Mark Brooke’s defence of Australian tobacco policy has a credibility problem: the standard of evidence changes depending on whose proposal is being examined. For an excise cut, the Lung Foundation Australia chief executive demands detailed modelling of smoking initiation, quitting, relapse, consumption, disease, healthcare costs and illicit trade. For his own proposal to eliminate 80 per cent of tobacco retail licences and reserve sales for large supermarkets, his article supplies no equivalent modelling. An excise cut is an experiment, while his preferred restrictions are presented as a credible alternative, a distinction asserted far more confidently than it is demonstrated.
Brooke’s September 10 article contains legitimate questions, and a proposed 80 per cent excise reduction absolutely deserves scrutiny. But he weakens those questions by treating evidence as an obligation imposed principally on people who disagree with him.
Brooke cites the decline in daily smoking from 8.3 per cent in 2022–23 to 5.6 per cent in 2025. The figures are supported by the Australian Institute of Health and Welfare and could be acknowledged, but they cannot bear the argumentative weight he assigns to them. A population survey does not identify the optimal tobacco tax, establish how much of the decline was due to excise taxes rather than other interventions, or show whether different settings could yield better results. AIHW tobacco smoking data
Brooke lists the many measures contributing to tobacco control, then uses the combined outcome to defend the existing framework. That leaves the disputed question unanswered: is the current excise setting justified under current market conditions? Policies require reassessment precisely because conditions change, and decades of progress do not grant every existing measure permanent immunity from scrutiny.
Brooke acknowledges illegal tobacco, but largely treats it as a problem to be addressed through stronger enforcement while preserving the price policy. That is an inadequate treatment of the central challenge. The Senate inquiry describes a market in which avoiding excise and GST predominantly enables the lower prices of illegal tobacco, making tax policy part of the competitive environment in which illegal sellers operate. A high legal price has limited relevance to a smoker buying cheap, untaxed cigarettes; the intended price signal must actually reach the consumer. Senate inquiry, chapter one
This does not prove that an 80 per cent cut would work. Illegal suppliers could cut their own prices, legal manufacturers might retain some of the reduction, and total consumption could rise. Those are reasons to model the market properly, but they are also reasons to model the consequences of maintaining current settings. Continuing a policy is a decision with consequences, not a neutral position that escapes the burden of proof.
Brooke’s own proposals expose the imbalance most clearly. His article calls for an 80 per cent reduction in tobacco retail licences by 2030, the closure of tobacconists and sales restricted to large corporate supermarkets. That is an enormous restructuring of lawful supply, yet the article does not show how this particular package would affect quitting, illegal purchasing, access in regional communities or enforcement costs. It does not establish why 80 per cent is the right reduction, or why supermarkets should retain the right to sell cigarettes.
Evidence linking retailer density with smoking provides a basis for investigating restrictions, but it does not automatically validate any chosen reduction, deadline or retail structure. Where is the analysis of customers who would switch to illegal sellers, the comparison with less sweeping licensing reforms, or the evidence that concentrating sales in supermarkets delivers the best health outcome?
Brooke condemns convenience retailers’ commercial interests while proposing to concentrate lawful tobacco sales among larger commercial retailers. Supermarkets also make money selling cigarettes, and their corporate size does not answer the public-health questions. If commercial incentives demand scrutiny, that scrutiny must extend to the businesses his proposal would leave standing.
His account of the UK policy raises a further problem. Brooke presents Britain as a precedent for a Tobacco and Vape-Free Generation policy that would progressively prohibit the sale of tobacco and nicotine products to people born after a specified date. The distinction he blurs is fundamental: the UK’s generational tobacco restriction applies to people born on or after 1 January 2009, while vapes and other nicotine products have separate age-of-sale rules. Government guidance specifies an age threshold of 18 from 29 October 2026, rather than a lifetime generational prohibition. Tobacco and Vapes Act 2026, UK sales guidance
Brooke therefore presents the British precedent as supporting a broader prohibition than it establishes, which is especially damaging in an article that lectures others about selective use of international evidence. Britain also continues to recognise vaping as a tool for quitting smoking. The NHS describes vaping as less harmful than smoking, while making clear that it is not harmless and that children and non-smokers should not vape. NHS guidance
Brooke himself supports subsidised therapeutic vapes and plainly recognises that these products can have a useful role. That makes precision about regulation and access more necessary. Britain’s combination of tobacco restrictions, youth protections and adult access cannot fairly be compressed into an endorsement of his preferred Australian approach.
The Canadian evidence Brooke cites deserves serious consideration. A study of the 1994 tax cuts found higher initiation and lower quitting in provinces that reduced taxes, concluding that the cuts appeared to slow the decline in smoking. That undermines any claim that tobacco tax cuts are automatically harmless, but it does not determine the appropriate Australian excise rate more than three decades later. Canadian study
Brooke acknowledges the limits of the comparison, but those limits matter to the conclusion. Canada provides evidence to include in a contemporary assessment, rather than a sufficient answer to Australia’s present policy problem. The assessment must compare plausible alternatives, including their effects on legal and illegal consumption, because a case against one proposed cut does not establish a case for keeping every current setting.
Brooke also devotes considerable space to supportive professional bodies and Coatsworth’s lack of engagement with Lung Foundation Australia. The foundation has every right to participate in public policy, and its experience deserves attention, but a critic does not need to join its activities before questioning its position. Nor does a list of prestigious organisations substitute for the missing analysis.
Institutional agreement can help readers understand where professional opinion sits, but it cannot demonstrate the effects of a specific excise rate or an 80 per cent reduction in retail licences. The article’s defensive emphasis on standing and affiliation distracts from precisely the evidence Brooke says should decide the debate. His treatment of commercial interests has a similar weakness: disclosure and scrutiny are necessary, but identifying a retailer’s financial interest does not establish that the retailer’s policy argument is false. Arguments still need to be tested.
Brooke’s demand for transparent modelling is sound; his selective application of it is the problem. An honest comparison would examine substantial excise reductions, smaller adjustments, current settings, stronger enforcement and different retail restrictions. It would assess smoking, quitting, illicit supply, unequal burdens and implementation costs, and specify what evidence would persuade advocates to change their minds.
Brooke asks his opponents to demonstrate that their policies will work, and readers are entitled to ask him for the same demonstration. Before Lung Foundation Australia presents an 80 per cent reduction in retail licences as the credible alternative, it should publish the analysis supporting that figure. Before invoking Britain, it should describe Britain’s policy accurately. Before claiming that falling smoking rates vindicate current settings, it should establish the causal argument.
The public health authority carries a responsibility to meet demanding standards of evidence. It does not confer an exemption from them.
Need to reread. Lotsa good points
Alan Gor gently points out the glaring inconsistency in the Lung Foundation’s response to Australia’s descent into a smoking/vaping policy quagmire. Opponents are required to provide detailed modelling to support their positions but supporters of sky high cigarette excise and quasi prohibition of vapes have no equivalent requirement to support their preferred policy with evidence. Central to this debate is the assumption that more law enforcement is effective in clearing out illegal supplies of a prohibited demand. In 1976, a US psychiatrist Dr Joe Westermeyer published a paper well summarised by its title “The pro heroin effects of anti-opium laws in Asian countries”. Ten years after Thailand, Hong Kong and Laos introduced policies intended to eradicate opium smoking, applications for help from drug treatment centres had switched from people smoking opium to people injecting heroin.
Although it might seem logical that law enforcement is effective in reducing the supply of illegal drugs, evidence to support this claim is elusive. If you look this up yourself, you will find that the wholesale and retail price of illegal drugs has been decreasing for decades while their purity has been increasing. This tells us that supply has been increasing faster than demand. We know demand has been increasing because for decades, illegal drugs has been reported from a growing number of countries and the estimated number of people using drugs and the estimated quantity of drugs used have all been increasing. Like other members of the anti vaping cult, the Lung Foundation has been protected by refusing any contact with people with different views, and mass media and health establishment groupthink. But this protection will not last indefinitely. As Warren Buffet remarked in a financial context, ‘when the tide goes out, we will see who has been swimming naked’.