Laurence Steinberg, Ph.D.
Distinguished University Professor
Laura H. Carnell Professor of Psychology
Sir Cyril Chantler
Plain Packaging Review
C/o King’s College London
Room 1.2 Hodgkin Building
Guy’s Campus
London
SE1 1UL
By Mail and By Email (Christopher.1.cox@kcl.ac.uk)
Re: Independent review of the public health evidence on standardized packaging of
tobacco
7 January 2013
Dear Sir Cyril,
I write this letter in response to your call for evidence on whether the introduction of
standardized packaging is likely to lead to a decrease in the consumption of tobacco,
including in particular a decrease in the risk of children taking up and becoming addicted
to smoking. I have considerable expertise in the area of adolescent judgment, decisionmaking, and risk-taking, and have published widely on these topics.1 I have considered
the topic of smoking by minors extensively in recent years.
1
I am the Distinguished University Professor and Laura H. Carnell Professor of Psychology at Temple
University in Philadelphia and have published extensively on adolescent judgment, decision-making, and
risk-taking. I am a former President of the Society for Research on Adolescence (the largest professional
organization of scholars interested in this stage of development) and of the Division of Developmental
Psychology of the American Psychological Association. I am the author of more than 350 scholarly
articles and numerous books on adolescent development, including a leading textbook on the subject that is
used in colleges in the USA and elsewhere.
Department of Psychology  Temple University  Philadelphia, PA 19122
215-204-7485
215-204-5539 (fax) lds@temple.edu
It is common ground between us, and among right-thinking people generally, that
adolescents should be discouraged or prevented from taking up smoking. There are many
policy options available to governments to achieve this, and you have been asked to
consider whether the introduction of standardized packaging in England would be likely
to be effective. My view is that it would not. The introduction of standardized packaging
would be unlikely to affect underage smoking, either in terms of initiation or progression
from experimentation to regular use.
Adolescents’ experimentation with, and use of, tobacco is best viewed as a specific
example of their propensity to engage in risk-taking more generally. Measures to prevent
or reduce youth smoking are only likely to be effective if they are informed by scientific
research on risk-taking and decision-making in this age group. I know of no scientific
evidence that suggests, nor would my understanding of the current research on adolescent
decision-making suggest, that cigarette packaging is relevant to adolescents’ decisions to
experiment with or continue smoking.
These opinions are consistent with the contents of the November 2010 report on
“Adolescent Decision-Making and the Prevention of Underage Smoking” (copy
enclosed) that I prepared at the request of external legal counsel to Japan Tobacco
International in response to a consultation request from the European Commission with
regard to the proposed Second Tobacco Products Directive and to assist Governments
and other stakeholders considering standardized packaging and similar regulatory
proposals. On the specific question before you, I concluded in 2010 in that report that:
“… there is no evidence that changes in cigarette packaging affect adolescents’
experimentation with or use of cigarettes… [T]he impact of changes in cigarette
packaging on adolescent smoking is, at best, likely to be very small” (paragraph 75). My
view remains unchanged today, despite the further studies published since 2010 (which I
have reviewed) and the introduction of standardized packaging in Australia.
In passing, I should say that while I understand that Japan Tobacco International is, via
their external legal counsel, aware that I am writing to you, the views that I set out below
are my own, based on my experience as an independent scientist with extensive
knowledge based on research in the area of adolescent decision-making. They reflect the
best contemporary science on this topic, which I summarize below. I would be happy to
discuss my views further with you directly, if you would find that helpful.
In greater detail:
1. In light of the fact that smoking during adolescence substantially elevates the
likelihood for regular adult smoking, and, consequently, for the serious health
consequences associated with chronic smoking, many have called for policies and
Department of Psychology  Temple University  Philadelphia, PA 19122
215-204-7485
215-204-5539 (fax) lds@temple.edu
practices designed to reduce the number of adolescents who experiment with tobacco
and the number of those who experiment who progress to regular smoking, as well as
measures designed to encourage regular adolescent smokers to quit. It appears that
the most significant reductions in smoking prevalence are likely to come from
policies and practices that reduce the number of individuals who try cigarettes, rather
than from those that encourage cessation among regular smokers (Gilpin et al., 2006).
So it makes sense to focus on policy measures that will discourage or prevent
adolescents from experimenting with cigarettes.
The question is whether
standardized packaging is likely to have that effect, in light of what we know about
adolescents’ decision-making and their risk-taking behaviour generally including why
adolescents experiment with tobacco.
2. The high rate of risky behavior among adolescents relative to adults, despite massive,
ongoing, and costly efforts to educate teenagers about its potentially harmful
consequences (including a tremendous investment in health education), has been the
focus of much theorizing and empirical research by developmental scientists for at
least three decades (Steinberg, 2008). This work has disproved several widely-held
beliefs about adolescent risk-taking: for instance, that adolescents are more likely
than adults to believe they are invulnerable; that adolescents are deficient in their
information-processing, or that they think about risk in fundamentally different ways
from adults; and that adolescents do not perceive risks where adults do, or are less
risk-averse than adults. None of these assertions is correct. Indeed, most studies find
few, if any, age differences in individuals’ evaluation of the risks inherent in a wide
range of potentially dangerous behaviors (e.g., smoking, driving while drunk, having
unprotected sex). Research consistently shows that adolescents are well aware of the
health risks of smoking2 but that some start smoking anyway. Given the nearuniversal acknowledgement among teenagers in the UK of the health risks of
smoking, changing cigarette packaging will likely have no impact on adolescents’
awareness of the potential harmful consequences of smoking.
3. Adolescents are knowledgeable, logical, reality-based, and accurate in the ways in
which they think about risky activities, including smoking – no different from adults,
in fact. But they do engage in higher levels of risky behavior than adults. The
explanation for this apparent paradox which is highly relevant to your assessment, for
reasons that I explain later – is explained by more contemporary models of adolescent
e.g. “When asked about their beliefs about smoking, the majority of pupils reported strong agreement
with the negative effects of smoking. Almost all the pupils thought smoking can cause lung cancer (99%),
makes your clothes smell (97%), harms unborn babies (97%), can harm non-smokers health (96%) and can
cause heart disease (93%).” The NHS Information Centre, Lifestyles Statistics, “Statistics on Smoking:
England” (2012), at p.47; available at: https://catalogue.ic.nhs.uk/publications/publichealth/smoking/smok-eng-2012/smok-eng-2012-rep.pdf.
2
Department of Psychology  Temple University  Philadelphia, PA 19122
215-204-7485
215-204-5539 (fax) lds@temple.edu
decision-making that draw on recent advances in developmental neuroscience. The
dominant framework to emerge is what has been called a “maturational imbalance” or
“dual systems model” (Casey et al., 2011; Steinberg, 2010). This posits that
heightened risk taking in adolescence is a natural by-product of the asynchronous
maturation of the “reward system” or “incentive processing system” of the brain,
which is responsive to emotion, reward and novelty, and the “cognitive control
system,” which is critical for impulse control, emotion regulation, and planned
decision making. It has been suggested that the incentive processing system becomes
especially aroused early in adolescence, and that this arousal pushes the adolescent to
engage in sensation-seeking in the pursuit of immediate rewards, but that this arousal
takes place before the cognitive control system has fully matured. Later in
adolescence and in early adulthood, there is a decrease in the incentive system’s
responsiveness to rewarding and emotionally arousing social stimuli and
improvements in the cognitive control system. This leads to a decline in risk-taking
behavior that continues into adulthood. There is growing support in the scientific
literature for numerous aspects of the dual-systems model, in the fields of both
neurobiology and psychology (see Engle, 2013, for a recent series of articles on the
adolescent brain).
4. These more contemporary models explain a series of observations about adolescent
decision-making that inform why minors take risks and why some experiment with
cigarettes:
a. Adolescents are especially sensitive to rewards (Galvan, 2010), including
rewarding stimuli like social status or admiration (Burnett et al., 2011). Thus,
when faced with two alternative courses of action (e.g., trying versus forgoing
smoking), adolescents will pay greater attention to the potential rewards of each
alternative (e.g., gaining the admiration of one’s peers versus pleasing one’s
parents) than to their risks.
b. Compared to adults, adolescents are more likely to focus on the immediate
consequences of a decision, rather than think about the longer-term ones
(Steinberg et al., 2009). This does not appear to be due to poor impulse control
but instead to the generally weaker orientation to the future evinced by young
people, especially during the early adolescent years (i.e., before 16). Thus, it is not
so much that teenagers are incapable of delaying gratification (as one might see in
a small child) as it is that they just prefer not to.
c. Compared to adults, adolescents are more likely to pay attention to and focus on
the immediate and short-term drawbacks of a choice (e.g., that smoking will
cause bad breath, or that not smoking will lead to social exclusion by peers) than
Department of Psychology  Temple University  Philadelphia, PA 19122
215-204-7485
215-204-5539 (fax) lds@temple.edu
on the longer-term ones (e.g., that smoking may cause lung cancer or heart
disease). To a sensation-seeking 15-year-old focused on what he experiences to be
the here-and-now rewards of smoking, preventing experimentation with cigarettes
by emphasizing the possibility of developing a disease 40 years in the future is not
likely to be a deterrent. Conversely, making cigarettes less affordable to minors
has been proven to be an effective short-term deterrent to their smoking3; in
contrast, the introduction of standardized packaging emphasizing the costs of
smoking, and, in particular, the potential long-term health consequences of
smoking would not have any impact within the relevant short term timeframes of
adolescent decision-making.
d. Adolescents’ decisions about risk-taking are more easily swayed than are adults’
by the influence of their peers. Susceptibility to peer influence is high during early
and mid-adolescence and declines steadily until about age 18, at which point it
levels off (Steinberg & Monahan, 2007). Peer influence tends to exacerbate
adolescents’ sensitivity to rewards and their preference for immediate rewards
(Albert et al., 2013), which may lead them to engage in more risky behavior when
they are with their peers than when they are alone (Gardner & Steinberg, 2005).
The role of peer and societal influences as the primary drivers for smoking uptake
by adolescents is widely recognized (e.g., Osaki et al., 2008).
e. Owing to immaturity in brain regions associated with cognitive control,
adolescents are less able to regulate their behavior than are adults (Casey et al.,
2011; Steinberg et al., 2008). Although it is unlikely that adolescents’ decisions to
purchase cigarettes are impulsive, because in order to circumvent age restrictions
on the sale of tobacco, they must devise some sort of plan (e.g., decide which
retail store is least likely to ask for ID, rehearse what they will say to the
salesclerk in case ID is requested or to a stranger or someone they know over 18
to ask for a proxy purchase), their decision to try cigarettes for the first time may
be made on the spur of the moment – and particularly in circumstances where peer
influence is strong and cigarettes are readily available.
f. Adolescents’ decision-making is more easily disrupted by emotional and social
arousal than is that of adults (Albert & Steinberg, 2011). An important
implication of this is that conventional research that finds few differences between
3
The price of cigarettes and the ease of availability of tobacco have repeatedly been shown to be key
factors in smoking uptake by minors (Allison et al., 1999; Li, Stanton, & Feigelman, 2000; Petraitis et al.,
1995; Sen & Wirjanto, 2009). Research indicates that adolescents, because of their relatively more limited
discretionary income, are especially sensitive to cigarette pricing; changes in cigarette prices have an
especially large impact on underage smoking, which rises as cigarette prices fall and declines as prices rise
(Francis, 2000; Leverett et al., 2002; Waller et al., 2003).
Department of Psychology  Temple University  Philadelphia, PA 19122
215-204-7485
215-204-5539 (fax) lds@temple.edu
adolescents and adults in the way they think about risk may reach very different
conclusions than would be the case if the same decision making were studied
when individuals were actually in the moment. To be more concrete about it,
asking questions during a focus group or telephone survey about the potential
risks of smoking or the impact of packaging on likely cigarette use may yield very
different responses than one would get if one asked the same questions to a group
of adolescents who were drinking beer with their friends at a party (and this is a
significant limitation on the subset of the standardized packaging research that
does consider adolescent behavior). Accordingly, it is wise to interpret the results
of research on adolescents’ responses to hypothetical changes in packaging or
other aspects of marketing with great caution. How adolescents respond to a
hypothetical cigarette package when they are alone and completing a research
questionnaire may bear no or little resemblance to how they respond to a real
package when they see one at a party.
5. Taken together, and applied specifically to standardized packaging, these features of
adolescent decision-making suggest that:
a. The desire to experiment with risky activity, including smoking, is a normative
aspect of adolescent behavior. It is highly improbable that the color or other
features of cigarette packaging that would be addressed by the introduction of
standardized packaging have any impact on an adolescent’s desire to engage or
not to engage in risk-taking behavior of this sort.
b. Given adolescents’ innate and natural propensity for risk-taking, the sheer
availability of cigarettes within the adolescent’s social network is likely a stronger
influence on his or her initial experimentation with smoking than is the type of
cigarettes (e.g., brand, flavor, filtered or non-filtered) that are available or the
packaging in which these cigarettes are contained. It is highly improbable that an
adolescent who is interested in trying smoking will decline a cigarette from a
friend because of the packaging of the cigarette that is offered, or agree to smoke
that cigarette because of its packaging.
c. Because of this, measures which focus on packaging are unlikely to make any
significant impact on experimentation or use of tobacco products by adolescents.
Measures that focus on the availability of cigarettes (i.e., removing them from
adolescents’ social networks, for example, by raising the minimum legal purchase
age or by criminalizing proxy purchasing, as I understand has been done in
Scotland) and on their price (e.g., raising the tax on them) are far more likely to be
effective.
Department of Psychology  Temple University  Philadelphia, PA 19122
215-204-7485
215-204-5539 (fax) lds@temple.edu
d. Those adolescents who may find standardized packaging less appealing are most
likely to take measures to personalize their packages similar to the way many
adolescents do for their smartphones. There has been a sharp rise in sales of such
personalized cases or labels since the introduction of graphic health warnings or
standardized packaging (in Australia).
e. Adolescents, who cannot legally buy cigarettes, often obtain them from friends,
often without seeing the packaging in which the cigarettes were initially supplied.
We also know that minors who smoke in England and Wales are more likely to
ask someone else to buy them for them (proxy purchasing) rather than try to buy
them in shops, or to obtain them from friends or family4 – here, too, they may
well not see cigarette packaging before obtaining the cigarettes. Thus, the ways in
which adolescents, who may be experimenters or irregular users, and adults, who
are likely to be regular smokers, obtain cigarettes are very different, which
diminishes the reach and force of policies aimed at regulating how cigarettes are
packaged.
f. A frequently-stated goal of standardized packaging is to make on-package health
warnings more salient. However, as already noted, it is abundantly clear that
adolescents are aware of and understand the risks of smoking and know that it has
harmful long-term health consequences. It is simply that they privilege short-term
reward over long-term risk and are more susceptible to making decisions about
smoking experimentation “in the moment” and under the influence of their peers.
Therefore, even if standardized packaging were shown to increase the prominence
of health warnings, this would in my view have no influence on adolescent
experimentation with, or use of, tobacco products.
g. There are relatively few studies that consider the effect of standardized packaging
on the smoking behavior of adolescents (as opposed to adults), and those that do
exist have used similar methodologies to those used in the adult studies. One must
be very cautious in attempting to extrapolate the results of studies involving adults
“Smoking, drinking and drug use among young people in England in 2012”, National Statistics and
HSCIC (2012). Available at: https://catalogue.ic.nhs.uk/publications/public-health/surveys/smok-drin-drugyoun-peop-eng-2012/smok-drin-drug-youn-peop-eng-2012-repo.pdf. At page 9: “Rather than trying to buy
cigarettes in shops, pupils were more likely to have asked someone else to buy cigarettes for them (proxy
purchasing) […] In 2012, 8% of pupils had asked somebody to buy cigarettes on their behalf, and nine out
of ten (88%) were successful at least once.” At page 17: “Pupils who smoked were most likely to get
cigarettes by being given them by other people (69%), typically by other friends (57%).”
4
Department of Psychology  Temple University  Philadelphia, PA 19122
215-204-7485
215-204-5539 (fax) lds@temple.edu
to adolescents, given the differences in adults’ and adolescents’ decision-making
that I have described.
h. I know of no studies that directly address whether levels of smoking initiation or
progression among adolescents would be different, were standardized packaging
required. Instead, studies ask consumers to imagine how they might behave if
they had the opportunity to purchase cigarettes in standardized packages.
Demonstrating that, when presented with a particular pack design by a researcher,
a person will say that he or she would be more likely to quit smoking, or never to
take it up, is not the same as demonstrating that the packaging actually leads to a
change in behavior. There is a long tradition of research showing that it is far
easier to change what people say they will do than to change their actual behavior.
i. The choice presented to research subjects in the typical standardized packaging
experiment is between a product in a conventional package and one in a
standardized package. This might be informative to questions about the sorts of
packages that a manufacturer interested in selling a product ought to choose.
However, if the question under consideration is whether mandating standardized
packaging would reduce the prevalence of smoking, it is not at all clear that
research comparing standardized and conventional packaging is the least bit
informative. If someone is thirsty, he may prefer a beverage in a colorful bottle to
one in a plain bottle. But it is unlikely that, if given the choice between a plainly
bottled beverage and nothing, a thirsty person will choose to forgo purchasing any
beverage at all. Indeed, in one focus group study in which smokers rated
cigarettes in plain brown packages less appealing, the participants explicitly noted
during follow-up questioning that this preference was a consequence of the
comparison between standardized packaging and other forms of packaging, and
that they did not believe that standardized packaging would reduce the appeal of
smoking if all cigarettes were sold in this form (Moodie, Mackintosh et al., 2011).
6. Overall, it is unlikely that standardized packaging will affect underage smoking at all,
either in terms of initiation or progression, given that research indicates (1) that
adolescents’ decisions to smoke are heavily influenced by the behavior of their peers
and are hardly impacted by the communication of information about the health risks
of smoking; (2) that the desire to experiment with risky activity, including smoking,
is a normative aspect of adolescent behavior; and (3) that adolescents are likely to
obtain cigarettes from friends, rather than retail outlets, and in many cases where the
cigarettes in question have been removed from their package. The extant research on
the likely impact of standardized packaging measures provides little evidence to
suggest the contrary. Limiting adolescents’ access to cigarettes, through the more
vigilant enforcement of minimum legal purchase age (MLPA) laws and through
Department of Psychology  Temple University  Philadelphia, PA 19122
215-204-7485
215-204-5539 (fax) lds@temple.edu
increasing the price of cigarettes are proven strategies for reducing underage smoking
and should continue to be the focus of attempts to deter adolescents from
experimenting with tobacco.
Please do not hesitate to contact me. at lds@temple.edu, if you would like to discuss
these insights further. Copies of the various references above are enclosed.
Sincerely,
Enc. (hard copy only) - various papers.
Department of Psychology  Temple University  Philadelphia, PA 19122
215-204-7485
215-204-5539 (fax) lds@temple.edu
References
Albert, D., & Steinberg, L. (2011). Judgment and decision making in adolescence.
Journal of Research on Adolescence, 21, 211-224.
Albert, D., Chein, J., & Steinberg, L. (2013). The teenage brain: Peer influences on
adolescent decision-making. Current Directions in Psychological Science, 22, 114-120.
Allison, K. et al. (1999). Adolescent substance use: Preliminary examinations of school
and neighborhood context. American Journal of Community Psychology, 27, 111–141.
Burnett, S., Sebastian, C., Kadosh, K., & Blakemore, S-J. (2011). The social brain in
adolescence: Evidence from functional magnetic resonance imaging and behavioural
studies. Neuroscience and Biobehavioral Reviews, 35, 1654-1664.
Casey, B. J., Jones, R., & Somerville, L. (2011). Braking and accelerating of the
adolescent brain. Journal of Research on Adolescence, 21, 21-33.
Engle, R. (2013). The teenage brain. Current Directions in Psychological Science, 22 (2)
(entire issue).
Francis, D. (2000). Dramatic rise in teenage smoking. NBER Digest. October 25.
Galvan, A. (2010). Adolescent development of the reward system. Frontiers of Human
Neuroscience, 4, 1-9.
Gardner, M., & Steinberg, L. (2005). Peer influence on risk-taking, risk preference, and
risky decision-making in adolescence and adulthood: An experimental study.
Developmental Psychology, 41, 625-635.
Gilpin. E. et al. (2006). What contributed to the major decline in per capita cigarette
consumption during California’s comprehensive tobacco control programme? Tobacco
Control, 15, 308-16.
Leverett, M. et al. (2002). Tobacco use: The impact of prices. The Journal of Law and
Medical Ethics, 30 (suppl), 88-95.
Li, X., Stanton, B., & Feigelman, S. (2000). Impact of perceived parental monitoring on
adolescent risk behavior over 4 years. Journal of Adolescent Health, 27, 49–56.
Moodie, C., Mackintosh, A. et al. (2011). Young adult smokers’ perceptions of plain
packaging: a pilot naturalistic study. Tobacco Control, 20, 367-373.
National Statistics and Health and Social Care Information Centre (2012). Smoking,
drinking and drug use among young people in England in 2012.
Department of Psychology  Temple University  Philadelphia, PA 19122
215-204-7485
215-204-5539 (fax) lds@temple.edu
NHS Information Centre (2012). Statistics on Smoking: England.
Osaki, Y. et al. (2008). Decrease in the prevalence of smoking among Japanese
adolescents and its possible causes: Periodic nationwide cross-sectional surveys.
Environmental Health and Preventive Medicine, 13, 219–226.
Petraitis, J., Flay, B., & Miller, T. (1995). Reviewing theories of adolescent substance
use: Organizing pieces in the puzzle. Psychological Bulletin, 117, 67–86.
Sen, A., & Wirjanto, T.(2009). Estimating the impacts of cigarette taxes on youth
smoking participation, initiation, and persistence: Empirical evidence from Canada.
Health Economics, 19, 1264–1280.
Steinberg, L. (2008). A social neuroscience perspective on adolescent risk-taking.
Developmental Review, 28, 78-106.
Steinberg, L. (2010). A dual systems model of adolescent risk-taking. Developmental
Psychobiology, 52, 216-224.
Steinberg, L., Albert, D., Cauffman, E., Banich, M., Graham, S., & Woolard, J. (2008).
Age differences in sensation seeking and impulsivity as indexed by behavior and selfreport: Evidence for a dual systems model. Developmental Psychology, 44, 1764-1778.
Steinberg, L., & Monahan, K. (2007). Age differences in resistance to peer influence.
Developmental Psychology, 43, 1531-1543.
Waller, J. et al. (2003). The early 1990s cigarette price decrease and trends in youth
smoking in Ontario. Canadian Journal of Public Health, 94, 31-35.
Department of Psychology  Temple University  Philadelphia, PA 19122
215-204-7485
215-204-5539 (fax) lds@temple.edu