TRA letter to the Welsh Assembly on their plans on retail density using data from the registration scheme.

22nd November 2017

Ms Rebecca Evans AM
Minister for Social Services and Public Health
National Assembly for Wales
Cardiff Bay
Cardiff
CF99 1NA<

Dear Ms Evans,

I am writing to you in my capacity as the National Spokesperson for the Tobacco Retailers’ Alliance (TRA). The TRA represents and campaigns on behalf of legitimate retailers who sell tobacco products in a legal and responsible way including throughout Wales. As an organisation, the TRA is committed to raising awareness about tobacco-related issues that affect small and independent stores across the UK.

I am writing regarding the proposal in the Welsh Government’s recently published smoking strategy that it would use information and evidence gathered from the tobacco retail registration scheme to ‘examine the density of tobacco retailers’.

When the Assembly Government introduced the retailer scheme there was no official statement or confirmation that such a scheme would lead to a review of density. I am concerned that a scheme designed to combat the illicit trade in tobacco (that the TRA indeed supported) has seemingly been introduced under the pretence of looking at a way of controlling and restricting the number of independent retail outlets. I am extremely disappointed and concerned that the Welsh Government has adopted this approach ‘by the back door’ bypassing any scrutiny.

The only individual I believe who mentioned the potential of making such a connection was the representative of Public Health Wales who appeared during the scrutiny stages of the Bill undertaken by the Assembly’s Health Committee.

I wrote to Dr Julie Bishop in December 2015 asking for both her interpretation of her comments and the evidence she had used to make such an assertion. Dr Bishop responded in January 2016 stating that the evidence and literature available, including from international sources, relating to the influence of smoking prevalence and consumption was inconclusive.

Therefore, I would like to know on what new basis and in respect to the supporting evidence, the Assembly Government has now deemed it appropriate to move forward with this examination. I would welcome the opportunity to review the research you used to base this statement.

Furthermore, I would welcome an indication of the timetable for completing this examination, who it will be conducted by and which groups will be involved and consulted.

I would point out that tobacco makes up around 35% of the turnover of many small, independent stores. Despite the un-evidenced assertions of some in the public health lobby, these shops depend on tobacco for their continued economic survival acting as it does as an important footfall driver. For many communities across Wales the local shop is quite often the only community asset that exists offering many other services such as a post office. Again, it is a fact that legal tobacco sales help to sustain such resources that would not otherwise exist.

I would like to know therefore what discussions you had with the relevant business communities throughout Wales on this proposal before it was announced and what the subsequent plan is to involve them in it. What discussions did you have with the Assembly Government’s own economic development department, the Welsh business minister and the Secretary of State for Wales? I also believe that it crucial that the voice of local communities are also heard as well; were such groups consulted before this announcement was made?

I would also point out that the black market would simply fill the void if the numbers of legitimate businesses were forcibly reduced especially given with around 40% of smokers in Wales already regularly buying from illicit sources. Such a move would do nothing to stop this supply and would simply penalise legitimate retailers. What assessment did the Assembly Government make on the impact of illicit sales before in announcing this plan?

I would also highlight that increasingly children are accessing tobacco through illicit means given the widespread availability of illicit tobacco. Such concerns about the scale and damage of the illicit trade are also highlighted by others. The group Fresh North East on 1st November published the results of a survey that found that children were increasingly accessing illicit tobacco as their primary source. 55% of children aged between 14 and 15 who smoke say they buy illegal from sources such as ‘tab houses,’ while 73% say they have been offered illegal tobacco.

Given the concerns I have over how this review was made and announced I would welcome an opportunity to meet with you to discuss my members’ concerns. I will also be sharing the contents of this letter with wider business and retail communities in Wales, members of the Welsh Assembly and Welsh MPs and, given the obvious wider public interest, making it available on TRA website.

I look forward to your response on the points I raise above.

Yours sincerely,

Suleman Khonat,
National Spokesperson,
Tobacco Retailers’ Alliance
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