Note for W B D Braarl ev
N,-4~,Jw L.
VI LH +
N &r-
The M~naqer~ of Recpllatorv 1-. ircl,,Air=
-%-t-icir= and Prcmo+-icn
1. RecTulat--Tv Issues
For the purpose of this note regulatory issues are
defined as:
(a) Tedmi-l issues +-,-t -n eli. ech Iv -ffect the
Droduct:
Additives
Cigarettze testing procedures
ceilings for the deliveries of individual
and
(b) Brnader i-es:
Advertisizg Restricticns
Packaging (prircipally health warnings)
Use of t-oba trade marks in other pro~ts
Product liability
smoking -restrictions i.e. public places,
workplace.
2. oblect-.-e
To mcnit= prcposed or actual new legislation
arising from US and Dirope-en
Regulat=ry Bodies, and to ensure that the Group's
views are taken into,
account charing the framing of new regulaticns.
3. (i) M-,o are the Prirr-ir-1 Re=latorv P-iies
(acting as agents of
Gmmrrmerrt) ?
Me following are examples of a long list
world-wide:
TM Dept. of Health and Human Services.
UK Dxlq~iL Scimitific 0oanittee.
Ncrwegian Medical Board.
F--rnish Medical Board.
New Zealand Tcxic Substances Board
Gcve==ent departments in Gen=V.
%aricus organizaticns in other European Countries.
Arab Health Izague
C-If Ministers Health Conference
4. &:~--sili-v Recrilatorv Pmies
Again the follading are exairples:
Gz-vernment (or Government approved) testing
laboratories.
:.n.terrat-ional standards organizations (IM).
CZREM (delegated role f3= ISO in respect of
cigarette testing). CD
Saub Arabia Standards Organization rIj
C-If Stan:Iards Organisation U-1
BATCo document for Province of British Columbia 25
October 1999


5. What am the current Mccutorina Svsterrs?
(a) Actual legislation
This is generally carried out by the industry
jointly chiefly through
organizations such as of CECCM and National
manufacturers Associations
(NMA,) and individually Uz-xjh political advisers,
-ternal lawyers
etc. This area is well covered and docxmented e.g.
Smoking
Status Book produced and updated by n07MB. In the
USA the BAT Gmup
does not belcng to the NMA (the TI) so that it
conducts its own
information gathering activities.
(b) Prcpcsed legislation
Monitoring prcposed legislation clearly depends an
establishing
ccrtacts with politicians, civil servants and
government advisers.
This is ca=ed out both at industry and company
level. Fiawever, BAT
cont,acts : to be s"trengtherx3d (Oi--m later).
Cbvicusly the
ease of mmitoring proposed ne-w legislation varies
from country to
country depending on the goverrmw7t's stance on
smoking and health
issues but there is generaUy advance wanurxj of
iupending legislation
and cpportuziity to respwd, with the possible
exception of 14jarne Past
countries sLx1i as Saudi Arabia. In the UK forzal
advance %;arning IS
given in the reports of the Independent Scientific
oommittee: inforzal
systems operate in Germany and in the EEC draft
legislation can be
identified at an appropriate stage in the Cczimi
icrV*Parliament/
Council circuit. In the USA the "Kennedy' bJ-U to
regulate the
irchistry has been circulated as a draft and in
New Zealand the report
of the Timac: Substances Board preceded the start
of the legislative
process-
6. How are the Gr--Is views on Drocosed new
recrilatiorm mnTentlv exDressed?
(i) Wh--e the irdustrv h- a view
(i.e. InIustry views coincide with BAT)
Generally they are put over with vigcur by NMAs or
CECCM arxI have had
sme effect on m=1ifying proposed legislation e.g.
in the UK, Germarry,
Denmark and New Zealand. M-vere is an iuplicaticn
that BAT -st be a
member of such organizations.
As yet, there has been a lack of si however, in
significantly
influencing the EDC in aiissels.
(ii) Where the irchLstrv does not have an
unanimous view
Fbr obvious reasons the industry tends not to have
unanimous views a,
issues where commercial advantage may result fram
a particular
regulatory decision e.g. inclusion of channel
ventilated cigarettes
within or without a standard smoking regim.
BAT necessarily use such ccnnec~cns with
politicians, civil servants
and government advisers as are available.
Generally such activitles
have been corilacted by BkT with reasonable
success, the most notable ~-n
examples being the ism of BAR= and regulatory
approval for the CD
use of additives, for example in the U.K. NJ
Lr
---J
CD
BATCo document for Province of British Columbia 25
October 1999


Ha,ever, the BAT Group do not have sufficient
contacts in all markets
(notably in the EEC) and better coordination is
needed across
cmpanies and departments. This is later.
7. Re-1-1.3atioris for manacrina i-- of Gr--
Stratecric TT=ortanr-e
rically issues have developed in particular
countries at different
t-i . The tendency has been for the local company
to develop a view,
pexhaps cross ctxbckuq with other BAT companies.
Problems have arisen where
there is inconsistency in cccpanies approaches in
different markets or where
a truly internatiarml strategy is required to meet
international problems.
it is thus that:
PRsponsibility for identifyiM issues should lie
with a noodnated
individual in each toba operating company
(including BAar-o) -
This person collects information about proposed
changes and coordinates
views from his own R&D, Public Affairs, Legal and
Marketing personnel.
He would then be responsible in the case of a
BATCo =cparry for infornung a
designated indivir"filal or ixtlivid-I within
Mill-bank. In the case of a CAC
company for liaising with the other CAC companies.
Those strategies having internatioral implicatian
or Group strategic
importance will be pr~~ for review by Messrs.
Bramley, Herter, Mercier
and Pritchard and a unified Group strategy is
determined, subject to TSRT
appraval. The 7MU will resolve any problems
arising from different local
strategies.
The agreed position will be presented to the
indivichml CAC companies.
In order to ens=e nore effective monitnx-ing and
lobbying it is also
reccrmnended that companies:
i. cmitirme to use CECCM and NMAs and all other
sources to obtain
information.
ii. maintain membership of CcFa=, focussiM our
activities with perhaps
fewer, more seruor people representing the BAT
Group.
iii. Maintain and strengthen dialogue with
standards organizations and
other influential bodies.
iv. identify additional third parties who are
formal or informal.
Government advisers and who are sympathetic to the
BAT view. (These
third parties are both to obtain information for
the BAT Group and to
put over the BAT Group view to Regulatory bodies).
v. Specifically to ident~y potential turd party
m4port in IMC
countries.
Rr-,---ndations for action bv BAqCo
i. Within BATCo inplement xUatians in section 7
above. C)
N)
Specifically: -
BATCo document for Province of British Columbia 25
October 1999


ii. BkTCo coapanies to establish contact with
politicians, civil
servants and government advisers on Regulatory
Ism, within a
policy framework established by BkTCo.
iii. Designated individual or individuals within
Millbank to maintain
ccrTtact (direct or delegated) with nominated key
personnel in Woo
c=panies and CAC ccmpanies.
iv. F=/AIH to advise the PDSG and senior
management of impending
legislation and its importance to BAIK)o (and the
BAT Group it
appropriate) .
V. in order to improve the capability of Group
Crupanies in handliM
these issues it is intended to circulate them at
apprupriate
intervals a review of current regulatory ism and
related BAT
Group policy guidelines-
I.zq
Dr R E Tho
RET/IEW
16 th May 1990
CD
rIj
CD
BATCo document for Province of British Columbia 25
October 1999