Japan Tobacco International (JTI) has called for a single official estimate of the UK’s illicit tobacco market that brings together government data, physical evidence and other research, following a report by Action on Smoking and Health (ASH) questioning the reliability of tobacco industry-funded estimates.
Responding to ASH’s report, Beyond the headlines: the reality of illicit tobacco in the UK, JTI shared with Asian Trader that there was a “striking gulf” between official government figures and industry estimates, arguing that differences in research methods made it difficult to compare the results directly.
HM Revenue and Customs (HMRC) estimates that illicit products accounted for 12 per cent of cigarette consumption and 19 per cent of hand-rolling tobacco consumption in 2024-25.
JTI said its own Pack Swap survey estimated that illicit products accounted for 34 per cent of cigarettes and 50 per cent of hand-rolling tobacco during the same period. Separately, the industry’s Empty Pack Survey estimated that 46 per cent of cigarettes were illicit.
Nicky Small, Corporate Affairs and Communications Director at JTI UK, told Asian Trader, "There is indeed a striking gulf between official government figures and our own estimates. HMRC uses survey data and trend analysis to build its estimates.
"Industry research differs by using physical evidence - analysing packs collected - with JTI’s Pack Swap survey estimating 34% and 50% of cigarettes and hand-rolling tobacco respectively being illicit for 2024-25, and the industry Empty Pack Survey estimating 46% of cigarettes being illicit for the same period."
Small argued that neither approach should be treated as definitive.
"No single estimate should be treated as definitive – inherently different methodologies will drive different results. HMRC has acknowledged the uncertainty around its own estimates, which it rates as ‘high’ and is exploring other methods, including wastewater analysis.
"But this should not be a debate about whose number is right, instead a shared effort to build the most reliable picture possible with one official estimate, that brings survey data, physical evidence and other credible research together – because we cannot fix what we cannot accurately measure."
The comments come as ASH’s report released last week questioned tobacco industry-funded research suggesting that illicit tobacco accounts for a substantially larger share of UK consumption than HMRC estimates.
The report raises concerns about the methodology used in industry-funded research, including reliance on discarded cigarette pack surveys and tobacco industry information. It also questions estimates of total cigarette consumption in the UK, arguing that some figures are difficult to reconcile with national smoking surveys.
ASH says official figures show that annual illicit cigarette consumption fell from 15.1 billion cigarettes in 2000/01 to 1.9 billion in 2024/25, a decline of almost 90 per cent. It also reports an 81 per cent fall in illicit hand-rolling tobacco consumption over the period.
The organisation argues that these figures challenge claims that higher tobacco taxes and stricter smoking regulations inevitably increase illicit trade. However, it acknowledges that illegal tobacco remains a problem, citing its links to organised crime, lost tax revenue and access to cheap tobacco.
ASH is calling for stronger enforcement, improved coordination between Trading Standards and police, and a comprehensive tobacco retail licensing scheme with penalties for retailers selling illicit products or selling to children.


