PRWeek has been made aware of several communications firms that help plan and organise influencer events and activities for tobacco giants and vaping firms.
The Advertising Standards Authority’s probe into the use of influencers includes seven posts on social media, including some by singer Lily Allen and House of Holland, and could have wider ramifications for social media platforms to "get their house in order", an ASA spokesperson confirmed.
Concurrently, PRWeek has been looking into how Big Tobacco firms use influencers and social media in marketing.
The ASA probe follows complaints by the anti-smoking groups Campaign for Tobacco Free Kids and other anti-smoking advocates, including Action on Smoking and Health (ASH UK) and Stopping Tobacco Organizations & Products (STOP).
They claim that British American Tobacco’s use of social media platforms – including Instagram, Twitter and Facebook – to promote Vype e-cigarettes "have been designed to maximise exposure of e-cigarettes to children, teenagers and non-nicotine users, in contravention of UK advertising regulations".
The UK has some of the strictest regulations in the world around e-cigarette marketing that prohibit online advertising of e-cigarettes, but allow a manufacturer to provide factual product information such as the name, content and price of the product on its own websites.
The ASA guidelines allow e-cigarette manufacturers’ social media accounts to provide factual content as long as it can only be found by "those actively seeking it".
"By advertising on Instagram, Twitter and Facebook, British American Tobacco will reach kids and young people," Campaign for Tobacco-Free Kids director of international communications Mark Hurley said.
"Tobacco companies like British American Tobacco use social media to promote their products because they think they can get away with it and because they know it reaches young people in the UK and around the world."
Deborah Arnott, chief executive of ASH, said the group challenged BAT about how responsible its e-cigarette marketing was at its recent AGM, "but did not get a satisfactory reply".
British American Tobacco (BAT) denies any wrongdoing and told PRWeek it has "strict controls in place to ensure that our communications are appropriate, in line with current regulation and target adult smokers and vapers".
Will Hill, BAT’s head of legal and external affairs, said: "Our response to the ASA will include independent data that we believe proves we take all reasonable measures to ensure our communications are targeted at adult smokers and vapers.
"It is disappointing that these three groups are attempting to influence the ASA’s process by pre-judging the outcome of an investigation they have not yet been able to complete. We believe the ASA’s team should be given the chance to conclude their investigation before we comment further."
The marketing of House of Holland's Vype collaboration for Fashion Week is also under investigation. This post instructing users where they can buy the product is under investigation.
Using ‘earned social media’
It is clear is that BAT, Philip Morris International (PMI) and other big tobacco firms are increasingly using influencers and earned media to market their e-cigarette products online.
BAT’s group head of corporate affairs Simon Cleverly said the company had a clear ambition to "lead the transformation of our industry by offering adult consumers a range of potentially reduced-risk products".
"If we’re going to transform the tobacco marketplace and make adult smokers aware of these new products, we need to communicate via the channels that they are using. As such, for these potentially reduced risk products, social media has an important role to play.
The company’s communications tactics focus on "developing compelling collaborations that we believe will generate earned social media coverage, which appeal to adult smokers and adult users of potentially reduced-risk products".
In the UK, this has included launching two projects for Vype and collaborating with fashion designer Henry Holland and singer Lilly Allen for its Vype ePen 3 device – both of which are now part of the ASA probe.
‘4.9 billion UK impressions’
BAT isn’t the only tobacco company in the firing line of anti-smoking campaigners. Last year, the non-profit organisation Campaign for Tobacco Free Kids released the findings of a two-year investigation into how tobacco firms use influencers to market their products.
The study analysed the use of 123 tobacco-related hashtags across social media.
Campaign for Tobacco Free Kids said these hashtags were viewed 4.9 billion times on Twitter in the UK alone.
Several hashtags that the investigation found had reached UK social media accounts linked to cigarette campaigns, including Lucky Strike’s #likeus, Marlboro’s #RedMoveNow, Kent Cigarettes’ #aheadBR and Winston’s #freedommusic.
This was done through influencers based in countries where cigarette marketing rules are more relaxed, but still have a significant UK follower base.
One product that features prominently in Campaign for Tobacco Free Kids’ research is PMI’s heated tobacco product iQOS.
The NGO said it had discovered at least 11 UK-based influencers who had posted or mentioned iQOS. The study found that in the year to 27 November 2018 #iqosUK was viewed by more than 1.2 million people over 3.9 million times on Twitter.
The #challengeyourimagination was set up by PMI's iQOS for the Formula One. The above post and the three below are not under ASA investigation.
PMI spokesperson Ryan Sparrow told PRWeek the influencers it works with must abide by a set of principles "to ensure responsible digital communications about our smoke-free products".
These include making sure digital communications programmes are in compliance with applicable local laws; that digital influencers are at least 25 years old; are adult smokers or users of smoke-free products; and that their areas of interest do not appeal to minors and target adults.
Digital influencers are also required to publicly disclose their relationship with PMI in communications about its smoke-free products.
"We analyse the audience of each influencer with the support of tools available for a particular platform, a good indication of whether the audience is predominantly adult. We review every engagement in advance, following a strict internal procedure involving people from different departments," Sparrow added, while also reiterating the company’s ambition is to help smokers move towards smoke-free alternatives.
When asked why PMI continued to sell cigarettes if it wants to move people away from smoking, he added: "Not selling our cigarette brands would solely result in our competitors selling theirs to our customers, with limited or no impact on people’s decision to switch to less harmful alternatives.
"Instead, we are scaling up our efforts to convince adult smokers, who don’t quit altogether to switch to smoke-free products, and our dialogue with all those who can help accelerate change, such as government, scientists, NGOs and all others who have a role to play in the change."
Popular UK influencers used #iQOSuk on social posts when invited by PMI to attend the Monaco GP.
At the heart of anti-smoking campaigners concerns are two key issues: whether tobacco companies are using deceptive tactics to reach consumers and position their brands, and whether this form of indirect marketing makes it easier for their marcoms to reach minors.
Social media platforms are clear that tobacco products cannot be advertised to promote the their sale or use, but more subtle techniques can be used that steer within these boundaries.
An example that Campaign for Tobacco Free Kids points out is inviting British influencers to last year’s Monaco Formula One (see images above) where they posted about the trip, but referenced iQOS and more vague hashtags like #challengeyourimagination, which is an iQOS initiative for Formula One.
PMI sponsors the Scuderi Ferrari and Ducati racing teams through its Mission Winnow initiative. The Mission Winnow website positions PMI as using ‘cutting edge science and technology’ to share research on tobacco harm reduction.
Another example that Campaign for Tobacco Free Kids shared was a BAT campaign in Brazil to reposition Dunhill cigarettes to younger audiences using an ‘unbranded platform’ called Taste The City (see above). The campaign was created by Geometry, a subsidiary of WPP that focuses on tobacco marketing.
In response, BAT told PRWeek: "In Brazil, on the back of the Campaign for Tobacco Free Kids’ allegations, investigations by the Public Prosecutor Officer and the Brazilian Consumer Protection Agency have commenced and Souza Cruz is cooperating with those agencies, has provided them with relevant information, and firmly denies any illegality in its actions."
Geometry is one of four marcomms agencies, including Beagle Media, Flat White Communications and The Social PR, that Campaign for Tobacco Free Kids found were involved in tobacco product marketing on social media.
Comms leaders PRWeek approached declined to comment on the record about how the industry works with tobacco companies, but one agency source who has previously worked with tobacco firms said they err on the side of caution.
"If there’s a black and a white and then a grey, we will never even enter into the grey. We have been so, so careful in terms of everything we do that we don’t even come close to activities we could probably get away with," the agency source said under the condition of anonymity.
"Where you might see tobacco products on social is at events where influencers will post, but they are not paid or asked to do that.
"The company that has got into the most trouble is Juul (vaping products) and you see people [breaking the rules] out of ignorance. The two major players, BAT and PMI know what they are doing and generally wouldn’t do anything that goes against those [Tobacco Products Directive]."
The ASA probe is expected to take a few months. The five other Instagram posts under investigation are: