Philip Morris used AI to flood the European tobacco consultation

The European Commission is currently revising two major directives on tobacco products and related advertising. As part of this process, it launched a public consultation which received nearly 90,000 responses. A Dutch journalistic investigation[1]-[2] reveals that a massive proportion of these contributions were generated by an artificial intelligence tool implemented by Philip Morris International, under a concealed identity. In France, this phenomenon is particularly pronounced: 68% of the responses to the consultation were reportedly written by Artificial Intelligence (AI).

A consultation overwhelmed by fabricated responses

The revision of European directives on tobacco products and advertising is a central public health issue within the European Union. As part of this legislative process, the European Commission launched a public consultation to gather input from citizens, associations, and stakeholders. The volume of responses received is particularly unusual: 88,000 contributions were submitted in just one month, whereas similar consultation procedures typically receive fewer than 1,000 responses.

An investigation conducted by the data editorial team of Point, The investigative journalism department of KRO-NCRV, one of the leading Dutch public broadcasters, in collaboration with NOS, the Dutch equivalent of France Télévisions, analyzed more than 65,000 of these contributions. The analysis revealed that 22,500 of them, or 35% of the total, were entirely generated by artificial intelligence tools. This proportion actually encompasses two distinct phenomena, which should be differentiated. On the one hand, there is the use of generative AI tools by individuals to write their own contributions, which does not necessarily reflect the viewpoint expressed. On the other hand, and this is what the investigation primarily documents, there is the organized dissemination of pre-formatted responses from the manufacturers themselves, constructed from predefined arguments that leave little room for the personal expression of the signatories. This second practice constitutes a form of remote-controlled response, already observed and denounced during the previous revision of the directive on tobacco products, which also saw an unusually high number of contributions.

If the investigation of Point And the NOS analysis established that a large majority of AI-generated responses came from the tool implemented by Philip Morris International; this figure likely reflects only part of the phenomenon. Beyond PMI, several other tobacco manufacturers, as well as vaping industry organizations, proved equally proactive in influencing the contributions submitted during this consultation, suggesting that the actual proportion of industry-driven responses could be even greater than the data available to date indicates.

Philip Morris behind the tool: a hidden campaign

The investigation reveals that almost all of these AI-generated responses originated from a single tool, developed by Philip Morris International (PMI). The campaign operated under the name "Your Voice Your Choice," in which Philip Morris was only mentioned in small print. Posters in tobacconists' shops in certain member countries, emails sent to customers, and advertisements on the website of IQOS, the group's heated tobacco brand, directed customers to this tool via a QR code.

The tool was simple to use: users answered a few questions—whether they smoked, what products they consumed, and what aspects they considered important—and it automatically generated a first-person response ready to be submitted to the European Commission's portal. However, of the eleven "important aspects" presented to users, only one supported stricter regulations; all the others presented arguments against them. Researchers also found that in at least 50 cases, the tool added arguments against regulation that the user had not selected.

An attack on democratic integrity denounced by experts

The European Commission has expressed its concerns, indicating that it is paying close attention to reports of industry-backed campaigns to influence the results of the consultation, and stressing the importance of ensuring that citizens' positions are neither manipulated nor misrepresented.

This case falls within a very specific strategic context. Saturating a public consultation with automated responses is a well-documented tactic used by the tobacco industry to delay or weaken legislative processes that are unfavorable to it. The high rate of AI-generated responses in France is not surprising given the country's stated position on this issue. Indeed, France supported, within the framework of this same consultation, [the following][3], Several particularly ambitious measures have been adopted, including a ban on all flavorings in products covered by the directive, the introduction of plain packaging across Europe, a reduction in permitted nicotine levels in certain products, and, for the first time, a ban on cigarette filters. This stance is consistent with reforms undertaken at the national level, making France one of the Member States most committed to stricter regulations on new tobacco and nicotine products.

The stakes are all the higher given the evaluation of the European tobacco control framework published by the Commission on April 2, 2026[4] The report concluded that current guidelines are now insufficient in the face of the rapid growth of new tobacco and nicotine products, and that the Commission deemed a revision of the legislation necessary to support the European objective of a "tobacco-free generation" by 2040. Faced with this prospect, Philip Morris International, along with other manufacturers in the sector, mobilized their consumer networks to try to influence the outcome of the consultation. Philip Morris advocates a so-called "risk-based" approach, which would involve applying differentiated rules according to product categories, in order to obtain more favorable regulatory treatment for e-cigarettes, heated tobacco products, and nicotine pouches—segments in which the group now generates a growing share of its revenue.

From an international law perspective, the WHO Framework Convention on Tobacco Control (FCTC), to which the European Union is a Party, stipulates in Article 5.3 and its implementing guidelines that the tobacco industry must not exert any influence on the development of public health policies, due to the fundamental contradiction between its commercial interests and the objectives of public health. By massively manipulating an official consultation through automatically generated responses, manufacturers presented their own interests under the guise of citizen participation, effectively circumventing this commitment. In the Netherlands, several health organizations filed complaints with the relevant authorities, and a large majority of Parliament formally condemned the campaign.

©Generation Without Tobacco

AE

[1] AI van Philip Morris dominates the Nederlandse inspraak op EU-tabakswet, Published on June 28, 2026, Pointer, accessed the same day

[2] Marleen de Rooy, Tabaksgigant laat AI 'publieksreacties' schrijven tegen strengere EU-regels: 'Dit is valsspelen'', Published on June 28, 2026, NOS, accessed the same day

[3] France is pushing the European Union towards more ambitious regulations on tobacco and nicotine, Tobacco-Free Generation, published on June 20, 2026, accessed on June 29, 2026

[4] Tobacco Control Directive: A European assessment reveals an outdated framework., Tobacco-Free Generation, published April 7, 2026, accessed June 29, 2026