name Action Board Not-Smoking
class association
category commercial tobacco control
funding indirect pharma contributions
association SPD, SFP
bloomberg ties unlikely
motivation cancer/pharma lobby
science aversion πŸŸ₯πŸŸ₯πŸŸ₯🟧🟨
public discourse πŸŸ₯πŸŸ₯πŸŸ₯πŸŸ₯🟨

This German lobby coalition started as genuine tobacco control association for non-smoker and passive smoking protection. But has since abdicated the guise to advocate for prohibition of lesser evils. They don't seem to be in on the Bloomberg/WHO loop, since their references are usually more bland and dated. (Member of smokefreepartnership)

They've been utilized by the SPD to provide shallow pretexts (e-cigs not completely harmless, ergo very harmful) for implementing excessive e-cigarette taxes - as likely distraction from negligible tobacco tax raises.

argumentation schemes

  • Exaggerated harm projections about e-cigarettes.
    • A somewhat obsessive talking point seems to be formaldehyde. (And usually communicated as "contained" in e-cigarettes, not as heating by-product.) Rationalized with high toxicity at any and all concentratitions (no minimum levels according to regulator BfR)
    • Heavy metals / lead get mentioned often, based on a dated smolder studies.
    • Refute assessments like "95% less harmful" as industry claims/ploys, but refuse alternative harm quantification.
    • Obviously also avert any comparisons to combustible tobacco.
  • Conflating tobacco for nicotine addiction. Insisting that e-cigarettes had identical addiction potential/effect to combustibles.
  • Disputing applicability of e-cigarettes for cessation (PHE/RCP, Hajek, Cochrane, ADSB denounced as "individual opinions").
  • Plainly lied about existence of "long term studies". (But their representative might have been genuinely unaware of the scient. definition.)
  • Think of the children is a talking point, but not as absurdly as US lobbying groups.
    • Gateway hypothesis is often brought up (but never clarified for individual, population level or reactance effects)
    • Ignores the continued decline in teen smoking and regular teen vaping down at 0.5%.
    • They're also preoccupied with their child-friendly logic of "child-friendly" vaping flavour bans (wasn't initially a topic in finance committe)
    • And advocate to make ATFs prevalent for teen experimentation (have the gateway hypothesis come true, as seen in US/SanFran).
    • The notion of TI marketing is brought up in position papers. Though it should be mentioned that Germany only very recently legislated serious tobacco/vaping ad restrictions (2022-24).
    • Older position papers recommend plain packaging for vaping; which was sort of sensible, since German manufacturers could never be bothered to turn down the attention-whory package designs.
  • One of the prior ABNR testimonies was a straight Wikipedia recitation.
  • It's possible they still fed the SPD with EVALI disinformation (this came up recurringly and was included in canned responses), despite their own member newsletter clarifying this in early 2020.
  • Impact assessments are rarely presented, or else tunnel-visionary.

skimpy critique of tobacco taxes

Interestingly their initial statement to the committees advocated for higher tobacco taxation (15% raise per year, 2.3ct/cigarette). Which would have raised the pkg price from ~6.50 to ~9.50 EUR, thus stirred real smoking decline (and black markets). Unclear if that was meant as genuine proposal.

And unfortunately the SPD was also in prior talks with the tobacco industry; thus the result is a laughable 40ct/pkg raise over 5 years.

ABNR-associatetd DKFZ released a timid response about the mediocre tobacco tax raises. There's probably internal outrage that their proposed 96ct/ml e-liquid proposal was rejected.


Since it's an association, there's an extensive members list of German public health organizations. Most of which presumably just outsourced lobbying to ABNR, when topically it's not an internal priority. Notably there are a lot of cancer research and treatment associations on the member/donor list. Which is why cross-financing from pharmaceuticals (even if indirect/obfuscated) is fairly probable.