco advertising and promotion.
Monitoring and reporting of tobacco company sponsorship expenditures would be of great use because it would give the public as well as lawmakers and policy makers a more accurate picture of tobacco company promotional spending. The failure to report these expenditures in the current report format constitutes a substantial omission that prevents the reports from providing an accurate and complete picture of tobacco company promotional spending.
Currently, the FTC reports spending for sports sponsorship only, and also reports spending for public entertainment. However, as my research shows, there are many other categories of tobacco company sponsorship that are clearly not encompassed by either of these two categories. A specific line item that reports total sponsorship spending, perhaps broken down into categories (such as sports, entertainment, philanthropy, etc.) is the only way to provide an accurate and complete picture of tobacco company promotional spending.
2. Reporting of Television Advertising Value Achieved Through Sponsorship of Televised Motor Sports Events: Despite a federal ban on television advertising of tobacco products, tobacco companies achieve the equivalent of millions of dollars of expenditures on television advertising annually by sponsoring motor sports events and having cigarette and smokeless tobacco brand names and logos shown prominently on television as a result of the broadcasting of these automobile races.
The attached manuscript, in press at the American Journal of Public Health, summarizes my research on television advertising achieved by tobacco companies through their sponsorship of motor sports events.
In summary, my research demonstrates that during the period 1997-1999, tobacco companies achieved 169 hours of television advertising exposure and $410.5 million of advertising value for their products by sponsoring motor sports events. This is a substantial amount of television advertising, and there is no reason why it should not be included in the FTC's reports on cigarette and smokeless tobacco advertising. To report tobacco company television advertising expenditures as zero is grossly inaccurate, and completely ignores the millions of dollars in television advertising value achieved through their sponsorship of motor sports events, which is documented in my research.
Therefore, I suggest that the FTC should add to its reports a summary of the equivalent value of television advertising achieved through tobacco company sponsorship of motor sports events. Such information would be of great use to the public as well as to lawmakers and policy makers because it would provide a much more accurate picture of the extent of tobacco advertising on television. It would also assist the Department of Justice in monitoring and enforcing compliance with the Federal Cigarette Advertising and Labeling Act, which prohibits cigarette advertising on television, and it would assist the FTC in monitoring and enforcing the Comprehensive Smokeless Tobacco Health Education Act of 1986, which prohibits smokeless tobacco advertising on television.
There is a strong precedent for the enforcement of the Federal Cigarette Advertising and Labeling Act by the Department of Justice, as in 1996 and 1997, the Department of Justice used the Act to force tobacco companies to remove cigarette billboards from more than a dozen stadiums and arenas throughout the country. There is also precedent for the FTC to enforce the ban on television advertising of smokeless tobacco products contained in the Comprehensive Smokeless Tobacco Health Education Act of 1986, as in 1991, the FTC entered into a consent agreement with Pinkerton Tobacco Company to eliminate the placement of Pinkerton brand names and logos in areas likely to be viewed by television cameras during sponsored truck and tractor events.
Attached are the following two manuscripts, currently in press, as supporting documentation for this comment:
Because these two manuscripts are in press, they are being submitted only for the purpose of receiving timely consideration by the Federal Trade Commission. Copyright resides with the respective journals, so the manuscripts and data contained therein cannot be released publicly or to the press until publication of the articles.
Thank you for your consideration of these comments.
Michael Siegel, MD, MPH