A public consultation on the revision of the tobacco taxation directive is being targeted by a massive spam campaign from the tobacco lobby.

An analysis by the anti-lobbying firm Impact Unfiltered indicates that approximately half of the 18,480 contributions submitted as part of the European Commission's public consultation on the revision of the Tobacco Excise Directive (TED) were automatically generated by actors linked to the tobacco industry.[1]. Published by Politico Europe, this analysis notes that the consultation, which closed on October 31, 2025, received almost nine times more contributions than an average European consultation.

Among these, nearly 8,000 repeated the same argument: the idea that a tax increase would encourage illicit trade, a point disputed by independent data and facts highlighted by the World Health Organization (WHO) and numerous health organizations, including the CNCT. According to Laurent Huber, director of Action on Smoking and Health (ASH) USA, the almost identical repetition of this argument by thousands of anonymous individuals suggests a coordinated operation rather than spontaneous participation.

The use of bots in online mobilizations to influence democratic decisions

Laurent Huber believes that this is not genuine citizen participation, but a form of manufactured opposition, explaining that "« When 7,770 people across Europe spontaneously and anonymously use the same argument of “illegal trading” during office hours, it is not a spontaneous citizen mobilization, but rather a strategy orchestrated by the industry. ".

Health professionals, however, point out that scientific data shows that tax increases significantly reduce tobacco consumption and that this decrease also leads to a decline in the illicit market for these products. They also emphasize the tobacco industry's role and responsibility in these illicit markets, both past and present.

68 of the responses to the European consultation on the revision of the text on tobacco product taxation came from three countries: France, Italy – two countries characterized by a retail distribution system particularly linked to manufacturers – and Sweden. Furthermore, more than 6,000 responses mentioned "harm reduction."«[2], an argument of smoking cessation instrumentalized and misused by the tobacco and nicotine industry to justify the expansion of the market for new nicotine products, with a narrative that exactly echoes the terms of tobacco manufacturers.

According to Impact Unfiltered, supported by the School of Moral Ambition (SMA) which seeks to support public health actors in the face of industry influence, only 90 contributions, or 0.5 % of the total, came from non-governmental health organizations.

The situation is all the more sensitive given that the draft revision includes an increase in minimum excise duties on tobacco – cigarettes, rolling tobacco, cigars – and the introduction, for the first time, of harmonized taxes on e-cigarettes. The European Parliament's Committee on Fiscal Affairs (FISC) is scheduled to examine the text on November 20, 2025.

In a message posted on LinkedIn, Rutger Bregman, founder of the SMA, denounces what he describes as a form of "« democratic capture »", lobbyists using the results of the consultation to claim that European citizens oppose excise tax increases.

He indicates that the revelation of fraudulent contributions has already prompted calls in Brussels to strengthen the protection of decision-making processes against interference from industry, noting that parliamentarians are now better informed about the true origin of contributions.

Impact Unfiltered's findings are part of a broader trend: the increasing use of bots to artificially amplify opposition to new regulations. In 2024, a Mirror investigation in the UK revealed that three-quarters of the 120,000 contributions to a consultation on the Tobacco and Vapes Bill, a An ambitious bill to create a tobacco-free generation and strictly regulate the marketing of vaping products, were automated.

The long-standing use of public consultation as a tool for political influence

For several years, online consultations have been a preferred method for tobacco and nicotine stakeholders to promote their positions to institutions, often through messages presented as coming from private individuals. Contributions originating directly from the industry are analyzed in light of the provisions of Article 5.3 of the WHO Framework Convention on Tobacco Control (FCTC): this article stipulates that public health policies must be independent and protected from any interference by the tobacco and nicotine industry and its representatives.

Campaigns have already been conducted to mobilize individuals. In 2022, for example, the World Vapers' Alliance (WVA) encouraged citizens to oppose the ban on flavors for electronic cigarettes in the Netherlands, even though the organization is funded by the tobacco industry.

At the European level, the tobacco industry began actively opposing the Tobacco Products Directive (TPD) as early as 2009, seeking to block so-called "extreme" measures such as plain packaging, the ban on point-of-sale advertising, and the prohibition of certain ingredients.[3]. A public consultation organised at the end of 2010 gathered more than 85,000 contributions, with the Commission stating that’ No public consultation launched by the European Commission had ever recorded such high participation. »Although only 2,320 contributions openly stated they were linked to the tobacco industry, further analysis of the responses showed that a large proportion of them were attributed to mobilization campaigns conducted by the tobacco industry in Poland and Italy.

©Generation Without Tobacco

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[1]Tabaknee, Duizenden fake-reacties op Europese tabaksconsultatie, Published on November 10, 2025, accessed on November 17, 2025

[2]Rory O'Neill, EU tobacco tax hike plan swamped with pro-industry feedback, Politico, published November 6, 2025, accessed November 17, 2025

[3]Tobacco Tactics, EU Tobacco Products Directive Revision, Updated on March 25, 2021, accessed on November 18, 2025

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