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Submissions

Each year ASH makes a number of submissions to government, parliamentary committees and other inquiries and consultations related to tobacco and smoking both in the UK and internationally.

Action on Smoking and Health (ASH) submission to the smokefree generation consultation

ASH supports:

  1. Raising the age of sale for all tobacco products by one year every year from 2027 onwards
  2. Tackling the rise in youth vaping by:
    (i) Prohibiting branding and brand imagery on vapes and vaping products which is appealing to children
    (ii) Including non-nicotine vaping products in the regulations
    (iii) Keeping vapes behind the counter in shops and prohibiting instore promotion
    (iv) Making vapes subject to excise tax to increase the price of the cheapest disposable products while ensuring they remain less expensive than cigarettes
    (v) Strengthening enforcement powers

ASH does not support banning disposable vapes or flavours because the risks of unintended consequences outweigh the potential benefits.

The ASH submission is supplemented by this supporting document.

See press release here.


To find out more about the consultation visit Creating a smokefree generation and tackling youth vaping 12 Oct - 6 Dec 2023

Action on Smoking and Health (ASH) submission to the call for evidence on vaping which closed on 6th June 2023

This call for evidence was subsequently followed up with the more detailed smokefree generation consultation which contains comprehensive recommendations from ASH.

See press release here.

See call for evidence on vaping here.

Action on Smoking and Health (ASH) and SPECTRUM representation to HMT 2023 Budget

In advance of the Budget on 15th March 2023, ASH and SPECTRUM submitted a joint representation to HM Treasury backed up by a Cost Benefit and Public Finance analysis of the cost of smoking and benefits of achieving the Government’s smokefree 2030 ambition.

Key findings

  • The cost of smoking to public finances (£21 bn) is nearly double the revenue raised by tobacco taxes (£11 bn)
  • Spending £125 million a year to deliver a smokefree 2030 could provide a net benefit to public finances of £5.3 billion by 2030
  • A cost-benefit analysis of this investment found a net benefit to society over 50 years of £827.8 billion.
  • Four Tobacco transnationals (PMI, BAT, Imperial and JTI) are responsible for around 95% of cigarette sales in the UK and the same proportion of deaths from smoking. They should be made to pay to deliver a smokefree 2030.

Key recommendations

  • Government should find the £125 million a year needed to implement the Khan review recommendations to deliver a smokefree 2030.
  • HMT should implement a corporation tax surcharge on tobacco manufacturers’ profits in this Budget, which could raise ~£74 mn.
  • Government should legislate to impose a ‘polluter pays’ levy on tobacco manufacturers to raise ~£700 million a year for the public purse.

ASH response to the Health and Social Care Committee inquiry into Integrated Care Systems: autonomy and accountability

In August 2022, ASH responded to the Health and Social Care Committee inquiry into Integrated Care Systems: autonomy and accountability. The NHS has a key role to play in achieving national targets to reduce smoking prevalence and tackle health inequalities. ICSs are central to these objectives, and it is vital that initiatives to tackle smoking and other preventable risk factors are prioritised and embedded in ICS strategies.

ASH and SPECTRUM response to DHSC consultation on the mental health and wellbeing plan

In July 2022, ASH and SPECTRUM, a public health research consortium of academics from 10 UK universities and partner organisations funded by the UK Prevention Research Partnership, submitted a joint submission to the Department of Health & Social Care call for evidence for the mental health and wellbeing plan. The submission recommends that the plan should prioritise reducing rates of smoking among people with mental health conditions to reduce the burden of mental ill health in society and improve the wellbeing of people living with mental health conditions.

ASH response to Welsh Tobacco Control Plan

In March 2022, ASH strongly welcomed Wales setting a target to go smokefree by 2030, broadly agreeing with their approach whilst making minor recommendations which would better ensure progress against this ambition

ASH response to DEFRA’s call for evidence on commonly littered and problematic plastic items

In February 2022, ASH responded to DEFRA’s call for evidence on commonly littered single-use plastic items. ASH called for the Government to introduce a fully regulatory Extended Producer Responsibility (EPR) scheme so that the tobacco industry pays for the costs of managing tobacco litter, including public education, clean up, and processing. ASH also called for the Government to consider a ban on tobacco filters and to do more to drive down the number of people smoking, including by introducing a polluter pays levy on the industry so that it pays for the costs of tobacco control.

ASH response to NHS England and NHS Improvement consultation on CORE20PLUS5

In November 2021, ASH responded to NHS England and Improvement’s consultation on the CORE20PLUS5 approach to addressing inequalities. Whilst broadly welcoming the overall model, ASH’s response highlighted the importance and commonality of smoking as a determinant of the five clinical health inequality priorities the CORE20PLUS5 model specifically seeks to address, and the need for more explicit direction to ICSs on the need to address smoking in order to reduce health inequalities locally and across the country. The submission was written by Nathan Davies, Specialty Registrar in Public Health.

Action on Smoking and Health (ASH) and SPECTRUM representation to HM Treasury’s Spending Review (SR21) and Budget

In September 2021, ASH and SPECTRUM, a public health research consortium of academics from 10 UK universities and partner organisations funded by the UK Prevention Research Partnership, submitted a joint representation to HM Treasury’s Spending Review (SR21) and Budget. The representation is organised around three key areas: strengthening the UK’s tax base, sustainable long-term funding for enhanced public health, and maintaining the UK’s position as a global leader in tobacco control.

Consultation response by ASH and SPECTRUM to the UK Product Safety Review: Call for Evidence

In June 2021, ASH and SPECTRUM responded to the Office for Product Safety and Standards consultation on the UK’s overarching product safety regulations, so that any prospective reform results in a product safety framework that is fit for the future – protecting people and supporting both growth and investment. Our response focused on concerns about the lack of appropriate regulation of novel nicotine products, in particular nicotine pouches.

Consultation submission by ASH, the Royal College of Physicians and SPECTRUM to Proposals for a Smokefree Aotearoa 2025 Action Plan: Discussion document.

In May 2021, ASH in collaboration with the Royal College of Physicians and the SPECTRUM Research Consortium submitted our response to the New Zealand Government’s consultation on proposed actions to achieve the Smokefree 2025 goal, which will inform the development of the Smokefree Aotearoa 2025 Action Plan (the action plan).

ASH and SPECTRUM response to the DHSC consultation on Tobacco and related products legislation introduced between 2015 to 2016

In March 2021, ASH and the SPECTRUM Research Consortium submitted a joint response to the DHSC consultation reviewing the effectiveness of the Tobacco and related products legislation introduced between 2015 to 2016. The submission, which concluded that the legislation had been effective, but could be strengthened, was underpinned by peer reviewed research carried out by SPECTRUM members. Set out in Appendix 1 of the document is a full list of the 32 recommendations made by ASH and SPECTRUM about how the regulations could be strengthened.

ASH and SPECTRUM budget submission 2021

In January 2021, ASH and SPECTRUM Research Consortium submitted a joint response to HM Treasury’s consultation ahead of the the 2021 Budget. The response’s recommendations focus on strengthening the UK’s tax base, securing greater investment in public health and strengthening the UK’s place in the world as a global leader on tobacco control.

ASH response to NHSE/I consultation on the next steps for Integrated Care Systems

In January 2021, ASH responded to a joint consultation by NHS England and NHS Improvement on the next steps for Integrated Care Systems (ICS) in England. ASH’s response agrees with the principle that ICS should be given statutory footing and makes the case for strengthening collaboration with local authorities to ensure ICS ambitions are met.

ASH recommendations to DHSC and PHE on a regional structure for public health following the abolition of PHE

In December 2020 ASH ran a round table which would focus on the regional structure, and address a set of questions set for us by DHSC and PHE. While the round table did not settle these questions directly, it did facilitate useful discussions about the pros and cons of different options with key stakeholders in the public health system. This note builds on the roundtable discussions to try to answer the questions and synthesise a regional model which can secure support across the public health system.

ASH response to Public Health England consultation on proposed changes to the calculation of smoking-attributable mortality and hospital admissions

In November 2020 ASH responded to a consultation issued by Public Health England (PHE) on changes to how the impact of smoking on mortality and hospital admissions is calculated. ASH’s response focuses on the need to take into account the full breadth of available evidence when determining the new methodology and also supports the submission made by the National Addictions Centre at King’s College London.