A Special Newsletter from the ENSP & Impact Unfiltered

Welcome back to Policy Unfiltered - a newsletter from ENSP and Impact Unfiltered, where we deliver analysis on EU tobacco control policy to support advocates across Europe.

The integrity of the Tobacco Tax Directive (TTD) process is under threat.

In this edition we uncover the flaws across multiple crucial areas: industry-flooded responses for the TTD public consultation, the FISC hearing's lack of balance, intense lobbying practices and positions taken at ECOFIN. Lastly, we provide the economic defense required to gain a footing in Europe's dominant language of competitiveness.

From 3 September 2025, we analysed all 18,480 submissions to the TTD public consultation.

What we found:

• 7,770 near-identical, copy-paste entries (42% of total) recycling scripts on "illicit trade" and "harm reduction"

• ~6,000 replies use "reduced-risk/less harmful/safer alternatives" language

• 2,500 explicitly mention "harm reduction"

• 6,700 contain harm-reduction signals

Template text. Repeated claims across languages. This looks less like citizen input and more like coordinated astroturfing designed to bend the evidence base.

The contrast: Real public health organisations? Fewer than 80. That's 0.3% of all submissions.

Our exposé on the consultation flood was covered by POLITICO, detailing how the 'EU tobacco tax hike plan [was] ‘swamped with pro-industry feedback'.

The European Parliament's 20 November FISC subcommittee hearing on the TTD featured a disproportionate focus, resulting in the clear amplification of industry positions.

• Low Political Attendance: Just 7 of the 30 committee members attended, with no representatives from S&D, Renew, or Green groups. Four of the attending MEPs had held tobacco industry meetings in recent weeks or months.
  
  

• Skewed Participation: Industry representatives received 37 minutes of total speaking time versus 25 minutes for health experts.
  
  

• Aligned Questioning: MEPs with recent industry contact posed questions that closely reflected industry submissions. For example:

  • Marco Falcone (EPP, Forza Italia), who had held five meetings with industry (including two on 5 November alone) asked questions that mirrored phrasing in Imperial Brands' submission.

  • Denis Nesci (ECR, Fratelli d'Italia) asked whether taxes threaten "EU industrial and agricultural protection," a concern echoed by Italian growers' and tobacco associations Filiera Italia and UNITAB.

• Rapporteur Influence: The TTD rapporteur, Tomáš Kubín (Patriots, Czechia), held three recent meetings specifically on the directive with Philip Morris, Tobacco Europe, and the European Cigar Manufacturers Association.
  
  

• FCTC Conflict: The hearing gave Tobacco Europe—the Brussels lobby arm of the industry—a prominent platform, and Prof. Francesco Moscone’s presentation closely tracked industry positions. This occurs despite the EU's legal requirement under WHO FCTC Article 5.3 to protect health policy from industry interference.

Today, POLITICO covered our in-depth analysis of the hearing, as well as the story on fake submissions in the names of Moldovan health professionals without their consent.

We’ve developed a tool to track meetings between the tobacco industry and Members of the European Parliament, providing real-time intelligence on lobbying activities.

Our findings are telling. 

Tobacco industry lobbying has exploded. Since the new Parliament took office (July 2024) the monthly average of MEP-tobacco industry meetings has surged by approximately 57% (rising from an average of 14.7 per month to 23 per month). 

Better declaration compliance or actual surge? Possibly both. What's certain: the industry shifted into high gear around the TTD vote.

The targeting is strategic: EPP leads with 34% of meetings, but Patriots for Europe punches above its weight at 17% - and holds the TTD rapporteur role.

Meet TTD rapporteur Tomáš Kubín (ANO 2011, Czech Republic), who has met the tobacco industry three times since March 2025:

• 1 October 2025 on “TTD categorization discussion” with the European Cigar Manufacturers Association

• 15 July 2025 on “TPD review meeting” with Tobacco Europe AISBL

• 18 March 2025 on “Position explanation” with Philip Morris International.

How do we know: 

We track declared meetings using public European Parliament data and the EU Transparency Register. This captures only scheduled, public meetings, informal lobbying is invisible. So these figures are a floor, not a ceiling.