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OPINION

Impact Assessment (IA) Lead Department/Agency Stage Origin Date submitted to RPC RPC Opinion date and reference Overall Assessment Standardised packaging for tobacco products Department of Health Consultation Domestic 13/01/2012 22/02/2012 RPC12-DH-1229 AMBER

The IA is fit for purpose. Although no monetisation of costs and benefits is provided, the IA provides sufficient qualitative discussion of the main impacts to facilitate the consultation. However, the IA should provide more analysis to support the claim that the proposal will have an overall neutral effect on business. Identification of costs and benefits, and the impacts on small firms, public and third sector organisations, individuals and community groups and reflection of these in the choice of options Impact on business. Although no monetised impacts of the proposal are provided, the IA says that it is expected that the proposal will have a neutral effect on business (paragraph 58) as the initial one-off cost will be offset by the brandingrelated cost savings. Given the proposal is a restriction on business, the IA would benefit from further explaining why this is considered to be the case so that this assumption can be more readily tested during consultation. In the absence of any monetisation, the consultation will have to be used to seek additional evidence to provide robust estimates of the net impact of the proposal, particularly on business, at final stage. Effectiveness of proposal. The IA acknowledges that as a result of this proposal, there is the possibility that tobacco companies will decide to compete on other grounds, if they can no longer compete on branding. The IA should discuss clearly the risks of how tobacco manufacturers are likely to respond to the proposal in terms of achieving the policy objectives of reducing smoking. Furthermore, while the IA does acknowledge the current tobacco control policies, the IA would also benefit from explaining more clearly how this proposal will interact with these other recent proposals in this area, such as the ban on display of tobacco products at points of sale. This will allow the marginal costs and benefits of this proposal to be assessed at final stage. Have the necessary burden reductions required by One-in, One-out been identified and are they robust? The IA says the proposal is a regulatory measure (an IN). This appears to be consistent with the One-in, One-out Methodology. The IA should provide a robust estimate of the Equivalent Annual Net Cost to Business at final stage.

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Signed

Michael Gibbons, Chairman