Christopher Snowdon's Blog, page 3

No smokes without fire in Australia

Australia saw another two murders in its ongoing nicotine wars last week and the ABC (Australian Broadcasting Corporation) has finally had enough. 

Australia's illegal tobacco problem has made the proverbial transition from tragedy to farce.

Illicit, excise-evading cigarettes now comprise half of the cancer-inducing products sold to Australia's 2.7 million smokers.

... In the past couple of years, there have been 125 firebombings of tobacco shops in Victoria, and another 50 or so in other states — the most recent last week in Corrimal, NSW.

... Violent robberies in Victoria have grown by more than 150 per cent since February 2024 due to tobacco-related crime.

This is much worse than an unintended consequence of the effort to reduce smoking; it is a complete stuff-up.

... The CEO of the Australian Association of Convenience Stores, Theo Foukkares, says the tipping point happened in 2019 when the excise increased 55 per cent over three years to $1.10 per cigarette stick.

As a direct result, illicit smoking took off and tobacco excise revenue to the government collapsed, from a peak of $16 billion in 2019 to this year's $7.4 billion.

 All in all, it is a dramatic and resounding condemnation of Australia's 'public health' establishment who assured us that this kind of thing would never happen. The ABC even implicates plain packaging - for which Australia was a 'world leader' - in this mess. 

And it's not just the price that's driving people towards the much cheaper illegal alternatives, although that's the main thing, especially in a cost-of-living crisis.

For a start, the packs look nicer without pictures of horrible mouth tumours.

 There is probably no way back for Australia now. Shopkeepers are sick of getting robbed and firebombed and are increasingly not stocking cigarettes at all, thereby leaving the tobacco market to the gangsters. The dolts in 'tobacco control' who should be held accountable for this fiasco will never get their comeuppance (Simon Chapman's blog posts reveal a man deep in denial). The only thing Australia can do is be a warning to the rest of the world.   
 

 

Endless battle with illicit tobacco market - BBC

The BBC has been waking up to the scale of Britain's illicit tobacco market. Packs of illicit whites sold for a fiver are one of the more visible symptoms of a country in which rules and regulations are treated as optional. We free marketeers have been warning that this would happen for years but were given short shrift. The BBC isn't ready to admit that we were right, but the problem is too big to be ignored completely. The latest BBC story ignores the demand side and focuses on the supply, which appears to be endless. Indeed, the article is titled  'Endless battle': Fighting the crime gangs taking over the high street . 

Swansea has become a hub for counterfeit rolling tobacco, says Harries. He says the trade is controlled by Chinese gangs in the city who are making "phenomenal" amounts of cash this way.

Chinese migrants, brought in on student visas, are forced to work illegally and stuff hundreds of pouches of tobacco every week, he says.

"The amount of money [the gangs] they can make selling tobacco is greater than if they were selling drugs," he explains.

The counterfeit tobacco is supplied to predominantly Kurdish gangs, who then sell it under the counter in mini-marts, according to Harries.

 Having attended the scene of the fire, the BBC asks the arsonist for her opinion. 

The chief executive of the anti-smoking charity Ash, Hazel Cheeseman, says that although the illicit tobacco market has declined over the last few decades, it remains a concern. 

 The illicit tobacco market has quite obviously grown over the last few decades, which is why it is a news story. It has grown incredibly quickly in the last four years. HMRC's estimates don't reflect that because they based on untenable assumptions. It is a mathematical impossibility for only 10% of the cigarette market to be illicit. The true figure is around 25-30% and the figure for rolling tobacco is considerably higher.  The BBC doesn't challenge Cheeseman's claim despite reporting in the same article that "Illegal cigarettes, tobacco and vape products were seized from 3,624 shops across England, Scotland and Wales in 2024-25". How many were seized decades ago, one wonders?  The recent surge in black market sales has been driven by some exceptionally large tax hikes pushing smokers to breaking point. So what does the fool Cheeseman suggest? 

She urges the government to pass legislation to toughen licensing rules for the sale of tobacco, and gradually phase it out altogether.

 Phasing it out is a euphemism for prohibition which would make all sales illicit but, as history repeatedly tells us, would not eliminate the sales.  The article doesn't mention the all-important tax issue, although it did get a passing mention in another BBC article a few weeks ago:  

Professor Georgios Antonopoulos, criminologist at Northumbria University Newcastle, believes money is at the heart of it. "Legal tobacco products in the UK are subject to some of the highest excise taxes in the world," he says.

 Having followed events in Australia, we can see how this will play out. We have just reached the point where fears about the illicit trade can no longer be dismissed as tobacco industry scaremongering. That is a start. The next stage will involve more money being spent on enforcement, which will fail to make more than a dent in the problem. Politicians will then make a big deal about increasing fines and prison sentences for smugglers. That won't make much difference either. We may then see some pointless legislation, such as Cheeseman's suggestion of 'tougher licensing rules'. That will only inconvenience legitimate traders.  The preposterous Tobacco and Vapes Bill will be portrayed as somehow offering the solution even though it will obviously make things worse. Tobacco duty revenues will continue to plummet. The black market may or may not turn dramatically violent, as it has in Australia - it's too early to tell - but a time will come when the BBC and a few MPs start to admit that the root of the problem is the unaffordability of legal tobacco. In Australia, the ABC and the Guardian have been hugely supportive of 'tobacco control' but even they have had to admit that its excesses have led to disaster and that taxes are simply too high. We will only reach that point when the scale of the problem is understood by the general public - a process sped along in Australia by more than 200 firebombings and several murders. That time is not far enough and when it comes, the denialists in 'public health' will have switched from claiming that there is no problem to claiming that the problem is now so big that the genie cannot be put back in the bottle and therefore can't be solved by lowering taxes. Mainstream politicians will agree, saying that lowering taxes would 'send the wrong signal'. And so nothing will change, but the truth will at last be acknowledged. 

Semi-criminalisation

I've written about the Online Safety Act and the broader issue of semi-criminalisation in Britain for The Critic . 

Downloading random VPNs comes with risks of its own and opens up a whole new world of illicit online activity from free Premier League football to the Dark Web. But there is a deeper reason to feel uneasy about this unintended, albeit predictable, consequence of paternalistic regulation. By driving another wedge between the state and the individual, it further normalises rule-breaking in a country where casual lawlessness is becoming part of daily life. A law-abiding society cannot long endure if the median citizen thinks that the law is an ass.  

The breakdown of trust can be seen most clearly when the ordinary man or woman does not share the moral certainties of the governing class. Among smokers, a collapse in tax morale — the intrinsic motivation to pay taxes — has led to a huge rise in the consumption of illegal tobacco in recent years. Smokers no longer feel any obligation to pay taxes that are designed to impoverish them to a government that vilifies them. Cannabis smokers learn from an early age to be suspicious of a police force that they might otherwise respect. Motorists who are faced with 20mph speed limits that were introduced by people who hate private transport have no scruples about flouting the law.  

Closely analogous to the new age verification law are the affordability checks that punters are expected to undergo when they spend more than the state thinks is good for them on a gambling website. These have never been put into law and instead rely on a Kafkaesque system in which operators are expected to second guess what spending threshold the Gambling Commission thinks is appropriate. Faced with the threat of multi-million pound fines if they fail to spot a problem gambler, the companies err on the side of caution and request bank statements and other documents from any high-rolling customer. Unsurprisingly, many of these people do not want to share this private information and close their account. But they do not stop gambling. Instead, they switch to offshore gambling websites that are not regulated by the Gambling Commission. All they need to do that is — you guessed it — a VPN.

This all happens without any meaningful protest from the individuals involved. There are enough viewers of “adult content” to swing an election if they mobilised in their self-interest, but no group of consumers is less likely to stand up and be counted. Instead, like millions of other ordinary souls who find themselves semi-criminalised by an over-bearing state, they roll their eyes and find a workaround.

 

Minimum pricing - a warning from 2017

Writing about gambling on my Substack yesterday, I had cause to mention an article I wrote for Spectator Health in 2017 which has long since disappeared (along with the rest of the Spectator Health website). I reprint it below as a reminder that I warned that minimum alcohol pricing would not help pubs and would likely damage them.

 

It’s the economy, stupid – why minimum pricing won’t work

5th September 2017 

There was a reminder last week that politics produces strange bed-fellows when the Institute of Alcohol Studies (formerly known as the UK Temperance Alliance) promoted the pub industry’s view of alcohol policy.

Pubs have traditionally been the temperance lobby’s greatest foe. The American prohibition movement was not spearheaded by the Anti-Alcohol League or the Anti-Drunkenness League but by the Anti-Saloon League. Concerns about people drinking at home are a more recent, British phenomenon. For decades, the temperance lobby preferred people to be drinking at home than in bars, but years of excessive regulation and high taxes have led to thousands of pub closures and they are no longer seen as such a threat. People are now buying most of their drink in the off-trade and so, like Willie Sutton who robbed banks because ‘that’s where the money is’, the temperance lobby targets the off-trade because that’s where the drink is.

In a classic example of Bootleggers and Baptists behaviour, the hospitality industry has found common cause with anti-alcohol campaigners in going after supermarkets. The survey found that most publicans want higher taxes on alcohol in supermarkets and lower taxes on alcohol in pubs. Rent-seeking doesn’t get more blatant than this, but the Institute of Alcohol Studies half-agrees. It never wants lower taxes anywhere – so it ignored the issue of pub prices in its press release – but it is firmly behind the call for higher off-trade prices.

The IAS was even more excited by the pub trade’s support for minimum pricing. Putting a minimum price on a unit of alcohol had the backing of 41 per cent of the publicans surveyed, against only 22 per cent against. Partial support from the drinks industry for this temperance policy is nothing new. When David Cameron was weighing up the policy in 2013, the chief executives of several pub chains publicly urged him to go ahead with it.

A minimum unit price of around 60p will raise the price of most of the alcohol sold in supermarkets but will have virtually no effect on pubs. It is easy to see why this appeals to publicans. They are, however, being short-sighted. Once the government starts setting prices for one part of the market, it is likely to extend its reach into others. In Canada, where a form of minimum pricing exists in several provinces, campaigners want a minimum price in bars and they want it to be twice as high as the minimum price in off-licences. In Alberta and Manitoba, bars have been subject to minimum pricing laws for years.

Appeasement is always a risky strategy and it is doubtful whether the pub trade’s support of minimum pricing would pay off even in the short-term. They are assuming that people are forsaking pubs because of the gulf between pub prices and supermarket prices. They are further assuming that people would visit pubs more if this gap were narrowed, even if pub prices did not fall.

This logic is appealing because a drink bought in a supermarket is a substitute for a drink bought in a pub, but there are good reasons to think that minimum pricing could have quite the opposite effect on pubs. To see why, we need to consider the counter-intuitive finding of the economists Jensen and Miller who noticed that low income consumers in China buy more rice when the price of rice goes up. The same phenomenon is said to have taken place when the price of potatoes rose in nineteenth century Ireland: people bought more of them. The law of demand predicts that a rise in price should lead to fewer sales, so how do we explain this Giffen behaviour?

Like most economic issues, it comes down to limited resources. If your budget for food is tightly constrained, you need to get the most calories for your dollar. Carbohydrates such as rice and potatoes are the cheapest sources of energy in many countries. When times are relatively good, the poor can afford to buy meat, but if the price of carbohydrates rises, they have a choice between eating less meat or eating less food.

Let’s say that 50 cents buys you rice containing 2,000 calories or meat containing 500 calories. If you have a food budget of one dollar a day, you can buy both, but if the price of rice suddenly rises by 50 per cent, what do you do?

2,000 calories of rice now costs you 75 cents. If you keep buying your 50 cents of meat, you will have to buy a third less rice and go hungry. It makes more sense to sacrifice the relative luxury of meat and buy more rice.

This may seem an extreme example that has little to do with the pub trade in wealthy countries, but it is really just a question of budgeting. If you have a set budget and fixed preferences, a rise in prices is likely to push you towards the cheapest option.

Now let’s say you want to drink ten beers a week and have £20 to spend. You have one beer a day from the supermarket at £1 each but on Saturday you go to the pub and have four beers at £3.50 each. The effect of minimum pricing will be to raise the price of your supermarket beer to £1.50. If you want to keep drinking ten beers a week, you will have to cut down to three bottles in the pub and buy an extra bottle from the supermarket.

In practice, that is only one option reflecting one set of preferences. A consumer might instead decide to increase their beer budget or to do without a couple of beers in mid-week. But of all the options available, surely the least tempting is to cut down to five or six beers a week and buy them all in The Dog and Duck – and yet that is what the consumer would have to do for minimum pricing to benefit pubs.

If the price of food in supermarkets rose by 50 per cent, no one would predict a surge in demand for expensive restaurants. On the contrary, higher supermarket prices would make consumers eat out less to save money for groceries. So it is with alcohol. Consumers are well aware that pub prices are higher than supermarket prices. If pubs were no more than an alternative location in which to buy alcohol, everybody would go to the supermarket and the pubs would be empty.

Pubgoers are buying much more than a drink. They are buying an experience, with ambience, company, service and entertainment. There is no doubt that some consumers would prefer to drink at home less and visit the pub more, but they are unable to do so because of high prices in the off-trade. But minimum pricing is not going to make a pint in a pub cheaper. It is just going to leave people who buy alcohol in supermarkets with less disposable income. Unless these people have a highly inelastic demand for pubs and a highly elastic demand for alcohol – a strange combination of preferences – they will need to cut expenditure elsewhere to maintain their alcohol intake. Buying fewer drinks in the on-trade is one way of doing this.

I am not saying that alcohol is a Giffen good (ie. a product that sells more when the price goes up) but if you look at on-trade and off-trade drinks as rival products it is easy to see how raising the price of the latter could lead to Giffen behaviour. For consumers who have a particular desired consumption level and are quite indifferent as to where they drink it, buying more of the cheapest option and less of the pricier option is a rational response, even though the cheapest option is more expensive than it used to be. Supermarket beer should be seen as the equivalent of rice and potatoes, and pubs as the equivalent of meat. When budgets are tight, we cut down on the luxuries first.

 

Postscript

Pubs in Scotland closed at twice the rate of pubs in England once minimum pricing was introduced. 

 

HMRC has its head in the sand about illicit tobacco

A study published last week estimated that 26.8 billion cigarettes are smoked each year in the UK. The state-funded pressure group Action on Smoking and Health (ASH) described this as a “staggering figure” and claimed that it was a “stark reminder of the deadly toll of inaction”. Seizing the opportunity to remind people about the ludicrous Tobacco and Vapes Bill, they said: “Everyday that passes without this legislation is a day lost in protecting our children from addiction and improving public health.”

It is ASH’s job to say things like this, of course, but it is nevertheless perverse to claim that smoking has been the subject of political inaction. It would be truer to say that “tobacco control” is one of the few things that pygmy politicians have been obsessed with in this era of displacement politics. And since the generational tobacco sales ban will not have any effect on anyone until its first victims turn 18 in January 2027, there is no need for parliamentarians to make haste. 

Whether 26.8 billion is a “staggering figure” depends on how you look at it. It seems a big number but it is simply a function of 7.5 million smokers consuming an average of 10.4 cigarettes a day. Both of these figures are the lowest on record, no doubt as a result of all that government “inaction”. The study also found that only 5.5 per cent of smokers consume more than 20 cigarettes a day. When it comes to snouts, Britain has become a nation of lightweights.

The more interesting thing about 26.8 billion cigarettes being smoked each year is that only 14 billion cigarettes were sold legally in the UK last year. On top of that, legal sales of hand-rolling tobacco account for between 4.5 billion and 6.3 billion cigarettes (depending on how many fags you think can be made from a kilogram of loose baccy), but that still leaves between a quarter and a third of all the cigarettes smoked unaccounted for. 

 Read the rest at The Critic . 

Just rejoice at this news

Some good news for consumers and taxpayers in the Politico newsletter... 

EU funding cuts force health NGOs to slash staff

Health NGOs are making staff redundant and leaving Brussels after the European Commission failed to pay out expected grants, leaving some without most of their funding for the rest of the year.

Get in!

The European Public Health Association (EUPHA), based in Utrecht, the Netherlands, said it would file a complaint to the European ombudsman over the missing grants, which forced it to close its Brussels office and make its head of advocacy in the Belgian capital redundant in June.

“It’s a huge issue when the Commission agrees to fund us, sign [agreements] with us, but withholds it without explanation. Not only it betrays trust, it also probably breaches its own legal obligations,” said Charlotte Marchandise, executive director of EUPHA. 

In the unlikely event that you are feeling sorry for the EUPHA, bear in mind that the appalling Martin McKee used to be its president and it has long had a reprehensible anti-vaping stance.

EUPHA is one of 30 health NGOs that signed agreements with the European Commission outlining their planned activities last year, in anticipation of operating grants for the following financial year. Operating grants go toward daily overhead costs like staff salaries and without which many NGOs say they cannot survive. 

They're not really NGOs then, are they?

The call to apply for those grants never arrived, however, while Commission officials have informally told NGOs to expect no funding.

 Based. 

Other health NGOs have had to take similarly dramatic cost-cutting measures after learning no grants from the Commission would arrive this year. Last week, the European Public Health Alliance (EPHA), one of the biggest health NGO networks in Brussels, confirmed it would cut five of its 13 staff. 
Haha! YES!!
Incredibly, it gets even better... 

The European Alcohol Policy Alliance (Eurocare) is also in danger of losing two of its four staff, Anamaria Suciu, policy and advocacy manager, told POLITICO. The Commission’s operating grant typically accounts for 60 percent of Eurocare’s funding in a given year, she said. 

 Why on earth is the EU giving fat sums of money to a temperance group? And yes, it is a temperance group. Even if you believe the specious reasoning that the EU needs to fund 'civil society' lobbying as a counterweight to industry lobbying, why have they picked a bunch of teetotal Methodists to represent civil society? Make it make sense. Politico is firmly on the side of the Brussels blob for some reason... 

Brussels is an increasingly inhospitable environment for NGOs since the European election last year.

 Cry me a river. 

Under a right-wing majority led by the European People’s Party, lawmakers such as the European People’s Party’s Dirk Gotink — appointed to head a probe into NGO funding on Wednesday — claim NGOs have used European money to “shadow lobby” for green policies. A POLITICO fact-check found little evidence for shadowy lobbying, however. EU funding is publicly disclosed and allows NGOs to counter the lobbying activities of better-resourced private interests.

 This is what the self-serving activists of the sockpuppet state claim. In fact, these NGOs usually either have a vast amount of money from big foundations or are heavily reliant on the EU. If they have foundation money, they don't need more and if they can't raise money from the public then why should anyone care what they think? There's a good interview with Dirk Gotink in which you can see what he actually means by 'shadow lobbying'. Keep up the good work, sir!

High taxes fuel illicit trade - shocker!

It's almost surreal to hear people insist that the black market in tobacco is (a) negligible, and (b) unrelated to tobacco taxes. In places like Australia and the UK, this not only contradicts our "lived experience" but also basic economics. 

And yet the UK government is so sanguine about the illicit trade that it didn't bother modelling the impact of the generational tobacco ban on it, and the recently leaked tobacco tax report from the European Commission confidently proclaimed that... 

“while price levels may act to incentivise the illicit trade of tobacco products (ITTP) the main driver is not the relative levels of price or taxation, instead other drivers are at play such as the permeability of borders; the severity of sanctions for offenders; the geographic proximity to illegal production and/or distribution sites…  In other words, there is no direct proportionality between tax levels and the level of illicit trade” 

 I've been doing some work on this using the most up-to-date cigarette tax/price/affordability figures and looking at their relationship with illicit cigarette sales. The results shouldn't surprise anyone. There is a very strong relationship. For example... 
 Epicenter published my findings yesterday. You can read the report here. 

 

 

The crack cocaine of amusement arcades

You probably know them as amusement arcades but the Gambling Commission knows them as Adult Gaming Centres. The pressure group Gambling With Lives claims that they offer “the most addictive gambling products out there”. The Association of Directors of Public Health has complained about their “proliferation”. The Local Government Association wants more powers to “curb their “spread”. GB News found a “gambling survivor” who dubbed them the “crack cocaine of gambling”. And, inevitably, the Guardian has been writing a series of pearl-clutching articles about them, bemoaning the fact that they are “disproportionately concentrated in Britain’s most-deprived areas” (i.e. seaside towns and city centres). 

If this all sounds familiar it is because it is a carbon copy of the campaign against betting shops and fixed-odds betting terminals (FOBTs) a decade ago. The anti-gambling lobby are mostly focused on suppressing online gambling these days, but they have found time to relive past glories and go after slot machines again. FOBTs were de facto banned in 2019 when the stake limit was lowered to an unplayable £2. The number of FOBTs in Britain fell from a peak of 34,949 in 2015 to zero in 2021. As anyone could have predicted, players switched to low-stake machines in betting shops and amusement arcades or went online. 

 Read the rest at The Critic . 

Tobacco and Vapes Bill - live!

The video of the IEA's recent panel discussion about the generational tobacco sales ban (AKA Prohibition 2.0) is now available. It includes some legal knowledge from Sir Robert Buckland, some strong words from Clive Bates, and a few thoughts from my good self.

HMRC greatly underestimates the black market in tobacco

Since writing about HMRC's implausible claim that only 6.9% of cigarettes in the UK were 'non-duty paid' in 2022/23, they have produced new figures claiming that the figure for 2023/24 was 10.5% (oddly, the previous year's number has been upgraded to 9.1%). I have been trying to think of any scenario in which this could be true. It is not just that the estimate doesn't not match what I'm seeing on the street, but that it is mathematically impossible under any reasonable set of assumptions. Put simply, HMRC estimates the amount of non-duty paid tobacco being sold by estimating the total consumption of tobacco (number of smokers x average annual cigarette consumption per smoker) and subtracting the amount of legal tobacco sold (via tax receipts). 

HMRC's tobacco bulletin shows that the number of cigarettes sold legally fell from 23.6 billion in 2021 to 13.2 billion in 2024, a decline of 44.4%. 

The ONS's Annual Population Survey says that the number of smokers in the UK fell from 6.6 million in 2021 to 6 million in 2023, a decline of 9%. ONS figures are not yet available for 2024, but the Smoking Toolkit Study reports that smoking prevalence in England fell from 14.7% in 2021 to 14.2% in 2024, a decline of less than 4% (accounting for population growth the decline in the number of smokers is even smaller). Quite clearly, there has not been a 44.4% decline in the number of smokers since 2021, nor anything close to it. 

Are smokers consuming fewer cigarettes? Apparently not. On the contrary, the ONS's Adult Smoking Habits in Great Britain survey finds that average daily cigarette consumption per smoker rose from 9.8 in 2021 to 11.3 in 2023. (The figure for 2021 is a modelled predicted estimate, but the 2023 is nonetheless higher than in any year since 2016.) An academic study published last year found that the decline in average cigarette consumption per smoker has plateaued since 2019. 

Have smokers switched to hand-rolling tobacco? Perhaps, but the tobacco bulletin also shows a decline in the legal sale of rolling tobacco, from 8.6 million kilograms in 2021 to 4.5 million kilograms in 2024, a fall of 47.6%. Overall, using the conventional estimate of how many cigarettes are made from a kilogram of loose tobacco, the number of cigarettes bought on the legal market in the UK fell by 45.5% between 2021 and 2024. 

HMRC also produces a tax gap estimate for hand-rolling tobacco. It is higher than the cigarette tax gap estimate at 22.9% but, implausibly, the figure for 2023/24 is the lowest estimate on record. Its estimate for the tobacco tax gap overall is 13.8%, fractionally higher than in 2022/23 but still one of the lowest on record. 

None of this stands up to basic arithmetic. We have a 45.5% decline in the quantity of duty-paid cigarettes sold (including hand-rolled cigarettes), but no decline in the number of cigarettes consumed per smoker and an overall decline in the number of smokers that is vastly smaller than 45.5%. 

It is a mathematical impossibility than only 10.5% of cigarettes consumed in the UK are non-duty paid. Even if there was no black market for tobacco in 2021 - an impossible proposition - it would now be much bigger than that now. 

For the sake of argument, let's assume that the next ONS smoking prevalence survey shows a 15% reduction in the number of smokers between 2021 and 2024 (although there is no reason to think that the decline is that large). Given what we know about daily cigarette consumption, this should translate into a 15% reduction in duty-paid tobacco sales if the non-duty paid market stays the same. This would mean legal sales of manufactured cigarettes fell from 23.6 billion in 2021 to 20.1 billion in 2024. In reality, only 13.6 billion cigarettes were sold in 2024, a shortfall of 6.5 billion cigarettes that can only have come from the non-duty paid sector. 6.5 billion equates to 32% of the total and that is with the profoundly unrealistic assumption that no non-duty paid cigarettes were sold in 2021. 

In other words, if there was no non-duty paid market in 2021, non-duty paid cigarettes would make up 32% of the market in 2024. If we assume, as HMRC does, that 8.8% of the market was non-duty paid in 2021, total cigarette sales (including non-duty paid) would have been 25.9 billion. If cigarette consumption then fell by 15%, the total market would be 22 billion in 2024, but we know that legal sales were 13.2 billion in 2024 so the non-duty paid market must therefore be 40% of the total.  A similar calculation can be done with hand-rolling tobacco and will produce a similar finding (since the decline in legal sales is almost identical). 

One can play around with these figures as much as one likes using different assumptions, but in no reasonable scenario do non-duty paid cigarettes make up 10.5% of the market, nor does non-duty paid tobacco overall make up 13.8%. It seems to me that HMRC's model is broken.