“Being Politically Active Doesn’t Have To Be Difficult.” A Content Analysis of Tobacco Industry Sponsored Advocacy Websites.

Abstract

Objective.

To characterize the thematic content of tobacco industry sponsored advocacy websites in the United States and to compare these sites to identify differences in products, target audience, policies or themes.

Methods.

In 2017 US-based Google and purposive searches identified six US tobacco industry sponsored advocacy websites. A coding guide based on existing literature, tobacco policy issues, and iterative review of the websites was developed and, descriptive analyses of themes on individual websites and overall were conducted.

Results.

We identified 18 themes; the most common of these were: tobacco taxes (13.9%), providing advocacy resources (10.6%), and pleas for action (10.3%). Related themes were aggregated into four broad categories: advocacy (36.7%), taxes (31.4%), legislation is excessive or unnecessary (21%), and support for weaker tobacco control policies (10.9%). Websites targeting consumers provided more resources to facilitate advocacy than websites targeting retailers.

Conclusions.

Websites promoting pro-tobacco advocacy are an important and evolving strategy for the tobacco industry. Websites are particularly well suited to leverage marketing activities (e.g. building relationships with retailers and consumers) to achieve policy objectives. Monitoring these tactics may allow advocates to counter and anticipate industry opposition to tobacco policy.

INTRODUCTION

Tobacco control policies are instrumental to reducing tobacco use.[1, 2] US cigarette smoking rates are currently the lowest in 52 years following enactment of policies,[3,4] including tobacco taxes, smoke free policies, tobacco marketing restrictions, enforcing age of sale laws, and banning flavored cigarettes. Current policies in the US include efforts to increase the age of sale to 21, prohibition of price discounts and coupon redemption, limiting pack size for little cigars/cigarillos, and prohibiting sale of flavored and menthol tobacco products.

The tobacco industry and pro-tobacco groups have a long history of opposing tobacco control policy utilizing coalition management, production of information to influence public opposition, and direct involvement in the policy process.[5]Media produced by the tobacco industry can reveal particularly incisive and specific insights into strategies used to defeat tobacco control policy. Cardador et.al. analyzed major themes from smokers’ rights magazines published and distributed by tobacco companies between 1987–92 and identified four broad themes (perceived threat, undermining the opposition, creating legitimacy, and political and social action).[6] The study concluded these publications were produced to protect tobacco sales and profits by attempting to refute scientific evidence supporting tobacco control, and to motivate and provide resources for their readers to advocate for policies supported by the tobacco industry.

There have been significant changes in the tobacco marketplace in the more than 15 years since this study, including the introduction of new products (e.g., vaper products), established products marketed in new forms (e.g., smokeless tobacco pouches), increases in flavored tobacco products (e.g. little cigars and cigarillos), and new media to reach the public. To our knowledge, no research has systematically examined tobacco industry websites focusing on tobacco policy. In this study we identified and analyzed the content of 6 tobacco rights websites sponsored by major US tobacco companies and/or trade organizations to identify the websites’ target audience, arguments against tobacco control policies, efforts to activate tobacco users and retailers, and provision of tools to assist in countering policies and contacting policy makers. To date, there has been little research into tobacco industry efforts to influence policy through pro-tobacco advocacy websites in the US. Prior research has focused on tobacco industry-funded advocacy organizations, or advocacy activities in print media such as magazines. The most recent study of such activity dates to 1995, a content analysis of tobacco industry sponsored “smokers’ rights” magazines in the US [6] Little attention has been paid since to tobacco industry sponsored efforts to influence and activate resistance to tobacco control initiatives, though such pro-tobacco activities have continued.

The overall objectives of the study were to (1) characterize the thematic content of tobacco industry sponsored advocacy websites in the US, and (2) compare the different sites to identify differences in products, target audience, policies or themes.

METHODS

Sample Identification

In January 2017, US-based Google searches were conducted using the terms: tobacco rights, cigar rights, vaper rights, and smoker’s rights. Review of the first four pages of results from each of these searches identified 18 tobacco advocacy websites of which four (22.2%) met the following inclusion criteria: (1) content includes pro-tobacco information and tools to facilitate advocacy for tobacco consumers, retailers, or both, (2) direct sponsorship by a tobacco manufacturer or trade association including tobacco manufacturers, (3) a US based organization, (4) does not directly advertise tobacco products. Two of the websites meeting these criteria (Citizens for Tobacco Rights,[7]and Vaper Rights ][8]) were aimed principally at consumers, while two others, (Cigar Rights of America,[9] and Transform Tobacco) [10] addressed both consumers and retailers.

To increase representation of websites aimed specifically at retailers, we conducted a purposive search for pro tobacco policy websites through online searches of corporate tobacco websites, online tobacco retailer trade magazines and recommendations from tobacco control experts. Two of these met the inclusion criteria. These were (Tobacco Issues[11] and Tobacco Ordinances).[12]All sites were reviewed and recorded January 2017 and coded in February - March 2017. As websites are complex in structure and content changes frequently, we preserved all websites using screen-shots of every webpage contained on the site.

Coding Guide Development and Coding Procedures

Each mention of thematic content contained in website text, banners, embedded videos and supplemental PDF attachments was recorded following a coding guide based on existing relevant literature,[5, 13]current tobacco control policy issues and advocacy, and through iterative review of the six study websites.[14] An initial coding guide was reviewed by the research team and codes and definitions refined and retested to generate consistent definitions and examples (Table 1).

Table 1.

Theme and Category Frequencies for All Websites combined

Theme	% Total Mentions
Category: Facilitating Advocacy 36.7%
Providing Resources for Advocacy	10.60%
General Pleas to Take Action	10.30%
Contact and/or Vote for Elected Officials	8.80%
Join or Donate for Advocacy	4.20%
Use Social Media for Advocacy	2.80%
Category: Taxes 31.4%
General Tobacco Taxes	13.90%
Misuse of Tobacco Taxes	7.60%
Tobacco Taxes Lead to Revenue / Job Loss	6.30%
Tobacco Taxes Lead to Crime / Bootlegging	3.60%
Category: Legislation is Excessive or Unnecessary 21.0%
General Tobacco Legislation	5.90%
Marketing Restrictions	5.40%
Provide Alternative Strategies to Existing Regulations/Legislation	4.60%
Public Bans on Use	2.30%
Flavor Ban/Menthol Ban	2.10%
Tobacco User Discrimination	0.70%
Category: Support of Tobacco Control Policies 10.9%
Underage Prevention and Retailer Age of Sale Compliance	4.90%
Links to Outside Tobacco Control Agencies	4.40%
Harm Reduction/Cessation	1.60%
TOTAL	100%

In developing the codes and coding guide we first conducted a literature search of issues and tobacco industry activities and strategies to influence policy and recorded each issue and strategy as a potential code. We also utilized the coding scheme from a prior content analysis [6] and added additional strategies that were identified in the literature.

In developing the guide we included codes addressing issues of particular interest to pro-tobacco advocates such as concerns over bootlegging of tobacco products, discrimination against smokers, flavor and product bans, taxation and how tobacco tax money is spent as well as pending legislation or policy initiatives.

Next, we conducted a preliminary review of the websites with the draft code book to clarify how codes were defined and identified, and to select exemplar quotes for each code. We identified areas where additional codes were needed or code definitions that needed to be clarified or modified. We continued this process iteratively for each of the six websites.

Finally, we took the revised codebook and double-coded all the websites. The coders met regularly to compare coding results, identify and resolve discrepancies, and revise or clarify the code book if necessary. Differences in coding were discussed and resolved by consensus or, if necessary, adjudication by a third reviewer. All websites were double coded by the trained coders. We utilized this process of iterative review and consensus to achieve reliable and valid coding, although we did not calculate formal measures of inter-rater reliability, as all points of disagreement were discussed and resolved.

Each page of each website was double coded by trained coders. Two research assistants met regularly to compare coding results, identify and resolve discrepancies, and revise or clarify the code book if necessary. Differences in coding were discussed and resolved by consensus or adjudication by a third reviewer.

We followed standard content analysis practices described by Weber [15] and utilized by Cardador and Glanz [6] in the prior analysis of tobacco industry smokers’ rights publications. For our study a mention was defined as a discrete theme or idea represented by a phrase reflecting a single idea. A mention might or might not be a sentence (i.e. could be a banner headline or one in a list of bullet points). A single statement that contained more than a single idea or mention could be divided and coded for each mention.

For example, the sentence “call your Senator today to stop the government from banning flavored cigars” includes mentions of both the “contact and/or vote for elected officials” and “flavor ban/menthol ban” codes. During coding, we identified illustrative examples of content for each code. The themes were subsequently grouped into four broad categories: “Facilitating Advocacy”, “Taxes,” “Legislation is Excessive or Unnecessary” (general opposition to tobacco control or regulation other than taxes) and “Support for Selected Tobacco Control Policies”. The percent of total mentions for each theme and the category were tabulated.

Analysis

The number of mentions within each theme was summed for each website. We then performed a descriptive analysis by dividing the number of mentions in the themes on each website by the total number of mentions of all themes across all the websites (N = 1992). Because we anticipated differences in concerns or issues by website due to product nature, target audience, or policy we also examined the data by website, dividing the number of mentions for each theme coded for that website by the total number of mentions in each website.

RESULTS

Of the six websites, three were sponsored or affiliated with Philip Morris International. Two of the PMI websites focused on consumers, with one emphasizing smoking and smokeless tobacco (Citizens for Tobacco Rights), and the other on e-cigarettes (Vaper Rights). PMI also sponsored one website focused on retailers (Tobacco Issues). Reynolds American sponsored a single website that included both consumers and retailers (Transform Tobacco). Of the remaining two websites, one was sponsored by the International Premium Cigar and Pipe Retailers (IPCPR) and targeted both consumers and retailers but focused exclusively on cigars (Cigar Rights of America), and one sponsored by the National Association of Tobacco Outlets and Swedish Match (Tobacco Ordinances) focused exclusively on retailers but included a wide variety of tobacco products

The home page of each website included opportunities to sign up to receive further information such as updates on tobacco policy issues, and signing up was encouraged but not required to access the site. None of the websites required age verification.

The theme and category frequencies for each website, is presented in Table 1. (This information, plus code definitions and examples are presented in the supplementary tables.)In all, 1992 mentions were coded on the six websites with distribution as follows: Transform Tobacco (566), Cigar Rights of America (457), Tobacco Issues (297), Citizens for Tobacco Rights (274), Tobacco Ordinances (261), Vaper Rights (137). The category with the highest number of themes coded was Facilitating Advocacy (36.7%) followed by Taxes (31.4%) Legislation is Excessive or Unnecessary (21%) and Support of Selected Tobacco Control Policies (10.9%). Overall, general tobacco taxes was the most mentioned theme (13.9%), followed by providing resources for advocacy (10.6%) and general pleas to take action (10.3%).

Facilitating Advocacy

Themes in the category “Facilitating Advocacy” focused on encouraging tobacco consumers and retailers to become involved in the political process, often calling for advocacy in broad terms like “take action now” and “speak out”. Many also included warnings about policies under consideration that would increase taxes or limit tobacco marketing.

The worst case scenario of FDA regulation is now a reality. It is now more important than ever that everyone’s voice is heard in opposition to FDA regulation. Take action now and contact your members of the US Senate and respectfully ask them to support exemption language for premium cigars. (Cigar Rights of America)

Activate your employees. The livelihood of each employee is directly impacted by decisions made by legislators. Encourage employees to make their voice heard (Transform Tobacco)

In addition to encouraging advocacy; five websites (all but Tobacco Ordinances) facilitated it by providing resource tools and tips for use in advocacy efforts (Table 2).

Table 2.

Advocacy Tips and Tools Provided on Websites

Advocacy resource tools	CTR	Vaper	CRA	Trans form	TobI ss	Tob Ord
Contacting representatives	X	X	X	X	X
Links to reps’ email and website, phone number	X	X	X	X	X
Sample letter with addresses	X	X	X	X	X
Sample email	X	X	X	X	X
Sample script for phone call				X	X
Sample script for in-person meeting					X
Calls to vote	X		X	X
Links to voter registration	X		X	X
Links to candidates in upcoming election	X		X
Specific state and local issues		X	X	X	X
Links to reps in districts with issues			X		X
Sample letter tailored for issue			X		X
Sign up for alerts (email, text) about issues		X	X		X
Signing petitions		X	X
Link to petition		X	X
Attending meetings					X
Sample script for attending meeting					X
Tips for speaking at meetings					X
Media engagement	X		X	X	X
Links to local media contact info			X	X
Tips for contacting media					X
Sharing news with social media followers	X		X	X
Links to site sponsored social media	X		X	X
Scripted post to share on own social media	X
Contacting friends to join cause	X		X	X	X
Link to send scripted email to your contacts			X	X	X
Joining or donating to the cause	X	X	X			X

CTR = Citizens for Tobacco Rights, Vaper = Vaper Rights, CRA = Cigar Rights of America, Transform = Transform Tobacco, TobIss = Tobacco Issues, Tob Ord = Tobacco Ordinances

Website resource tools were frequently displayed with larger fonts and short titles. A single click on these resources frequently linked to PDF files with more detailed information.(see Figure 1).

Figure 1.

Screenshots of Selected Advocacy Tips and Tools Examples from Websites

The most common tools were links to contact elected officials and providing examples of scripted letters or emails. Four of the six sites offered specific information on state and local issues with direct links to elected officials in those districts and sample letters regarding that issue. Only three websites encouraged voting and provided links to voter registration; two of the three sites provided links to all the candidates in an upcoming election and where they stood on tobacco issues.

Invite your legislator to meet you and your employees at your place of business to discuss issues of importance. Make the visit a photo opportunity. Following the meeting, send a thank-you note and use the note to recap your discussion and key points. (Transform Tobacco)

In terms of working with media, four of the six websites offered tips and tools to disseminate tobacco advocacy information to television, radio, print, and social media. These were commonly available as downloadable PDFs such as fact sheets or talking points.

. . . One good way to let others know about important issues is to write a letter-to-the-editor or call into a local radio show. The links below will provide you with tips on how to effectively make your voice heard through the local media. . . . (Tobacco Issues)

The websites also offered guidance on how to use social media such as Facebook and Twitter and linked to social media sites and three of them provided links to site-sponsored social media and encouraged sharing of information found there.

Start tweeting. Once you’re following @4TobaccoRights, it’s time to make your voice heard. You can tweet your opinions and share important links be sure to mention @4TobaccoRights when you do. (Citizens for Tobacco Rights)

In addition, the websites encouraged people to join or donate to the site, and to recruit friends to do likewise.

Taxes

The “Taxes” category included themes about tobacco taxes being unfair and/or excessive and statements that funds collected through taxes were misused, including examples of Master Settlement Agreement(MSA) funds and tax revenue utilized for dump trucks and golf carts:

Cigarette taxes and settlement agreement funds are supposed to fund youth smoking prevention programs and other tobacco related public health programs, but that’s not always where the money really goes.(Transform Tobacco)

Despite the fact that cigarettes are the most heavily taxed consumer product, politicians still use excise tax increases to pay for a variety of things – from local pet projects to state budget shortfalls. (Citizens for Tobacco Rights)

In addition, this category included statements that tobacco taxes lead to loss of revenue for tobacco retailers and fewer jobs, or to crime and bootlegging:

When cigarette taxes go up, smokers increasingly find ways to evade paying the higher prices. They order from online sources, buy from black-market deals, or drive across the border to a neighboring state with lower prices. (Transform Tobacco)

Tobacco Control Legislation or Regulation is Excessive or Unnecessary

This category included themes characterizing tobacco regulations as overreaching or infringing on the rights of consumers, unfairly targeting tobacco users and retailers, and dismissing current legislation as ineffective or unnecessary.

A ban on redeeming coupons has nothing to do with reducing underage tobacco use. State and federal laws already prohibit the sale of tobacco products to underage individuals at any price (Tobacco Ordinances)

Marketing restrictions including public bans on use and flavor bans were criticized as restricting the rights of retailers and limiting the choices of adult tobacco users.

Pending Food and Drug Administration regulations could cripple the premium cigar industry by banning walk-in humidors, defacing or covering cigar box artwork and requiring manufacturers to submit their blends for ‘testing’ before they can be sold.(Cigar Rights of America)

Some websites also included complaints about discrimination against tobacco users, including refusing to hire tobacco users.

A growing number of employers are refusing to hire people just because they smoke or dip. In some cases, adult tobacco users have even been fired from their jobs just because they use tobacco products during their free time, and that’s not right. (Citizens for Tobacco Rights)

Supporting Selected Tobacco Control Policies

This category included themes related to compliance with and support for some widely accepted tobacco control policies, most commonly age of sale policies and youth prevention programs.

Minors should NEVER use tobacco products. This is a guiding principle and belief of R.J. Reynolds Tobacco Co. and all the operating companies of Reynolds American Inc. (Transform Tobacco )

Vaper rights believes kids should not buy or use e vapor products. We applaud the 48 states that have age restrictions in place for e-vapor products and hope these restrictions will soon exist in all 50 states. (Vaper Rights)

In addition, nominal support of these policies positions tobacco industry groups as reasonable; the websites also provided links to government and tobacco control agencies or groups (e.g., CDC, FDA), as well as other programs (e.g., the “we card” program and cessation programs of their corporate sponsor). Many contained information on the comparative risk of tobacco products and promoting treating some products (e.g., vaper, SLT, cigars) separate from cigarettes.

Ata minimum, public health authorities should convey truthful information about the comparative risk of tobacco products to smokers, allowing them to make more informed decisions. (Transform Tobacco).

Website comparisons

The number of mentions recorded overall and for each website and the top five most frequent themes are displayed in Table 3.

Table 3.

Website and Tobacco Industry Affiliation, Target Audience, Product Focus and Top Five Most Frequently Mentioned Themes

Website and Industry affiliation*/ Total mentions on website	Target Audience	Stated Purpose from Website	Product Focus	Top Five Mentioned Themes Per Website	% of Theme Mentions on Website
Citizens for Tobacco Rights (PMI) / 274 Total mentions	Consumers	Citizens for Tobacco Rights helps adult smokers and dippers stay informed about tobacco issues and learn how to become effective legislative advocates.	General Tobacco	1. General Tobacco Taxes 2. General Pleas to Take Action 3. Links to Outside Tobacco Control Agencies 4. Providing Resources for Advocacy 5. Use Social Media for Advocacy	15.7 12.4 9.5 8.4 8.4
Vaper Rights (PMI) / 137 Total mentions	Consumers	Vaper Rights believes that public policies should recognize the differences between e-vapor products and traditional cigarettes.)	Vape Products	1. Provide Alternative Strategies to Existing Legislation/Regulations 2. General Tobacco Taxes 3. Underage Prevention and Retailer Age of SaleCompliance 4. General Pleas to Take Action 5. Public Bans on Use	21.9 18.2 14.6 8.8 7.3
Cigar Rights of America (IPCPR) /457 Total mentions	Consumers Retailers	Cigar Rights of America (CRA) is the first and only consumer-based public advocacy group fighting to protect the individual rights to enjoy premium cigars	Premium Cigars	1. Providing Resources for Advocacy 2. General Pleas for Action 3. Join or Donate for Advocacy 4. General Tobacco Legislation 5. General Tobacco Taxes	25.8 15.8 12.9 12.5 6.6
Transform Tobacco (RAI) / 566 Total mentions	Consumers Retailers	The Tobacco Industry is Transforming! And so should you. As a retailer, wholesaler or consumer of tobacco products, you have long known about the impact of higher cigarette excise taxes. But as the industry changes, so do the risks to your individual rights.	General Tobacco	1. Contact and/or Vote for Elected Officials 2. General Tobacco Taxes 3. Misuse of Tobacco Taxes 4. Taxes lead to Crime/Bootlegging 5. General Pleas to Take Action	16.8 15.4 10.8 10.4 8.8
Tobacco Issues (PMI) / 297 Total mentions	Retailers	Governments around the country—federal, state, and local—are targeting adult tobacco consumers, retailers, and wholesalers with excessive taxation and unfair policies and regulations. Help us fight for fair tobacco policies. Take action today!	General Tobacco	1. General Tobacco Taxes 2. Contact and/or Vote for Elected Officials 3. General Pleas to Take Action 4. Providing Resources for Advocacy 5. General Tobacco Legislation	29.0 13.5 11.8 8.4 7.4
Tobacco Ordinances (NATO/Swedis h Match) /261 Total mentions	Retailers	T.O.T.A.L. is an online information hub to share facts and information regarding these ordinance and how they negatively affect communities without actually addressing the problem.	General Tobacco	1. Marketing Restrictions 2. Misuse of Tobacco Taxes 3. Tobacco Taxes Lead to Revenue/Job Loss 4. Links to Outside Tobacco Control Agencies 5. Underage Prevention and Retailer Age of Sale Compliance	20.7 19.9 14.9 10.3 8.8

^*PMI = Phillip Morris International, IPCPR = International Premium Cigar and Pipe Retailers, RAI = Reynolds American Incorporated, NATO/Swedish Match = National Association of Tobacco Outlets / Swedish Match

In contrast to advocacy websites targeting retailers, which frequently featured business owners and employees, those targeting consumers tended to include general pleas to take action and provided consumer-friendly resources to facilitate advocacy. The two websites targeting retailers also differed in their thematic content. While of the two, Tobacco Issues provided more resources for advocacy (8.4%), Tobacco Ordinances focused more on the threat of marketing restrictions to retailers (20.7%). The two websites that targeted both consumers and retailers also differed in focus and product type. Cigar Rights of America provided many resources for advocacy while Transform Tobacco’s primary focus was the threat of taxes. Of all six websites analyzed, Cigar Rights had the highest level of content promoting advocacy (62.1%) to fight FDA regulation and other proposed policies. Vaper Rights had the highest percentage of content relating to legislation being excessive or unnecessary, and 22% of mentions were coded as providing alternative strategies to existing legislation or regulations.

Website Features

Four websites contained videos that mainly portrayed concerns of the website’s audience (e.g., consumers, retailers) through personal experiences and real-life scenarios. Tobacco taxes were a common topic for videos featuring tobacco consumers. One adult woman on a Citizens for Tobacco Rights video spoke of being overburdened with taxes and concluded “Enough is enough, we need to band together to fight them.” Other comments on taxes portrayed in videos were:

I think politicians target smokers because it’s a very easy target. Raising tobacco taxes is just their primary go-to for everything. They’re really hitting the regular person really hard. I mean they taxed this again last year now I’m hearing of a forty percent tax coming up on the cigars. –Montage of adult tobacco consumers (Citizens for Tobacco Rights)

In contrast, some videos on websites aimed at retailers (Tobacco Ordinances, Transform Tobacco, Cigar Rights of America) featured business owners and employees telling about negative effects of anti-tobacco policies, such as lost revenue for the business or loss of wages for employees. They encouraged others to get involved in fighting these policies.

If people had to go to another city to buy their tobacco products, it would kill us. Our hours would be drastically cut, I wouldn’t have enough money to live on and neither would the girls, guys, the employees that work with me.– Female convenience store employee. (Tobacco Ordinances)

Other video themes included bootlegging and illegal sales. The narrator on avideo on the Transform Tobacco website stated, “Our prohibition by price with cigarettes is causing the same un-intended consequences as alcohol prohibition did in the 1920’s and early 1930’s.” This video included a Detroit, MI cigarette wholesaler relating his experience with tobacco taxes leading to crime:

I can tell you that the worst day of my life was that morning after the second hijacking when the drivers got kidnapped. We found them. We had about 80 deliveries to go the next day and my drivers all came in and they just – they were looking at me. They said George – ‘we’re afraid to drive these trucks – what are we gonna do?’- Male tobacco wholesaler (Transform Tobacco)

DISCUSSION

To the best of our knowledge, this is the first systematic analysis of tobacco industry sponsored advocacy websites. We found that the websites are being used to deploy many of the same strategies tobacco companies have used previously in print magazines[6] and in other studies of industry efforts to oppose tobacco control policy, particularly taxes.[16]The arguments appearing most frequently on the websites were largely consistent with prior content analyses. The emphasis on tax policy was similar to a recent review of research on tobacco industry efforts to defeat tobacco tax initiatives by characterizing tax increases as unfair, arguing that tax funds are misused, stating that taxes lead to smuggling and illicit trade, and arguing taxes negatively impact local businesses and employment.[16]Our study is also consistent with a report on the advocacy website (T.O.T.A.L.) (included in this study as Tobacco Ordinances), identifying claims that there is insufficient evidence to support tobacco policies, that limits on marketing violate the First Amendment, and that policies are unnecessary or will incur unanticipated economic, health or other costs.[13]The past content analysis of smokers rights magazines found the most frequent category of mentions was “political and social action,” which corresponds to our “Facilitating Advocacy” category, comprising 36.7% of all mentions in our analysis.[6] As smokers’ rights publications have largely disappeared, this suggests that the websites have largely taken over the function of the magazines, to motivate and provide resources for readers to advocate for tobacco industry policies. Websites have some features which facilitate action more effectively and easily than magazines, such as buttons to click to send instant messages to elected officials, real-time updates on legislation, and links to social media.

The websites’ focus on two main audiences (retailers and consumers) suggests that websites are particularly useful to build perceptions of large “grassroots” movements of advocates outside of tobacco companies. Videos may further “give life” to stories of “real people” that are compelling to policy makers. Compared to past analyses,[6]stories of smoker persecution were less prevalent on the websites, but where they did appear they were prominent, as these testimonials were more frequently portrayed in videos.

Compared to prior analyses of smokers’ rights magazines [6], we found fewer mentions of attempts to refute scientific evidence on the health effects of smoking or second hand smoke. This is consistent with tobacco companies’ evolving positions on health effects of tobacco use over time, from flat denial[6,17] to admission that tobacco products are addictive[18]and that smoking has adverse health consequences, to even embracing the idea that smoking is harmful in service of harm reduction initiatives.[19]Historically, tobacco companies have supported youth prevention policies or programs as a weak alternative to stronger restrictions,[20] or as “trojan horse” legislation containing definitions or preemption clauses that undermine tobacco control policies[21], and the use of advocacy websites in this manner appears to serve that purpose.

The major themes identified also reflect the taxonomy of discursive strategies in the Policy Dystopia Model discussed by Ulucanlar et al in 2018[5]. The arguments identified in this model that were consistent with our coding include “unanticipated costs of economy and society”, which included arguments that policies will lead to lost sales or jobs, increase crime, and that the government is unreasonable or acting as a nanny state. Two arguments found in the international policy realm we did not identify on the websites were claims that the policies were a breach of trade agreements or intellectual property laws, or that the Government is anti-free-enterprise. The model also describes “unintended benefits to undeserving groups” as smugglers or big business will profit from the policy; on the websites in our analysis there was little mention of “big business” although smuggling appeared. Also consistent with the model, we found the argument that the “policy will be counterproductive” was present.

Anecdotally, we noticed upon subsequent visits to the websites after the completion of the study, that two of the websites have incurred substantial changes in the time since our formal analyses. Most notably, Tobacco Ordinances changed to National Local Advocacy Alliance and the website now has more opportunities to engage in local and national advocacy.[22]Transform Tobacco also changed names, and now also automatically redirects the user from www.transformtobacco.com to www.ownitvoiceit.com.[23] The site continues to be sponsored by RAI Services. We observed during the course of regular surveillance that the new iteration has been redesigned, and in the fall of 2018, emails sent from RAI cigarette brands Camel, Newport and Pall Mall regarding a possible menthol ban in New Jersey included links to the Own it Voice it website, where users could directly relay objections to state officials.[24] The new site also links users to its social media platforms including Facebook, Twitter, Instagram and YouTube.

Unlike other tobacco products, which were regulated by FDA since 2009, both cigars and vapor products were only included in FDA tobacco regulation effective August 8, 2016.[25] This relatively new set of regulations might explain why two of the six websites focused exclusively on cigars and vapor products.

This study provides further evidence that the World Health Organization’s best practices, cited in WHO FCTC article 5.3, be practiced, as “There is a fundamental and irreconcilable conflict between the tobacco industry’s interests and public health policy interests.”

Limitations

There are limitations to our study. Our findings are based on review of website content in 2017. As noted above, two of the reviewed websites have incurred notable changes since that time and others have undoubtedly been updated or revised. In addition, our findings may not reflect the content of all tobacco advocacy websites, as our sample was limited to sites we could connect directly to the US tobacco industry. As Hatchard et al have noted [26], there may be other corporate, political, or organizational interests opposing anti-tobacco policy initiatives that we did not analyze as a result. In addition, we were unable to collect information on the number of visitors to these websites or, for those that did visit, how many took advantage of advocacy tools or undertook advocacy efforts.

CONCLUSION

Websites promoting pro-tobacco advocacy are an important and evolving strategy used by the tobacco industry to integrate marketing and policy objectives. Websites are arguably a more powerful mechanism for delivering messages and promoting action than other media, providing a seamless link enabling consumers and retailers to take action to influence policy and to connect with policy makers. Advantages of websites include broad reach, interactivity, and delivery of messages in a variety of formats, including videos and testimonials, which may motivate action in a more personal, impactful way. An important attribute of websites is their immediacy. They can inform people in a timely manner about issues that may concern them and facilitate immediate action by providing examples, sample language and links to decision makers.

Given their potential for countering tobacco control policies it is important for public health and tobacco control professionals to be aware of and monitor these websites and adopt strategies to anticipate these tactics. Like other direct to consumer marketing strategies employed by the tobacco industry, these websites benefit from operating out of the view of public health and have largely gone unnoticed by those in public health and tobacco control. Greater awareness of the websites along with ongoing surveillance and documentation of their content is a necessary step to anticipate industry opposition to tobacco control policy.

What This Paper Adds.

• Previous studies have documented tobacco industry advocacy to counter tobacco control policy initiatives through traditional media. However, examination of the use and utility of new media to promote advocacy for pro-tobacco policy has been limited.

• This study analyzed industry-sponsored protobacco advocacy websites aimed at tobacco users and retailers to disseminate pro-tobacco positions and encourage advocacy.

• We found websites promoting pro-tobacco advocacy are important and evolving tools that are particularly well suited to leveraging marketing activities (e.g. building relationships with retailers and consumers) to achieve policy objectives.