As I have said several times before, it is a mathematical impossibility for illicit tobacco to make up only 13.8% of the total market (as HMT claims). The number of cigarettes sold legally in the UK fell from 23.4 billion to 14 billion between 2021 and 2024 - a drop of 40% - and the amount of hand-rolling tobacco sold legally fell from 8.6 million kilograms to 4.5 million kilograms - a drop of 48%. At the same time, according to the ONS, the total number of smokers fell by 20%, from 6.6 million to 5.3 million. In other words, legal tobacco sales have been falling at more than twice the rate as the number of cigarettes that are being smoked. It is blindingly obvious that the black market has picked up the slack.
... Even if you assume that there was no illicit tobacco sales in 2021, the data since then shows that they must now make up 28% of the market, twice as much as HMRC claims. And since there clearly was a black market for tobacco in 2021, the true figure must be even higher.
Wednesday, 3 December 2025
The OBR is bad and HMRC is worse
Friday, 28 November 2025
The WHO's "best buys" for alcohol
I've written a briefing for Epicenter off the back of this year's Nanny State Index about the WHO's so-called "best buys" for alcohol. These are the policies that are supposedly most cost-effective in cutting alcohol-related harm. As I show, there is scant evidence that they are effective at all, and they are certainly neither a sufficient nor necessary way of dealing with the problem.
Download it here or read a slightly modified version on my Substack.
Tuesday, 25 November 2025
What happened at COP11?
‘Unprecedented Levels of Industry Interference’ Stalls Decisions on New Tobacco Products and Pollution at UNFCTC COP11
Friday, 21 November 2025
The WHO is a billion dollars in the red
Among the many lowlights at this year's WHO anti-nicotine shindig was the Framework Convention Alliance giving New Zealand the Dirty Ashtray award for repealing the ludicrous generational tobacco ban while giving Mexico the Orchid Award for making a speech about how ghastly the tobacco industry is. New Zealand's smoking rate has been falling fast and is now one of the lowest in the world. Mexico's smoking rate has been rising.
But Mexico banned e-cigarettes this year and that's good enough for the WHO. In tobakko kontrol, it's process and intentions that count, not outcomes. (See this article for the hilarious response of Beowulf scholar turned "public health" expert Janet Hoek to New Zealand's "national shame".)
The poor old WHO isn't doing too well these days. In a document circulated to member states, it says that it has a $1.06 billion shortfall and is having to make cuts. They include:
2,371 job losses and a 28% reduction in headcount. The WHO's Regional Office in Africa is bearing the brunt (who cares about Africa, eh?) with a 25% reduction in staff, but Europe is not far behind with 24%.
The WHO's leadership team was reduced by around 50% in June.
The number of WHO units will be cut from 206 to 127.
The Assistant Director-General post on Universal Health Coverage, Communicable and Noncommunicable Diseases has been abolished. 'NCDs' are now the responsibility of Britain's Jeremy Farrar who is a good fit for the WHO because he likes sucking up to China.
The WHO says that it aims to "build on assessed contributions, diversify funding sources, and streamline grant management through technology". Don't be surprised if Bloomberg steps up with some more cash to tighten his stranglehold on the organisation.
Meanwhile, the New Zealand government has cut the budget of its temperance groups. I'll drink to that.
Have a great weekend!
"Good riddance" is not an economic policy
Sky Bet is relocating to Malta where it can enjoy an effective corporation tax rate of around 5 per cent rather than the 25 per cent it is currently paying in Leeds. The move comes after months of lobbying for higher gambling taxes and credible rumours that Rachel Reeves will increase remote gambling duty in next week’s Budget. Gambling operators cannot avoid paying duty on the Gross Gambling Yield generated by customers in the UK (which is essentially revenue, not profit), but they don’t have to be headquartered in the UK.
Since most gambling companies are based offshore and the government has done nothing to dampen talk of remote gambling duty going up from 19 per cent to 25 per cent or more, it should have taken no one by surprise when Sky Bet decided to flee the country. And yet the Chair of the Treasury Select Committee, Meg Hillier MP, was completely blindsided. “I’m pretty astounded,” she told ITV News. “The betting industry appeared in front of the Treasury Select Committee just a couple of weeks ago, extolling the virtues about how much tax they’re paying in the UK. And here we see a company going and offshoring. It rather takes the biscuit doesn’t it?”
The Betting and Gaming Council (BGC) did indeed appear before her committee last month, as I reported at the time, but it takes a tin ear to think that they were merely boasting when they explained that their members pay an effective tax rate of between 65 per cent and 80 per cent. They explicitly said: “The BGC’s role is to highlight to the Committee and the Treasury the negative impacts of any additional tax rises on the whole of the betting and gaming industry and the jobs it supports.” Mrs Hillier apparently misheard this as: “We pay lots of tax and would be delighted to pay some more.”
Sunday, 16 November 2025
COP 11 starts this week
The WHO’s big biennial tobacco conference kicks off this week in Geneva. A global tobacco conference wouldn’t be a bad idea right now. In a sane world, governments would be getting together to discuss how things are going so badly wrong and how to correct their mistakes.
Led astray by fanatics, a growing number of countries are seeing unintended consequences that are too disastrous to deny. Australia is the most dramatic example, but the black market in tobacco in Britain is also now a major source of criminal activity. Here are just some of the BBC stories from the last month involving the illegal sale of cigarettes:
Mini market closed after illegal cigarettes seized
Man jailed over illegal cigarettes and tobacco
£30,000 of illegal tobacco and vapes seized
Illegal vapes and cigarettes worth £60,000 seized
Illegal goods worth £280k netted in city shop raids
Arrests made and goods seized in police raids
Mini-mart crime network a ‘pull factor’ for illegal migrants, say MPs
Illicit cigarettes found under fake shop floors
Hundreds arrested in High Street crime crackdown
High Street action uncovers £75k of illegal goods
In countries such as France and the Netherlands, the illicit trade is similarly spiralling out of control. In Eastern Europe, balloons are being used to smuggle tobacco into neighbouring countries. In India, a WHO-approved ban on vapes has predictably led to a “rampant unregulated gray/black market”.
Tobacco duty receipts are declining, but in many countries smoking rates are holding steady. In the EU, the smoking rate has barely budged in a decade.
Faced with the consequences of its own actions, the anti-smoking lobby has shoved its head deeper into the sand. The secretariat for the Framework Convention on Tobacco Control (FCTC) has set out its stall for the eleventh Conference of the Parties (COP 11) by proposing some “forward-looking measures” that are just different flavours of prohibition. The real solution is to make smoking reasonably affordable while encouraging the use of low and ultra-low risk nicotine products like pouches and vapes. Instead, under the influence of Mike Bloomberg’s billions, they are demanding ludicrous policies such as putting health warnings on individual cigarettes and banning cigarette filters.
“a range of supply, demand and harm reduction strategies that aim to improve the health of a population by eliminating or reducing their consumption of tobacco products and exposure to tobacco smoke”.
The WHO is no longer very interested in reducing people’s “consumption of tobacco products”. It is now focused on reducing people’s consumption of products that contain no tobacco, do not produce “tobacco smoke”, and are substitutes for tobacco products. It is debatable whether this is even within the remit of the Framework Convention on Tobacco Control - given the WHO’s own definition of “tobacco control” - but it is certainly counter-productive and a threat to individual liberty. As I argued recently, it is quite possible that there would be fewer smokers around today if there had never been an anti-smoking movement.
As with the last two COP meetings, I will be in town with an impressive array of experts to have a reality-based discussion about what governments should do to heal their self-inflicted wounds, cut crime and improve health. The public and media are always banned from attending the conference (!), and it is anyone’s guess who will be on the UK’s delegation, but we’ll be doing our best to report on what’s happening and will be live-streaming a series of interviews and panel discussions throughout the week, so keep an eye on YouTube if this is your kind of thing.
Cross-posted from the Snowdon Substack
Friday, 7 November 2025
Black market gambling
Mr Kenny, the retired co-founder of Paddy Power, confirmed this approach by industry, noting that “[W]hen I campaigned for the gambling industry, I always used to talk about black markets and job losses. We saw it again when the FOBT [Fixed Odds Betting Terminal] legislation was brought in: “Oh, this will close all the shops,” but it didn’t. It is a bit of scaremongering.”
However, a recent paper in the Harm Reduction Journal noted research arguing that “[ … ] narratives advancing a threat of black-market provision of gambling [are] a form of ‘regulatory resistance’. Regulatory resistance is characterised by industry-led argumentation, often using industry-generated evidence, and arguments that reduced regulation can ‘protect’ the industry from the black market.”
Our best attempt to estimate the maximum ‘bearable’ rate of taxation produced an estimate lying around the 30% threshold, which is nearly the double of what was predicated by previous studies (e.g., 15% [13]).
France’s Illegal Gambling Market Surpasses Regulated Sector as Calls for Reform GrowFrance’s illegal online gambling market has overtaken the regulated sector for the first time, according to new data from the Association française des jeux en ligne (AFJEL). The group estimates 5.4 million players now use unlicensed websites generating about €2 billion in gross gaming revenue (GGR) in 2025 — a 25% increase since 2023.
Thursday, 6 November 2025
Chris van Tulleken and the slippery slope
The prof confirms that the slippery slope is very real. pic.twitter.com/LoqwzGZ7HY
— Christopher Snowdon (@cjsnowdon) November 6, 2025
Van Tulleken says the quiet part out loud. He wants warning labels on food because it will start a cascade of taxes and regulation. #slipperyslope pic.twitter.com/4XVdtwraSp
— Christopher Snowdon (@cjsnowdon) November 5, 2025
“We should just not advertise food.” pic.twitter.com/1EEerV7gtF
— Christopher Snowdon (@cjsnowdon) November 6, 2025
Opinion differs on what drives van Tulleken's increasingly demented campaign against brown bread. Some say he is a grifter trying to sell copies of his book. Others say he is an attention seeker. My view has always been that he has an unhealthy relationship with food and suffers from orthorexia nervosa. He casually mentions in his book that he has been known to make himself vomit so he can eat more food, i.e. he has (or has had) bulimia, but seems to think that this is perfectly normal.
Professor Van Tulleken bravely opening up about his eating disorder. pic.twitter.com/m8OwkBgjUb
— Christopher Snowdon (@cjsnowdon) November 6, 2025
Wednesday, 5 November 2025
Dewi Evans' unpublished letter to Private Eye
Private Eye's M.D. (Phil Hammond) is obsessed with the Lucy Letby case and has now published more than 30 lengthy (by Private Eye's standards) articles about it. They are getting rather repetitive so you'd think the magazine would be interested in some fresh content from someone who has an intimate knowledge of the case.
And yet when Dewi Evans, one of the key prosecution witnesses whom Hammond has bitterly attacked, wrote a letter to Private Eye, the editor chose not to publish it, although it did print a weird letter about the case from someone who inferred something from the way someone said something. Dr Evans has shared his letter with me and it is published below with his permission.
17 October 2025
Letters
Private Eye
The Editor
I am at a loss to understand Dr Phil Hammond’s excitable article in this week’s edition of The Eye, which relate to events surrounding the collapse and death of the infant known as Baby C.
The clinical facts are straightforward. Baby C was a tiny baby who was responding satisfactorily to treatment for pneumonia until his unexpected collapse. My preliminary report dated 7 Nov 2017 noted that “I have concerns regarding the unexpected collapse of [Baby C] at around 23.00 hr on 13 June 2015”. I added that “I would advise scrutinising the staffing present at the time”. Lucy Letby’s name as a ‘suspect’ was not known to me at the time, and there was no record of her presence in the infant’s clinical notes.
Cheshire Police’s attention to detail confirmed that the infant’s collapse occurred when in Lucy Letby’s presence, after the baby’s designated nurse had gone for a break. Lucy Letby’s involvement was noted in more detail in evidence given at the Thirlwall Inquiry [9 October 2024].
An x-ray taken 36 hours before the baby’s collapse noted a large ‘gas bubble’ in the stomach. The cause of the bubble has been the source of considerable discussion. Irrespective of its cause its presence cannot explain his collapse. Several clinical markers during the 36 hours after the x-ray was taken noted an encouraging improvement in his condition. His heart and breathing rates were within the normal range for a baby of his size. His oxygen saturations were in the high 90s. His oxygen requirements were falling, being just 25% just before his collapse. Encouragingly, he was deemed well enough to be taken out of his incubator for ‘skin to skin’ contact with his mother on the afternoon of his collapse and the day before.
An injection of air into the stomach would compromise the breathing of a tiny baby, quickly destabilising him. An injection of air directly into the bloodstream would be even more catastrophic. Whilst one cannot exclude the former the latter explanation is a more likely explanation for his collapse. One cannot rule out the possibility of his suffering from a combination of both. Either is indicative of inflicted injury, where the perpetrator would know that their action would place a vulnerable baby in harm’s way. This evidence led to the jury finding Lucy Letby guilty of the baby’s murder.
It's regrettable that Dr Hammond made no effort to get in touch with me prior to publishing his article. If he cares to get in touch with Cheshire Police, the CPS, or the Prosecution team, I am sure they would confirm the sequence of events I have described above, thus setting the record straight.
Sincerely
Dewi Evans
Tuesday, 4 November 2025
See you in Hell, European Alcohol Policy Alliance!
Eurocare announces closure of its Brussels office amid funding difficulties
The Board of Eurocare have announced that due to constraints on its funding it will no longer be able to maintain an office in Brussels and will be letting go its paid staff members from the end of the year.
The Commission confirmed in July that it would be scrapping its operating grants — cash that goes toward daily overhead costs like staff salaries — for all health NGOs, despite signaling to many organizations that it would continue to fund them this year.
Monday, 3 November 2025
The big lies of ASH
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| ASH News |
Big Tobacco is out in force telling retailers what to think about impending changes to the law.
As you may have heard, the government is phasing out the sale of tobacco to the next generation, which means by 2027 no one born before 2009 can be legally sold tobacco.We’ve all seen the articles and the adverts from tobacco manufacturers painting a picture of doom over these proposed changes. And behind the scenes, no doubt, there are countless emails, letters, and visits from company reps pushing the same message: that stronger tobacco regulation spells disaster for business.But the real burden on retailers isn’t regulation – it’s reliance on tobacco itself. Cigarettes might bring in footfall, but they deliver some of the lowest margins in retail, often just 6%. Smokers are quick, transactional customers; they buy their pack and leave.
By contrast, the same customers who quit smoking or switch to legal vapes tend to buy more, such as food to go, coffee, groceries and snacks. Every time that happens, both retailer and customer are better off.
When display bans and plain packaging were first introduced, the same scare stories were rolled out. Yet the evidence tells a different story. ASH’s retailer survey, conducted by an independent market research firm with 900 small retailers, found 74% said the display ban had no negative impact or even helped their business, and 75% said the same about plain packs. Retailers adapted and carried on trading successfully.
The illicit trade mythAt ASH we are not remotely complacent about the illegal tobacco market.
It brings crime into our communities, undermines legitimate trade and keeps people smoking. Illicit trade is a real issue – but it’s not caused by sensible regulation. In fact, illicit tobacco consumption has dropped by almost 90% since 2000-01, even as tax and regulation have tightened.
The best way to end the illicit trade in tobacco, possibly the only way, is to end the demand for tobacco.
Tobacco taxes backfire as black market cripples retail giantsAustralia’s two biggest supermarket chains have recorded a collapse in tobacco sales, blaming Labor’s aggressive tax hikes and the booming black market for hollowing out legitimate trade.Coles and Woolworths both reported more than 50 per cent declines in tobacco revenue over the past year – the sharpest fall on record – with the retailers saying cigarettes were priced so high that smokers have turned to untaxed, criminally supplied alternatives.
Woolworths revealed a 51.1 per cent plunge in sales for the first quarter, while Coles reported a 57 per cent decline, saying tobacco products now made up less than 2 per cent of total sales.“New tobacco legislation and growth in the illicit market led to a 57 per cent decline in tobacco sales compared to the prior corresponding period with tobacco sales this quarter now less than 2 per cent of total sales,” Coles noted in its first-quarter trading update.
Woolworths chief executive Amanda Bardwell said the decline in tobacco sales was “accelerating” when asked about the plunging figures during her full-year results announcement. “We’re still navigating some near-term challenges, particularly the material reduction in tobacco sales,” she said.
“It’s been well-discussed by others, but the decline in tobacco sales is accelerating and the current regulatory settings, and continued illegal sales, is evident in our performance.”
The collapse follows The Australian’s investigation into the black market, which revealed convenience stores recorded a $2bn collapse in legal tobacco sales.
Friday, 31 October 2025
Desperate gamblers?
85% of people gamble hoping for a big win. What makes you think they are desperate? Ever dreamed of winning the lottery and planning how you would spend it? The same survey found 72% gamble because it is fun. The moral panic around gambling is getting absurd. pic.twitter.com/H7SrlKnpk2
— Chris Fawcett (@chrisgambler247) October 30, 2025
Gambling ‘for the chance to win big money’ and ‘because it’s fun’ remain the most popular reasons given as to why respondents gambled.
Wednesday, 29 October 2025
Look Back in Anger: The Conservatives and the nanny state
I was on a panel at the Tory conference earlier this month discussing the nanny state with two (pretty sound) Conservative MPs. Much of it was given over to how dreadful the Tories were in office, and why not? Now let the healing begin.
Sunday, 26 October 2025
Tobacco prohibition and public opinion
FOREST have released the results of a survey they commissioned to gauge support for the generational tobacco ban that is the centrepiece of the Tobacco and Vapes Bill. The majority of respondents are, quite sensibly, against it. 59% of respondents said that people aged 18 or over should be allowed to buy tobacco.
Monday, 20 October 2025
The battle for the gambling levy millions
Last month the gambling journalist Zak Thomas-Akoo revealed that the UK Research and Innovation (UKRI) has been changing the terms of its grant applications under pressure from anti-gambling academics and campaigners.
Thanks to the mandatory gambling industry level, the UKRI has £10 million to distribute to anyone who wants to research "gambling and gambling-related harm". It's a huge amount of money for a niche academic area and "public health" researchers are fighting like rats in a sack to get hold of it. This is why people who have never written about gambling before have suddenly taken an interest in the topic. A slew of articles about why gambling should be treated as a "public health" issue have appeared in medical journals in the last couple of years, all of which have been characterised by ignorance about problem gambling as a psychological disorder and robotic incantations about treating it like tobacco (this is a particularly comic example).
Applications must be consortia based and must bring together diverse people, institutions, expertise, experiences, places, and wider stakeholders. This includes people with lived and learned experience from gambling and gambling related harms.
By lived experience, we mean people with direct experience of gambling related harms. Partnerships with non-HEI [higher education institution] organisations and people across the third sector, community groups, industry, and the public sector are essential.
I have now seen some of these letters (released under FOI). What they reveal above all is a sense of entitlement. The activists and academics simply assume that the only way to look at gambling is as a tobacco-adjacent commercial determinant of health and that the only suitable framework is the relatively novel, untested and ill-defined "public health" approach to "gambling harm".
These groups are essentially trying to bully the UKRI into excluding anyone who disagrees with them by pretending that the "public health approach" is the only game in town and that treating gambling disorder as a problem for individuals is socially unacceptable.
Gambling With Lives wrote a similar letter and I daresay several other people did too. This is the "swarm effect". If they repeat something often enough, they think it will become an established fact.
Partnerships with non-HEI organisations and people across the third sector, community groups, the public sector, and industry are essential and can contribute to diverse, innovative and cutting edge research, particularly in respect of the provision of industry data and commercial insights for the furtherance of research endeavours. By ‘industry’ we mean any enterprise that places goods or services on a market and whose commercial activities constitute more than 20% of its annual operations. This definition applies across all sectors and is not limited to organisations within the gambling industry. However, we absolutely recognise the sensitivities in respect of partnerships or collaboration with businesses, the gambling industry or otherwise.
That is why we are clear that any engagement with industry partners, especially those from the gambling sector, must be demonstrably independent, evidence-based, research-led, and aligned with the programme’s public interest objectives to further understanding of gambling and gambling-related harm.
Further, all proposals will be subject to robust scrutiny through our peer review and governance processes, with particular attention paid to the independence and integrity of the research, the source and independence of the findings, and the potential for real-world impact in understanding gambling behaviour and reducing gambling harms.
UKRI wishes to clarify that, as well as not being permitted to host awards, under the Research Programme on Gambling UKRI does not permit funding to be provided to Gambling Commission licence holders who are subject to the levy. We have also placed restrictions on co-funding from such organisations. Furthermore, UKRI would not expect individual researchers to concurrently hold funding from licence holders subject to the levy while receiving funding from the Research Programme on Gambling.
UKRI does not permit engagement with industries whose core business can be associated with harm to public health or societal wellbeing, in line with our ethical standards and harms-based exclusion principles.
Exceptions may be made for time-limited, purpose-specific interactions deemed essential to achieving legitimate and high-quality research objectives (for example, access to proprietary datasets or materials), provided that:
... Partnerships can take different forms including project partners or collaborating organisations. You must demonstrate how the partnerships within your consortium are equitable, have contributed to the development of your application including its conceptualisation, are not compromised by non-compliance with our conflict of interest policy, and will help the centre achieve its aims.
- there is no direct funding or co-authorship from the excluded entity
- the interaction is subject to robust ethical review and declared transparently
- appropriate safeguards are in place to prevent undue influence, reputational risk, or conflicts of interest
- the public benefit of the research demonstrably outweighs the risks of engagement
Saturday, 18 October 2025
Good COP 11
The WHO's Framework Convention on Tobacco Control Conference of the Parties (FCTC COP) will be held in Geneva next month. The media will be banned as usual so I'll be there for the Good COP conference down the road to offer a more enlightened view along with a stellar line up of experts. You can attend or watch online. Details here.
Friday, 17 October 2025
Banning cigarette filters?
Smokers would have to greatly overestimate the benefits of filters for a ban to provide a net benefit in public health terms, and I doubt they do. I expect most of them think they provide no protection at all. Most smokers have only ever known filtered cigarettes and they know that they are highly dangerous. In any case, making a product more dangerous in order to scare people off using it has got to be ethically questionable.
The anti-smoking lobby’s approach to this issue is all over the place. They were all in favour of the development of low tar cigarettes in the 1970s. They now say that was a mistake. Fair enough, but if it was a mistake why did they lobby for the EU to set limits on tar yields in the 1990s and then fight to lower those limits in the 2000s? They then successfully lobbied the EU to ban tobacco companies from putting the tar and nicotine content on packs because this information was (supposedly) misleading. Which is it? Either all cigarettes are as bad as each other, in which case get rid of the limits on tar and nicotine, or low tar cigarettes are safer than high tar cigarettes, in which case consumers should be informed.
Their current position seems to be that all cigarettes are as bad as each other and that filters should be banned because they give the opposite impression. If so, the EU’s limits on tar and nicotine serve no purpose and should be abolished. Indeed, they will have to be abolished if filters are banned because there is no such thing as a low-tar unfiltered cigarette. This is an issue that the authors of the Addiction article, who include ASH’s Hazel Cheeseman, never address. They can’t be dumb enough to think that the EU will accidentally ban cigarettes by banning filters and leaving the tar limits in place so they must think - if they have thought about it at all - that the EU will allow high tar cigarettes to be sold again. That would be fine with me. It’s just be a bit surprising that it’s also fine with an anti-smoking group.























