Frequently Asked Questions

What is the Where There’s Smoke campaign trying to achieve?

The Where There’s Smoke campaign seeks to end tobacco marketing on social media and is calling on governments to investigate BAT, IMB, JTI, and PMI for advertising on social media and, depending on current laws, enforce or enact and enforce tobacco advertising bans.

Who runs the Where There’s Smoke campaign?

Where There’s Smoke is a project of the Campaign for Tobacco-Free Kids under its TakeAPart initiative. TakeAPart is a global fight to take down tobacco. We support proven policies to reduce tobacco use, and we stand against the tobacco industry as it targets the world’s most vulnerable people in its quest to profit from selling deadly products.

Does social media marketing reach youth?

Tobacco companies’ promotion of their deadly products on social media is alarming given the high likelihood that youth are being exposed to social media content on platforms like Facebook, Instagram and Twitter.

According to the Pew Internet Project, 92% of teens (ages 13-17 years) use the internet daily, and more than half (56%) go online several times a day. Smartphone access by 73% of teens helps to enable this frequent internet access. In addition, over three-quarters (76%) of teens report use of at least one social media platform.[i]

Exposure to tobacco advertisements via the internet among high school students susceptible to smoking cigarettes increased 73 percent from 2000 to 2011, reaching 44.7% teens.[ii]

Among youth aged 11-18 years, exposure to tobacco promotion on social media was correlated with a more favorable attitude towards tobacco, including the intention to initiate tobacco use among those who had not yet tried tobacco products.[iii]

A 2015 study assessing the role of social media in influencing tobacco-related behavior in young people found that exposure to tobacco content on social media predicts smoking tendency over that of exposure on television and movies.[iv]

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[i] Lenhart, A, et al., Teens, Social Media & Technology Overview 2015: Smartphones facilitate shifts in communication landscape for teens, April 9, 2015.
[ii] Dube, Shanta R., et al. "Pro-tobacco influences and susceptibility to smoking cigarettes among middle and high school students—United States, 2011." Journal of Adolescent Health 52.5 (2013): S45-S51.
[iii] Cavazos-Rehg PA, Krauss MJ, Spitznagel EL, et al. Hazards of new media: youth’s exposure to tobacco Ads/promotions. Nicotine Tob Res 2014;16:437–44.
[iv] Depue JB, Southwell BG, Betzner AE, et al. Encoded exposure to tobacco use in social media predicts subsequent smoking behavior. Am J Health Promotion 2015;29:259–61.

Which tobacco companies were investigated and found to engage in social media marketing in research for Where There’s Smoke?

Philip Morris International, British American Tobacco, Japan Tobacco International and Imperial Brands.

Are tobacco companies transparent about their social media marketing efforts?

No. While the world’s largest tobacco companies claim to have “voluntary codes of conduct" which promise investors, regulators and the public they won’t engage in social media marketing, there is indisputable evidence to the contrary. Findings of the Where There’s Smoke campaign directly contradict tobacco companies’ voluntary codes of conduct that claim the companies will not engage in viral marketing (British American Tobacco, Imperial Brands) or covert marketing where it is not explicitly clear that cigarettes are being advertised (British American Tobacco), require age verification in online ads (Japan Tobacco International) and will engage in marketing that is “honest and accurate” (Philip Morris International). Tobacco companies cannot be trusted to be honest about – and in some cases, law-abiding in – their marketing practices, so regulators and social media companies need to step in.

Have tobacco companies engaged in this type of marketing before?

Tobacco companies are engaging in the same marketing tactics used for decades to reach youth and young people – only now they use social media to reach an even wider, unlimited audience of all ages to promote their brands and re-normalize tobacco use.

Philip Morris understood the importance of targeting college students as early as 1949 to “Get' em young, train 'em right” [i] because “they are widely copied by others. They set the styles…[and] because they're young and if we sell them, we have customers for a long time.”

Another internal tobacco marketing document released as part of legal settlements in the U.S[ii]. regarding “trend influence marketing” highlights the “under the radar” advertising concept that cigarette firms perfected in bars, nightclubs and restaurants in the 1990s:

T.I.M. [Trend Influence Marketing] is strategic and subtle. It infiltrates the marketplace under the radar of the public's natural resistance to traditional marketing vehicles. Consumers in these settings should not feel that they are being marketed to - properly executed, the program will appear very natural and not at all contrived. The marketing company and process are invisible to the general public. What comes through is a genuine response to a product that is perceived as part of and integral to the setting and the "scene.”

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[i] CAHN,J. COLLEGE PLAN FOR 490000, 1949 December 30. Philip Morris Records. Unknown.
[ii] Kevin Berg & Assoc. Salem: Operation Green Apple. Trend Influence Marketing Program. 1996 October 07. RJ Reynolds Records.

What is a social media influencer?

Advertisers may use “influencer marketing” as part of their broader social media and online marketing mix to promote brands. Influencers are individuals who have large numbers of social media followers who are paid or incentivized by advertisers to promote specific brands or products on Instagram, Facebook, Twitter or other social media platforms. A high-profile influencer can be paid as little as $250 per post (0-50,000 followers) up to $15,000+ per post (500,000-1,000,000 followers).

SOURCE: Report prepared for the Campaign for Tobacco-Free Kids by Grassriots. IQOS Social Listening Report. March 2018 (citing Industry pricing chart for purchasing a product-post from an Instagram Influencer from The Influence Agency).

Is influencer marketing regulated?

In some countries, yes. In the United States, the Federal Trade Commission (FTC) regulates influencer marketing practices to ensure that consumers are not deceived into believing that a paid social media post by an individual is organic content.[i] FTC Enforcement Guides require influencer marketing posts to disclose whether there is a substantial (“material”) or financial connection between an influencer and advertiser by including words like #Ad, #Sponsored, or # Promotion in social media posts.[ii]

[i] Federal Trade Commission 16 C.F.R Part 255.5, Guides Concerning the Use of Endorsements and Testimonials in Advertising.
[ii] The FTC’s Endorsement Guides: What People are Asking. September 2017.

How can social media influencers participate in the Where There’s Smoke campaign?

Social media influencers should endorse the Influencer Code of Conduct and ensure their account is a #TobaccoFreePage.

Do social media companies allow tobacco advertising?

Facebook, Instagram, and Twitter prohibit tobacco advertising on their platforms.

For more information, please follow the links below: Facebook and Instagram: “Ads must not promote the sale or use of tobacco products and related paraphernalia.”
Twitter: “Twitter prohibits the promotion of tobacco products, accessories, and brands globally.”

What should social media companies like Facebook, Instagram and Twitter do to stop tobacco companies from marketing on their platforms?

Social media companies should enforce their tobacco advertising policies for ads placed through their advertising portal as well as sponsored content.

What should governments do to stop tobacco marketing on social media?

Governments with comprehensive tobacco advertising, promotion and sponsorship bans covering internet advertising should enforce the laws. Governments without comprehensive laws or laws that do not cover internet advertising should adopt and implement laws that completely prohibit advertising tobacco products on the internet.

Do you have resources for public health, consumer protection, corporate accountability and other advocates in government or with NGOs to initiate calls for investigations?

Advocates can file complaints to regulators or take legal action to ensure that tobacco companies can no longer deceptively advertise tobacco on social media channels.

What role do marketing agencies play in tobacco marketing on social media?

Marketing agencies are involved in many ways including designing social media campaigns and recruiting and managing social media influencers.

Should marketing agencies be held accountable for their role in tobacco marketing on social media?

Yes, to the extent that marketing agencies are managing the tobacco companies’ social media marketing strategies they should be held accountable for the content and images of smoking flooding the internet.

How can marketing companies be part of the solution?

Marketing companies can commit to not working with tobacco companies. The campaign #QuitBigTobacco is encouraging public health organizations and healthcare companies to pledge not to work with ad agencies with tobacco clients. Since the campaign was launched, 85 different organizations have signed the pledge.