Tobacco Documents Online

-11- [Tobacco] companies.., understand that many of their consumers would like to quit but are unable to do so. [Citing, inter alia Project Plus/Minus, p. i.] D. 60 Fed. Reg. 41671 & n.346 Market research documents also show that tobacco companies have conducted research in quitting behavior and have documented the reasons why people quit and why they fail to quit, despite a desire to do so. [Citing Project Viking Vol. III and Project Plus/Minus pp. 41-51] COMMENTS: The study makes no mention of advertising as a motivating or recruiting device among young people. Although the study explores the difficulties • cited by these respondents in quitting, it concludes that the psychological and social factors are much more responsible for those difficulties than physical factors. The study overall demonstrates that reasons for smoking are a complex mix of factors. To the extent the study is cited to demonstrate B&W's "knowledge" of the difficulties of quitting, it would be helpful to know why ITL authorized the study and how it was or was not utilized. V. DOCUMENT: DATE: BY: FOR: Project 16 October 18, 1977 Kwechansky Marketing Research Inc. Imperial Tobacco Corp. SUMMARY: Project 16 was a marketing study conducted using four discussion groups of smokers aged 16 and 17 in Toronto and Petersborough, Canada. At the time of the study, the legal smoking age in Toronto was 16. See p. 32. The study notes that, while social pressures against smoking had increased over the preceding decade, teen smoking remained constant or increased. Noting that "how the beginning smoker feels today has implications for the future of the industry," the study sought to "learn everything there was to learn about how smoking begins, how high school students feel about being smokers, and how the foresee their use of tobacco in the future." [p. 1]. The researchers encouraged the groups to discuss how they became smokers and how they felt about smoking. [p.2}. The participants were also shown a series of advertisements for both tobacco products and other products and asked for their reactions. [p.3]. The majority of the 97-page report is taken up by quotes from the participants. The conclusions reached are fairly mundane -- the major factor behind youth smoking is peer influence and the desire to be part of a group; the "forbidden" nature of the 566628851

- 12- product also provides dome attraction, as does concealing it from parents. Smoking is also used by teens as a way to pass the time, and as a social prop or crutch. The study finds that most teenage smokers begin "serious" smoking at the age of 12 or 13. [p. 12]. While defiance of parental authority did not, according to the study, constitute a significant factor in starting, the subsequent conflicts were found to create familial hostilities that might not otherwise exist. The study also indicates that some teens "regret" the fact that they began smoking. This regret stems from the fact that smoking has now become a habit; that their early belief that "they could experiment with cigarettes and not, as they put it, 'get hooked;'" that "they are in a distant sense concerned with smoking and health;' an that social pressures made them feel "second class" as smokers. [pp. 65-66]. The study indicates that over half of the participants wanted to quit 'someday" and that some had attempted to quit and found it difficult. [pp. 70-71]. (As the focus groups were limited to current smokers, those teens who had successfully quit were not represented.) The study indicates that the failed quitters interviewed return to smoking for many of the same reasons as adults. "It could be a time of stress, feelings of depression, seeing others smoking, and so on. All of these things and more conspire to break the quitters [sic] resolve." [p. 71]. The section regarding teen attitudes concludes: Smoking seems to feed on itself. The adolescent treats it as a thrill, a part of breaking away. The teen is "hooked,' admits the risks, but smokes anyway. Barring a drastic shift in adolescent attitude, or drastic governmental action, smoking will be around for a long time to come. The cycle seems extremely difficult to break. [pp. 81-82]. With regard to advertising, the study found that most respondents viewed it "as always self-serving and often false." [p. 87]. The study characterizes the respondents as "cynics about the glamour that they perceive advertising is trying to link to ordinary products" I[~.]. The study contains an anecdote of one respondent reacting negatively to a cigarette ad which she interpreted as attempting to make cigarettes look "glamorous." She responded "how could it be? They show it one way and then you walk down the street and see some old bum puffing on one." [p. 88] FDA REFERENCES: A. 60 Fed. Reg. at 41330 and n. 120 [R]esearch conducted for a Canadian affiliate of one U.S. cigarette firm focused on the need to attract young consumers, stating: 566628852

- 13- Ads for teenagers must be denoted by a lack of artificiality, and a sense of honesty. Attempts at use of celebrities * * * do not seem to really click. If freedom from pressure and authority can also be communicated, so much the better. [at p. 97]. The bulk of Project 16 appears directed at a fairly innocuous discussion of reasons youths began smoking. The effect of advertising on that decision is never even discussed. The decision by the researchers to include a discussion of teen reactions to various tobacco and non-tobacco advertisements, however, may be construed as demonstrating an intent to reach the youth market. However, all respondents were of legal smoking age. More importantly, the study concludes that teens react cynically to the glamorizations of "ordinary products," including tobacco, in advertising. [p. 87-88] Information on how the advertising conclusions, as well as the report as a whole, were utilized would be helpful. B. 60 Fed. Reg. at 41331 & n.145 Cigarette manufacturers are also aware of the difficulties young people encounter when they try to quit smoking. Studies prepared for a Canadian affiliate of a U.S. cigarette company state: . However intriguing smoking was at 11, 12, or 13, by the age of 16 or 17 many regretted their use of cigarettes for health reasons and because they feel unable to stop smoking when they want to. [Quote repeated at 60 Fed. Reg. 41671-72 & n.348 as part of jurisdictional analysis] C. 60 Fed. Reg. at 41670 & n.339 [Tobacco] companies.., understand that many of their consumers would like to quit but are unable to do so. [Citing, inter alia Project 16, p. vi.] COMMENTS: FDA attempts to bootstrap research into "difficulties encountered in quitting smoking" into a conclusion that cigarette companies knew that nicotine was physically addicting, a gross oversimplification. The study as a whole indicates that the decision to begin and continue smoking is a complex one, largely driven by factors of peer pressure and social comfort.

- 14- VI. DOCUMENT: DATE: BY: FOR: Matinee Marketing Plans 1971 unknown unknown Imperial Tobacco Corp. SUMMARY: Generally deals with plans to capitalize on Matinee brand's low tar content to increase market share, predicting that high tar smokers will trade down as health concerns and social pressures increase. FI)A REFERENCES: A. 60 Fed. Reg. 41688-89 & n. 384. A report by ITL also focused on the importance of developing low-yield cigarettes that address smokers' concerns about health, but that nevertheless provide the desired "physiological satisfaction": "A cigarette that delivers physiological satisfaction, yet is low in T & N, must surely be a major objective and represents an R&D challenge." COMMENTS: FDA cites the report in the midst of a discussion pointing out tobacco company research seeking to maintain levels of nicotine in cigarettes while reducing tar (a concept actually tested to consumers with little positive response in Project Day). The instant report discusses ITN's desire to market its pre-existing Matinee brand emphasizing the low tar and nicotine content "in a positive manner in relation to smoking and health considerations." Report, at 2. There is no discussion regarding manipulating nicotine levels, and tar and nicotine are never distinguished within the report. FDA contorts of the use of the word "physiological" to have a medical or scientific connotation not contained within this marketing report.