Illicit Tobacco in Australia 2023
May 2024

Australian Illicit Tobacco Market 2023, April 2024 FTI Consulting Inc. 1

Table of Contents
Contents
Disclaimer .......................................................................................................................................... 4
Acronyms and Abbreviations ............................................................................................................ 5
Glossary ............................................................................................................................................. 7
Executive Summary ........................................................................................................................... 9
1

2

3

4

5

About this study ...................................................................................................................... 14
1.1

The impact of illicit tobacco in Australia .......................................................................... 14

1.2

Purpose of this study ........................................................................................................ 14

1.3

Context for the 2023 study .............................................................................................. 15

1.4

Structure of this report .................................................................................................... 21

Australian Tobacco Market Estimation ................................................................................... 23
2.1

Components of the tobacco market measured in this study .......................................... 23

2.2

Methodology for estimating legal tobacco ...................................................................... 24

2.3

Methodology for estimating illicit tobacco ...................................................................... 25

Legal Tobacco Consumption ................................................................................................... 28
3.1

Total legal tobacco ........................................................................................................... 28

3.2

Legal domestic consumption............................................................................................ 28

3.3

Legal non-domestic consumption .................................................................................... 30

3.4

Key drivers ........................................................................................................................ 31

Illicit Tobacco Consumption .................................................................................................... 38
4.1

Summary of total illicit tobacco consumption in Australia .............................................. 38

4.2

Components of illicit tobacco consumption .................................................................... 39

4.3

Unbranded tobacco .......................................................................................................... 40

4.4

Contraband ....................................................................................................................... 43

4.5Counterfeit ....................................................................................................................... 46

4.6

Domestic illicit plains ........................................................................................................ 46

4.7

Seizures............................................................................................................................. 47

Conclusion ............................................................................................................................... 49
Australian Illicit Tobacco Market 2023, April 2024 FTI Consulting Inc. 2

5.1

Rising consumption of illicit tobacco................................................................................ 49

5.2

Access to illicit tobacco .................................................................................................... 49

5.3

Profitability of illicit tobacco ............................................................................................ 49

5.4

Further regulation and enforcement required ................................................................ 50

Appendix A: Estimating Unbranded Tobacco Consumption........................................................... 52
Appendix B: Empty Discarded Packs Survey and Estimating Other Illicit Components ................. 55
Appendix C: Non-Domestic Illicit Whites ........................................................................................ 58
Appendix D: Key Seizures in 2023 ................................................................................................... 59

Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 3

Disclaimer
This report was prepared in accordance with the scope of work and the instructions provided byImperial Tobacco Australia Limited (ITA), Philip Morris Limited (PML) and BAT Australia Ltd (BATA)
and was prepared exclusively for their use. This report is not intended for general circulation or
publication. There are no third-party beneficiaries with respect to this report, and FTI Consulting
does not accept any liability to any third party.
Information furnished by others, upon which all or portions of this report are based is believed tobe reliable but has not been independently verified, unless otherwise expressly indicated. Public
information and industry and statistical data are from sources we deem to be reliable. However,
we make no representation as to the accuracy or completeness of such information. FTIConsulting accepts no responsibility for actual results or future events.
The opinions expressed in this report are valid only for the purpose stated herein and as of thedate of this report. No obligation is assumed to revise this report to reflect changes, events orconditions, which occur subsequent to the date hereof.
All decisions in connection with the implementation or use of advice or recommendations
contained in this report are the sole responsibility of the client. This report does not represent
investment advice, nor does it provide an opinion regarding the fairness of any transaction to any
and all parties.

Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 4

Acronyms and Abbreviations
Term

Definition

ABF

Australian Border Force

ABS

Australian Bureau of Statistics

ACIC

Australian Criminal Intelligence Commission

AFP

Australian Federal Police

AIHW

Australian Institute of Heath and Welfare

AUD

Australian dollar

ATO

Australian Taxation Office

AWOTE

Average Weekly Ordinary Time Earnings

BATA

BAT Australia Ltd

CAGRCompounding Annual Growth Rate

CCC

Crime and Corruption Commission

CPI

Consumer Price Index

EDPS

Empty Discarded Pack Survey

FTI Consulting

FTI Consulting (Australia) Pty Ltd

ITA

Imperial Tobacco Australia Limited

ITTF

Illicit Tobacco Taskforce

g

Grams

kg

Kilograms

KPMG LLPKPMG Limited Liability Partnership

LCI

Living Cost Index

NSW

New South Wales

NVWG

National Vaping Working Group%

Percentage / per cent

PML

Phillip Morris Limited

QPS

Queensland Police Service

Q1

Calendar year quarter one (January 1 to March 31)
Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 5

Q2

Calendar year quarter two (April 1 to June 30)

Q3

Calendar year quarter three (July 1 to September 30)

Q4

Calendar year quarter four (October 1 to December 31)

RBA

Reserve Bank of Australia

RMR

Roy Morgan Research

RYO

Roll-your-owntTonnes (metric, 1000kg)

TGA

Therapeutic Goods Administration

UK

United Kingdom

USA

United States of America

WPI

Wage Price Index

Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 6

Glossary
TermDefinition

Consumer survey

A survey of adult smokers (those over 18 years old) who smoke daily(at least five times per week) conducted by Roy Morgan Research. The
survey sample is designed to be representative of the population byusing Single Source data to weight respondents based on location,age, gender, income, occupation and work status of smokers.

A survey conducted every six months by WPSM (and formerly AC
Nielsen and MSIntelligence) comprising a sample of 12,000 empty
cigarette packs collected across 16 cities, covering circa 75% of the
Empty discarded pack
population. The survey records pack size, based on the number ofsurveycigarettes, and identifies cigarette packs that are ‘non-domestic’ toenable estimation of the proportion of cigarettes that are nondomestic.

Euromonitor

Global market research on consumer products, commercial industries,
demographics trends and consumer lifestyles that is used as a primarysource of data for tobacco consumption rates across key source
countries to estimate the extent of non-domestic legal sales fromtourists visiting Australia.

Circana scan data

Circana scan data reflects the sales made to consumers and arereflective of the market size to the extent that each sale is scanned(and therefore included in the aggregate sales data collected andprovided to FTI Consulting). To estimate legal domestic sales, a rangeof data sources is examined including Circana scan data and industry
estimates based on exchange of sales and off-take data.

Contraband

Cigarettes brought into Australia illegally or acquired without excise
taxes being paid and illegally re-sold in the market. This category
includes genuine products (sold legally in overseas markets) brought
into a country in amounts exceeding the personal allowance; inAustralia, this limit is 25 cigarettes or 25 grams of RYO per person.

Counterfeit

Illegally manufactured cigarettes that carry the trademark/branding ofa legally manufactured brand without the consent of the trademark
owner. Counterfeit cigarettes are also known as fake cigarettes.

Domestic illicit plains

Flows of Illicit Whites brands that have packaging designed for thedomestic (Australian) market.

Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 7

Illicit whites

Cigarettes that are usually manufactured in one country or market but
have been smuggled across borders during their transit to Australia,
where they have limited or no legal distribution and are sold without
the payment of tax.

Legal domestic sales

The estimated volume or value of sales of manufactured (cigarette)and roll-your-own products.

Non-domestic
cigarettes

Cigarette packs that either do not carry health warnings or packaging
compliant with Australian regulations, relate to brands not typicallysold in Australia, and/or include identifying marks from other markets
such as tax stamps. Non-domestic cigarettes include both legal(referred to as ‘non-domestic legal’) and illicit products (known as‘contraband’ which incorporates ‘non-domestic illicit whites’
excluding ‘domestic illicit plains’).

Non-domestic illicit
whitesBrands that do not have plain packaging designed for the Australiandomestic market. In previous years, this has been referred to as ‘Illicit
Whites (non-domestic)’. In the report, non-domestic illicit whites areincluded in the contraband measurement.

Non-domestic legal

Legitimate tobacco purchased duty free or abroad within personal
allowance limits (in Australia, this limit is currently 25 cigarettes or
25g of roll-your-own).

Non-domestic
incidence

The proportion of non-domestic cigarettes recorded in the empty
discarded pack survey which generally have coloured or branded
packaging.

Total manufactured
cigarettes
consumption

The sum of legal domestic sales of manufactured cigarettes and total
non-domestic manufactured cigarettes.

Unbranded tobacco

Illegal loose-leaf tobacco which does not require duty to be paid anddoes not typically carry labelling or health warnings. It is sold andconsumed either in roll-your-own (RYO) form (called ‘chop chop’) or
inserted into empty cigarette tubes. It is commonly sold in both bags
and boxes. Blended estimates for unbranded tobacco consumption
adopt an average of the consumer survey results for the calendar
year, or most recent quarters, where an equal weighting is applied toresults from each quarter.

Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 8

Executive Summary
About this study
FTI Consulting Australia has been commissioned to estimate the size of the tobacco market inAustralia for the 2023 calendar year, including the proportion of illicit tobacco consumption. This
follows an earlier study completed by FTI Consulting in 2022, and previous studies undertaken
annually since 2007.
Monitoring the extent of illicit tobacco consumption is important to inform potential
governmental responses, since the illicit tobacco trade impacts consumers, government revenue
from excise and customs duties, and has broader community and economy-wide impacts.
This study seeks to:■ Estimate the volume of tobacco consumption in Australia, including the extent to which
tobacco consumed is legal or illicit■ Highlight trends in estimated tobacco consumption including legal and illicit tobacco over time
■ Estimate the loss of government revenues associated with the current rate of illicit tobacco■ Identify the extent to which further government action may be required to tackle the illicit
tobacco trade.

Total tobacco consumption in Australia declined in 2023
The total volume of tobacco consumed in Australia continued to drop over the last year. In 2023,
total tobacco consumption declined by 12.3%, from 11 million kg in 2022 to 9.7 million kg in
2023 (refer Figure 1).
Figure 1: Tobacco consumption by category, 2013-2023

Note: In the presentation of results, ‘Contraband’ also includes domestic illicit plains. Consistent with previous studies, nondomestic legal sales (a small component) are not shown.
Source: Previous studies of Illicit tobacco in Australia, 2013-2022, and FTI Consulting analysis for 2022 and 2023.
Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 9

This decline was predominantly due to the fall in the consumption of legal tobacco by 18.8% to
6.9 million kg. The volume of illicit tobacco in the past 10 years has moved between 2.0 to 3.0
million kg per year. Illicit tobacco volumes have not been impacted by the overall market decline,
having increased in volume in 2023.

Consumption of illicit tobacco is approaching 29% of the tobacco market
In 2023, illicit tobacco accounted for 28.6% of total tobacco consumption. The proportion of total
tobacco consumption in Australia made up of illicit tobacco increased 5.7 percentage points
since 2022 and exceeds pre-pandemic levels of circa 14% (Figure 2). The decline in total tobacco
consumption in 2023 was partly offset by an increase in illicit tobacco consumption of 9.5%, from
2.5 million kg to 2.8 million kg.
Figure 2: Illicit tobacco consumption, 2009-2023
30%

8

23.5%

7
20.4%
6

12.8% 12.2%

4

2
1

22.9%

16.9%

5

3

19.3%

28.6%

13.5%
11.5%

1.8
0.2
1.5

2.2

2.2

2.0

16.7%

14.0%

9.1%

2.4
0.1

14.7% 14.4% 14.3% 14.7%

2.4

0.4

0.5

1.3

1.4

1.4

1.0

2.6
1.2
1.4

2.5

2.4

2.3

1.1

0.9

1.2

1.4

1.1

1.4

2.1

3.0
1.6

1.1
0.9

18.2%

1.3

2.2

2.1

1.0

0.6

1.1

1.4

2.5
0.9

25%

20%

15%
2.8

10%

1.1
5%

1.5

1.6

0

Illicit tobacco as % of total consumption

Tobacco consumption (million kg)

90%2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023
Unbranded

ContrabandCounterfeit

2024 AIHW Update illicit tobacco %Illicit tobacco % of total consumption

Previously forecast illicit tobacco %Source: Previous illicit tobacco studies in Australia for historical data, FTI Consulting analysis (2022-2023) using various data
sources; and FTI Consulting re-estimation of unbranded tobacco consumption (2020-2022).

Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 10

Consumption of legal tobacco is declining in the face of readily available andcheaper illicit alternatives
Legal tobacco sales have decreased by 18.8% from 8.5 million kg to 6.9 million kg. This reflects
both a decline in the Australian Institute of Health and Welfare’s (AIHW) estimated daily smoking
incidence1 and a rise in the accessibility, affordability and consumption of illicit alternatives.
In 2023, nearly half of consumer survey respondents reported that it was easier to purchase illicit
unbranded tobacco products. Similarly, 71.0% of survey respondents were aware of unbranded
tobacco in Q4 2023, compared to 59.4% in Q4 2022 – an increase of 11.6 percentage points. This
reflects a longer-term trend of consumers reporting in every survey since Q4 2020 that it is easierto purchase illicit tobacco.
In 2023, legal tobacco prices rose by over 11% compared to December 2022, a rate well in excessof the Wage Price Index (WPI). The relative price of illicit tobacco declined across all illicit
tobacco categories to between 15.4%-37.3% of the price of legal cigarettes.
Also, the rising incidence of vaping illustrated deficiencies in the regulatory framework aroundvapes (also referred to as e-cigarettes) throughout 20232. Vaping incidence increased from 6.1%
to 7.9% (+400,000) over the year to September 2023,3 and it is estimated that less than 8% ofvapes were purchased legally.4 In 2023, it was far cheaper (at least 18 times) to consume illicit
vape products than legal cigarettes.5

Total consumption of illicit tobacco increased by nearly one tenth in 2023, withmore smokers turning to illicit tobacco
Consumption of illicit tobacco increased by 9.5% to 2.8 million kg in 2023. Consumption of both
unbranded tobacco and contraband (including domestic illicit plains and non-domestic illicit
whites) increased in 2023 (by 6.5% and 15.7%, respectively). Counterfeit remained stable,
decreasing by 1.6%, to 0.1 million kg – representing a small component of illicit tobacco.
Unbranded tobacco consumption accounted for the largest portion of illicit consumption in 2023
(58.3% of total illicit consumption). The increase in the volume of unbranded tobacco
consumption was driven by increases in consumer participation; more consumers reported that

1 The Australian Institute of Health and Welfare’s 2022-23 Household Drug Survey estimate that the daily smoking

incidence in Australia decreased from 11.0% in 2019 to to 8.3% in 2022-23.
2

Office of Impact Analysis, “Proposed reforms to the regulation of vapes: Impact Analysis,” Department of Healthand Aged Care – Therapeutic Goods Administration (October 2023),
https://oia.pmc.gov.au/sites/default/files/posts/2024/01/Impact%20Analysis%20%20Proposed%20reforms%20to%20the%20regulation%20of%20vapes.PDF.
3
Incidence data, Roy Morgan Single Source, Moving Annual Total September 2023; FTI Calculations using ABS
resident population (3101.0; TABLE 59. Estimated Resident Population By Single Year Of Age, Australia).
4
Office of Impact Analysis, “Proposed reforms to the regulation of vapes: Impact Analysis,” Department of Healthand Aged Care – Therapeutic Goods Administration (October 2023),
https://oia.pmc.gov.au/sites/default/files/posts/2024/01/Impact%20Analysis%20%20Proposed%20reforms%20to%20the%20regulation%20of%20vapes.PDF.
5
FTI Consulting calculations based on industry data of illicit vape and legal cigarette prices.
Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 11they had purchased illicit unbranded tobacco in 2023, increasing by 4.6 percentage points sinceQ4 2022, to 37.3%.6 The blended quantity of unbranded tobacco purchased per person (acrossQ2 and Q4) has stayed relatively constant between 2022 and 2023.
Increases in contraband were due to the 2.5 percentage point increase in the non-domestic
inflow of manufactured cigarettes to 14.8% in 2023, predominantly from ‘Unspecified’ countries(typically, the Middle East). Non-domestic incidence increased across all 16 sampled population
centres in Q4 2023 compared to Q4 2022, particularly for non-major population centres, where
non-domestic incidence rose from 8.6% to 12.6%. Though, it remains highest in major population
centres, at 16.6%.

Increased enforcement required to tackle illicit tobacco
The rise in illicit tobacco consumption coincides with evidence of increasing seizures of illicit
tobacco by law enforcement agencies. Between 2021-22 and 2022-23, the Illicit Tobacco
Taskforce (ITTF) reported an increase in total tobacco seizures of 21.7% to 2,178 tonnes. Basedon the estimated consumption of 2,766 tonnes of illicit tobacco identified in this study, it isestimated that the Taskforce manages to detect and seize less than half of the amount of illicit
tobacco supplied.
Appropriate resourcing of law enforcement agencies is essential to continue to detect and seize
illicit tobacco from the Australian tobacco market. However, given tobacco consumers pay
amongst the highest prices for tobacco in the world, this alone will not be sufficient to reduce
the attractiveness to organised criminal entities and individuals in the supply of illicit tobacco toAustralian consumers. Further legislative amendments have been introduced that may further
impact on legal tobacco consumption, however governments need to take targeted action to
reduce the ease of access, attractiveness and participation in illicit tobacco in Australia.
If excise was collected on illicit tobacco consumed in 2023, it would generate $4.85 billion in
additional government revenue based on 2023 excise rates. This is set to increase over time, withthe excise rate on legal tobacco to increase annually by 5.0% (in addition to standard average
weekly ordinary time earnings or ‘AWOTE’ indexation) for three years, starting from 1 September
2023 until 1 September 2025.7
Recognising the foregone excise revenue from the current consumption of illicit tobacco andbroader community and economy-wide impacts, there is a need to consider further targetedmeasures to address the illicit tobacco trade in Australia.

6

Using the approach to estimating the share of regular smokers that use unbranded tobacco adopted in previous
studies, to maintain the consistency between studies.
7
Australian Taxation Office, “Excise duty rates for tobacco,” Australian Taxation Office (22 February 2024),
https://www.ato.gov.au/businesses-and-organisations/gst-excise-and-indirect-taxes/tobacco-and-excise/exciseduty-rates-for-tobacco.
Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 12

1. About thisStudyAustralian Illicit Tobacco Market 2023, April 2024 FTI Consulting Inc. 13

1 About this study
1.1 The impact of illicit tobacco in Australia
Increases in the illicit tobacco trade undermine the objectives of legal measures such as tobacco
products’ taxation and regulation, and cost both the government and community. The tobacco
supply chain impacts a range of sectors in the economy including government, firms (including
retailers), and households. Any shrinkage in the legal tobacco sector, due to the presence of illicit
tobacco or other illicit substitutes will have repercussions across the entire economy, as well as
impacts on consumers from consuming products outside of the regulated market. As such, it isimportant to monitor the illicit tobacco trade.
Moreover, illicit tobacco impacts the community through its links to organised criminal activity.
In recent years, the operations of the Illicit Tobacco Taskforce (ITTF) have shown that the illicit
tobacco trade has generated significant profits for serious and organised crime groups, providing
the platform for further illicit activities such as drug importation and terrorism.8 The social
impacts of illicit tobacco have included violent crime and arson.

1.2 Purpose of this study
FTI Consulting Australia (FTI Consulting) has previously undertaken expert studies examining
illicit tobacco in Australia and other neighbouring countries. These studies aimed to measure thescale and impact of illicit tobacco, which has direct and indirect flow on effects throughout theeconomy including encouraging consumption of cheap tobacco, reducing government revenue,
and disadvantaging industries, businesses and employees operating in the formal (legal)
economy.
The purpose of this study is to:■ Estimate the volume of tobacco consumption in Australia, including the legal and illicit
components of the market■ Highlight trends in estimated tobacco consumption including legal and illicit tobacco over time
■ Estimate the loss of government revenues associated with the current rate of illicit tobacco■ Identify the extent to which further government action may be required to tackle the illicit
tobacco trade.
Changes in the Australian tobacco market, including the extent to which there is evidence ofillicit tobacco, have been monitored and reported on annually for over a decade. This is thesecond study that FTI Consulting has undertaken to quantify tobacco consumption and the8

Michael Phelan, “Media Statement: Illicit tobacco,” Australian Criminal Intelligence Commission (26 April 2022),
https://www.acic.gov.au/media-centre/media-releases-and-statements/media-statement-illicit-tobacco.
Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 14

proportion of illicit tobacco consumption in Australia. To ensure comparability between studies 9,
FTI Consulting has been asked to maintain a consistent approach with that pursued previously.

1.3 Context for the 2023 study
The findings of the Illicit Tobacco in Australia 2023 study are set against the backdrop of several
important social and economic factors. These include:■ Inflationary pressures reducing real household incomes■ An estimated decline in adult smoking incidence■ Increasing availability of illicit tobacco products■ Changes in domestic tobacco regulation, albeit many of these changes are yet to be fully
implemented■ Significant social impacts of illicit tobacco.
Inflationary pressures reducing real household incomes
Throughout 2023, the Consumer Price Index (CPI) remained significantly higher than WPI in eachquarter (refer Figure 3)10 and remains elevated compared to the pre-COVID-19 average (fromDecember 2013 – December 2019). Even the underlying inflation rate, which excludes volatile
price changes, exceeded WPI at a rate of 5.2% during 2023 (trimmed mean, September 2023
quarter).11
Figure 3: CPI and WPI trends, 2014-2023

Source: Australian Bureau of Statistics, Consumer Price Index and Wage Price Index, Australia, October 2023.

9

FTI Consulting (2022), KPMG LLP (during 2012 – 21), Deloitte in 2010 and 2011, and PWC in 2007 and 2009.
Australian Bureau of Statistics, “Consumer Price Index, Australia,” Australian Bureau of Statistics (25 October2023), https://www.abs.gov.au/statistics/economy/price-indexes-and-inflation/consumer-price-index-australia/sepquarter-2023.
11
Ibid.
10

Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 15

As shown in Figure 4, since pandemic payments have ended, Australian household disposable
income has continuously decreased over each quarter, declining by 6.8% over the 12 months to
Q2 2023.
Figure 4: Real household disposable income, 2013-2023

Pre-Pandemic
Trend Line

Pandemic
Stimulus

Source: Greg Jericho12; using ABS 5206.0 (Australian National Accounts: National Income, Expenditure and Product), Reserve Bank
of Australia Statement on Monetary Policy November 2023.

As a result, households are continuing to experience financial stress as their purchasing powerhas decreased. The rising cost of legal tobacco products due to regular excise increases alongsidedecreasing household income is expected to further drive demand for cheaper, illicit
alternatives.
Declining smoking incidence
Numerous reliable sources including Euromonitor, the Australian Bureau of Statistics (ABS) andthe AIHW show that the prevalence of regular smoking in Australia has decreased significantly
over the last 15 years.
The National Drug Strategy Household Survey, conducted by AIHW every three years, provides
the national daily smoking incidence estimate used to calculate (re-calculate) unbranded tobacco
consumption in Australia (a major component of illicit tobacco consumption).
The AIWH survey indicated that the national (daily) tobacco smoking rate for people aged 14 andover dropped from 11.0% in 2019 to 8.3% in 2022-23 (refer Figure 5). The smoking population(daily) in 2022-23 is estimated to be approximately 1.8 million, compared to 2.3 million in 2019.

12

Greg Jericho, “The past financial year was brutal for household incomes – and it seems the recovery isn’t coming
anytime soon,” The Guardian (23 November 2023),
https://www.theguardian.com/business/grogonomics/2023/nov/23/the-past-financial-year-was-brutal-forhousehold-incomes-and-it-seems-the-recovery-isnt-coming-anytime-soon.
Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 16

This study has drawn on the most recent AIHW survey results to reflect the revised estimate of
the smoking population. This has led to a modest revision of the 2020 to 2022 unbranded
tobacco and total tobacco consumption estimates.13
Figure 5: Total estimated smoking population in Australia, 2008-2023
2.9

Smoking population (million)

2.7
2.5
2.3
2.1
1.9
1.7
1.5
2009

2011

2013

2015

FTI Consulting Original forecast estimate

2017

2019

2021

2023

2024 AIHW Update

Source: AIHW, National Drug Strategy Household Survey, 2007, 2010, 2013, 2016, 2019 and 2022-23.

Increasing availability of illicit tobacco and illicit alternatives
An important driver of the decline in legal tobacco consumption is the widespread availability
and use of illicit vape products. While our approach to estimating total tobacco consumption
does not include vaping, in 2023, it is estimated that more than 1.6 million Australians haveconsumed e-cigarette products.14 This represents an increase of over 30% over the previous 12
months, equivalent to an increase of over 400,000 consumers.

13

Compared to previous estimates, the impact of the AIHW revision on total tobacco consumption is -0.3% in 2020, 1.3% in 2021, -0.7% in 2022 and -2.8% in 2023. The impact on the total illicit tobacco consumption in volume terms
is -1.7% in 2020, -7.0% in 2021, -7.0% in 2021, -3.2% in 2022, and -9.0% in 2023. Differences between years reflect
the share of unbranded tobacco consumption in total illicit tobacco consumption. Without updates to AIHW
smoking incidence, the proportion of the tobacco market comprised by illicit tobacco would be higher.
14
Australian Association of Convenience Stores, “New data exposes Australia’s rampant vape black market,”Australian Association of Convenience Stores (1 November 2023), https://aacs.org.au/new-data-exposes-australiasrampant-vape-black-market/. The national incidence of vaping in September 2023 was 7.9%, compared to 6.1% in
September 2022.
Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 17

Taking in to account a recent survey by Roy Morgan (2023)15, a survey by the National Illicit Drug
Reporting System in 202216 and other evidence17, a report produced by the Department of
Health and Aged Care estimates that less than 8% of vapers have used a prescription to purchasevapes.
Figure 6 presents evidence about the increasing incidence of predominantly illicit vapes acrossAustralia, which is consistent with the finding of significant deficiencies in the regulatory
framework applicable to e-cigarettes in 2023.18 There is wide recognition that the enforcementof laws related to vaping has been insufficient throughout 2023, and that any reforms need to beappropriately enforced to be effective (refer Box 1).
Figure 6: Annual incidence and adult population of e-cigarette users, 2018-2023

Source: FTI Consulting using Roy Morgan Research Single Source, Moving Annual Total June 2018-2023 and ABS resident
population (3101.0; TABLE 59. Estimated Resident Population By Single Year Of Age, Australia).

15

The survey by Roy Morgan in 2023 found that only 8% of all Australian vapers have a prescription (refer Wakefield,
M. et al, cited in the Department of Health and Aged Care, 2023).
16
The survey by the National Illicit Drug Reporting System in 2022 reported that only 3% of vapers have a nicotine
prescription (refer Sutherland, R et al, cited in the Department of Health and Aged Care, 2023).
17
Office of Impact Analysis, “Proposed reforms to the regulation of vapes: Impact Analysis,” Department of Healthand Aged Care – Therapeutic Goods Administration (October 2023),
https://oia.pmc.gov.au/sites/default/files/posts/2024/01/Impact%20Analysis%20%20Proposed%20reforms%20to%20the%20regulation%20of%20vapes.PDF.
18
Ibid.
Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 18

Box 1: Vaping regulatory context, 2023

Throughout 2023, nicotine and non-nicotine e-cigarettes were treated separately inlegislation. Since 2021, sales of vapes containing nicotine in any other market, including
retail stores have been banned. National regulation stipulates that e-cigarette products
containing nicotine must only be supplied through a pharmacy or TGA process, to patientswith a prescription.
Yet, e-cigarette packaging is often mislabeled, with a study by the University of Wollongong
finding that most e-cigarettes in Australia have been found to contain nicotine, even if the
packaging says that it doesn’t.
A report published by the Therapeutic Goods Administration (under the Department of
Health and Aged Care) in October 2023 stated that ‘recent compliance and enforcement
efforts, and discussions between Commonwealth, state and territory officials, illustrated
deficiencies in the (then) current TG Act compliance framework for nicotine vapes andvaping devices, most notably the general need to test for the presence of nicotine before
compliance and enforcement action may be confidently undertaken’.
Source: Therapeutic Goods (Standard for Nicotine Vaping Products) (TGO 110) Order 2021; Australian Government Department of
Health and Aged Care, ‘About vaping and e-cigarettes’, December 2023; and Department of Health and Aged Care (TGA), 2023.
Proposed reforms to the regulation of vapes, October 2023.

In 2024, the Commonwealth Government introduced a new regulatory framework to address
vaping. This included a ban on the importation of disposable vapes from 1 January 2024, and aban on the importation, manufacture, supply, commercial possession and advertisement ofdisposable single-use and non-therapeutic vapes, due to become effective from 1 July 2024. Asof May 2024, a comprehensive framework has not been implemented to enforce the new
regulations, and the new regulatory model will only be effective if changes are enforced.19
Changes in domestic tobacco regulation
Commonwealth and jurisdictional governments have recently introduced or announced
legislative and policy changes that are aimed at strengthening controls on the tobacco trade andcombatting illicit tobacco. However, the impact of most of these changes is yet to be reflected in
the market and the results of this study.

19

Wisbey, M, “Recreational vaping ban one step closer”, Royal Australian College of General Practitioners (21 March
2024), https://www1.racgp.org.au/newsgp/professional/recreational-vaping-ban-one-step-closer
Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 19

In late 2023, a series of new tobacco regulations were introduced (and passed) under two
Commonwealth bills:■ Public Health (Tobacco and Other Products) Bill 2023
■ Public Health (Tobacco and Other Products) (Consequential Amendments and Transitional
Probisions) Bill 2023.
These regulations included changes to standardise product packaging, restrict the use ofadditives in tobacco products and strengthen health warnings on packaging and healthpromotion inserts. The requirements of the new legislation will come into full effect at a retaillevel on 1 July 2025.20
Various states have also introduced a range of changes to their tobacco legislation over 2023. For
example:■ Queensland – in June 2023, the retail supply or possession of illicit tobacco became a criminal
offence and penalties applied to suppliers of illicit tobacco.21 From 1 September 2024,
retailers and wholesalers of smoking products in Queensland must also have an approved
licence.22■ New South Wales – the Health Legislation Amendment (Miscellaneous) Act 2023 came into
effect on 30 October 2023 and has clarified the powers of inspectors to search premises, andprovided health officers powers to seize and dispose of tobacco and smokeless tobacco
products.23■ Victoria – while there have not been any regulatory or legislative changes in 2023, in March
2024, the Victorian Government announced its commitment to introducing a licensing scheme
for wholesale and retail tobacco sales.24
Increasing social impacts
The scale and severity of organised crime linked to illicit tobacco and the threat it represents tocommunities has been observed by law and enforcement agencies. Box 2 sets out the social
impacts of illicit tobacco in 2023.

20

Dr Matthew Thomas, Leah Ferris, “Public Health (Tobacco and Other Products) Bill 2023 [and] Public Health(Tobacco and Other Products) (Consequential Amendments and Transitional Provisions) Bill 2023,” Department of
Parliamentary Services, Parliament of Australia (16 October 2023),
https://parlinfo.aph.gov.au/parlInfo/download/legislation/billsdgs/9422796/upload_binary/9422796.pdf.
21
Queensland Government, “New smoking reforms,” Queensland Government (28 November 2023),
https://www.qld.gov.au/health/staying-healthy/atods/smoking/new-smoking-reforms.
22
Ibid.
23
Parliament of New South Wales, “Health Legislation Amendment (Miscellaneous) Bill 2023”, Parliament NSW (30October 2023) https://www.parliament.nsw.gov.au/bills/Pages/bill-details.aspx?pk=18487
24
VicHealth, “Victorian tobacco retail licensing scheme commitment,” VicHealth (28 March 2024),
https://www.vichealth.vic.gov.au/news-publications/media-releases/victorian-tobacco-retail-licensing-schemecommitment
Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 20

Box 2: Social impacts of illicit tobacco in 2023

In 2023, an increase in organised crime has been connected to the illicit tobacco trade. Since
March 2023, 71 incidences of arson were linked to the Victorian illicit tobacco and vapetrade. Fifty of the 71 incidences were on tobacco stores or vape stores, while the remaining
21 targeted gyms, cafes, and reception centres. Arson and violent crime connected to illicit
tobacco is believed to have arisen due to competition between criminals for profit from illicit
tobacco.
In response, Taskforce Lunar was formed in Victoria to combat the increased incidence ofarson and other violent crime associated with illicit tobacco. Taskforce Lunar has worked
closely with many other agencies and departments including the ABF, ACIC, AFP, ATO, Arson
and Explosive Squad, Gang Crime Squad, Echo Taskforce, Viper Taskforce, Financial Crime
Squad and Criminal Proceeds Squad. This level of multi-agency involvement highlights thescale and severity of organised crime and the threat it represents to communities.
The problem exists in other states. In August 2023, a multi-agency response to organised
crime syndicates in Queensland resulted in the seizure of over 8 million cigarettes, 3.74
tonnes of loose-leaf tobacco, and 60,000 vapes.
The Queensland Crime and Corruption Commission stated that the community may have noidea that their purchase of cheap, under the counter tobacco products is an engagement in
the illicit tobacco industry and funding the criminal enterprises of these organised crime
syndicates in Australia and beyond. Victoria Police also stated that the heightened criminal
activity is putting people’s lives at risk.
Source: Various media reports/other sources including Australian Border Force, “Warrants executed across Melbourne targeting
illicit tobacco,”, October 2023; Crime and Corruption Commission Queensland, “Multi-million-dollar money laundering
investigation smashes illicit tobacco and vape supply,” August 2023; Herald Sun, “Eye-watering amounts fuelling Melbourne’s
fiery tobacco wars,” April 2024; and Jason Kelly, “Inquiry into Vaping and Tobacco Controls,” Victoria Public Accounts andEstimates Committee (15 April 2024).

1.4 Structure of this report
The remaining structure of the report is as follows:■ Chapter 2 - Australian tobacco market estimation, provides an overview of key terminology,
components of the tobacco market, and our approach to estimation■ Chapter 3 - Legal tobacco consumption, provides estimates of legal tobacco consumed in
2023, market components and key drivers of the results and observations■ Chapter 4 - Illicit tobacco consumption, provides estimates of illicit tobacco consumed in
2023, including key drivers of the results and observations■ Chapter 5 – Conclusion, which provides a summary of the Australian tobacco market in 2023
and the need for further action by government.
Further information on the approach and results for estimating illicit tobacco consumption canbe found at Appendices A-C. Appendix D provides a summary of the key seizures in 2023.
Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 21

2. Australian
Tobacco Market
Estimation

Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 22

2 Australian Tobacco Market Estimation
2.1 Components of the tobacco market measured in this study
To estimate total tobacco consumption, we have used a consumption model that has commonly
been used by various studies to estimate tobacco consumption including illicit tobacco, and isconsistent with previous studies in Australia. Adopting as consistent an approach as possible toprevious studies is important to enable a reliable comparison of tobacco market trends between
periods.
Total tobacco consumption includes the total volume of both legal and illicit consumption for all
types of tobacco.
All legal products are imported as finished products as it is illegal to domestically produce
tobacco products in Australia.
All tobacco products sold in Australia are required to comply with Australian regulations
including plain packaging. Excise applies to all tobacco products including loose tobacco,
cigarettes, cigars and snuff (smokeless tobacco). Customs duties also apply to all tobacco
products as no tobacco products are currently manufactured in Australia.
The model takes a combination of data from various sources including smoking incidence dataand consumption patterns across the population to estimate illicit consumption. The
components of the tobacco market included in the consumption model are shown in Figure 7.
Figure 7: Components of the tobacco market included in the consumption model* Contraband includes non-domestic illicit whites.
Source: FTI Consulting.

This study does not estimate the consumption of cigars, shisha/waterpipe tobacco, snuff andbidis,25 and excludes emerging categories of illicit such as counterfeit pouches. It also excludes

25

Bidis are a type of hand-rolled cigarette commonly made in India and other parts of South Asia.
Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 23

nicotine and non-nicotine vapes: a rapidly growing (predominantly illicit) substitute fortraditional tobacco products.
Legal tobacco
Legal tobacco is made up of two components:■ Legal domestic tobacco are cigarettes or roll-your-own (RYO) products that are legally
manufactured overseas then sold in Australia, with relevant excise paid by the importing
company.
■ Legal non-domestic tobacco are legitimate tobacco purchases made overseas (or duty-free)and brought into Australia by travellers carrying tobacco within their personal allowance
limit.26
Illicit tobacco
Illicit tobacco comprises several components including ‘unbranded tobacco’ including ‘chop
chop’ (loose-leaf tobacco) and ‘pre-filled tubes’, and ‘manufactured cigarettes’ – covering‘contraband’, ‘illicit whites’ and ‘counterfeit’ cigarettes:■ Unbranded tobacco, the largest component of illicit tobacco, is illegal loose-leaf tobacco uponwhich no duty has been paid and which typically carries no labelling or health warnings. It issold and consumed either in RYO form (also called ‘chop chop’) or inserted into empty
cigarette tubes (‘pre-filled tubes’). It is commonly sold in both bags and boxes.
■ Contraband tobacco is legally manufactured cigarettes that are sold without applicable excise
taxes being paid. Contraband cigarettes can be brought into the country illegally or acquired
without taxes and illegally re-sold in the domestic market. This category can also include
products brought into the country in amounts exceeding the personal (duty-free) allowance.
■ Illicit whites include domestic illicit plains which are illicit white brands that have packaging
designed for the domestic Australian market. Alternatively, those brands that do not havepackaging for the Australian market are referred to as non-domestic illicit whites and areincluded in the contraband calculation.
■ Counterfeit cigarettes are illegally manufactured cigarettes that carry thetrademark/branding of a legally manufactured brand without the consent of the trademark
owner. Counterfeit cigarettes are also known as fake cigarettes.

2.2 Methodology for estimating legal tobacco
To report on the size of the share of illicit tobacco in total tobacco consumption, we first need toestimate legal consumption, including both domestic and non-domestic sales. We have used arange of data sources to estimate legal domestic sales, including Circana scan data and sales data
provided by various industry participants. Circana scan data reflects the sales made to consumers
and to the extent that each sale is scanned.

26

In Australia, this limit is currently 25 cigarettes or 25g of RYO tobacco.
Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 24

Non-domestic legal sales are calculated using ABS data on arrivals from key source countries27,
combined with Euromonitor data on the prevalence of smoking among adults from other key
source countries to estimate the propensity of those adults (in key source countries) to bring inlegal tobacco through allowable limits.

2.3 Methodology for estimating illicit tobacco
As Figure 8 shows, the unbranded tobacco analysis is primarily based on the Roy Morgan
Research consumer survey, together with AIHW smoking incidence and ABS adult population
data. The estimation of illicit manufactured cigarettes draws primarily on the WSPM empty
discarded pack survey (EDPS).
Figure 8: Overview of approach to estimating illicit tobacco

Source: FTI Consulting.

Consumer survey
The consumer survey focuses on the tobacco consumption behaviour of Australian adult smokers
who smoke on a regular basis. Since 2016, Roy Morgon Research has conducted consumer
surveys bi-annually. Consumers are asked about their consumption and purchase of legal and27

Key source countries refer to countries with the highest inflow of non-domestic tobacco to Australia, which are
determined using the EDPS.
Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 25

illicit products, and specifically their consumption of unbranded tobacco products (which are allillicit).28 Considerations are given to the reliability of responses provided by survey participants.
Key metrics drawn from the consumer survey and used in the consumption model include:■ percentage of unbranded tobacco consumers (as a share of the smoking population)■ frequency of purchase of unbranded tobacco■ quantity of unbranded tobacco purchased on each occasion.
Other informative parameters that are collected for comparative purposes include theawareness of unbranded tobacco, ease of purchase of unbranded tobacco and supply outlets for
unbranded tobacco. Please refer to Appendix A for further information.
Empty Discarded Pack Survey (EDPS)The EDPS is used to estimate the components of illicit tobacco other than unbranded including
contraband, counterfeit and domestic illicit plains. WSPM Group conducts the EDPS on a sixmonthly basis (Q2 and Q4 of each calendar year).
The survey collects 12,000 discarded cigarette packs per survey across 16 different population
centres in Australia. Each discarded pack is identified according to brand and country of origin
and classified as domestic or non-domestic. WSPM then sends the information to participating
manufacturers to identify genuine and counterfeit products.
Key metrics drawn from the EDPS include:■ non-domestic incidence29 – the percentage of cigarettes with non-domestic branding (nonplain packaging, no Australian health warnings)■ counterfeit incidence – the percentage of cigarettes branded or trademarked without theconsent of the trademark owner■ domestic illicit plains – the percentage of cigarettes comprising illicit brands that havepackaging designed for the Australian market.
Non-domestic incidence and counterfeit incidence are applied to the estimates of total legal
tobacco consumption (domestic and non-domestic) to generate estimates of contraband andcounterfeit consumption.
This methodology is consistent with the approach adopted by FTI Consulting in the 2022 study
and the approach used by KPMG LLP in previous studies. Appendix B provides further
information in relation to the EDPS and approach to estimating illicit components of the market.

28

These estimations are then ‘blended’ (averaged) to reduce the fluctuation of illicit tobacco purchases throughout
the quarters.
29
Non-domestic incidence refers to the amount of non-domestic cigarettes consumed as a proportion of total
cigarettes, as recorded in WSPM’s empty discarded pack survey (EDPS).
Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 26

3. Legal Tobacco
Consumption

Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 27

3 Legal Tobacco Consumption
Key points■ In 2023, the consumption of legal domestic tobacco decreased by 18.8% to 6.9 millionkg.
■ While consumption of legal non-domestic tobacco increased by 67.0%, the total volumeof legal non-domestic tobacco consumed (0.1 million kg) is not considered significant.
■ The price of legal tobacco products in Australia increased by over 11% in 2023, driven inpart by ongoing increases in excise rates. The increase in legal tobacco prices paired withincreasing costs of living has made cheaper illicit tobacco products (including vapes)
more attractive to consumers.
■ Illicit tobacco was easier to access and more affordable in 2023, reducing participation in
the legal market.
■ Illicit vape products are at least 18 times cheaper than legal cigarettes, and unbranded
tobacco (in tubes) and unbranded tobacco (loose) is 5-6 times cheaper than legal
cigarettes.

3.1 Total legal tobacco
Total legal consumption (domestic cigarettes, domestic RYO products and non-domestic
products) have consistently decreased since 2018 (see Table 1).
Table 1: Total legal tobacco consumption by component, 2018-2023

Product (million kg)

2018

2019

2020

2021

2022

2023

Domestic Cigarettes

10.2

9.3

8.5

7.3

6.7

5.4

Domestic RYO

2.5

2.5

2.4

2.1

1.8

1.5

Non-domestic

0.02

0.02

0.01

0.00

0.01

0.01

Total legal tobacco

12.7

11.8

10.9

9.4

8.5

6.9

Source: Sales data provided by industry participants, FTI Consulting analysis of Euromonitor traveller data.

3.2 Legal domestic consumption
Legal domestic sales
Consumers continue to turn away from legal tobacco products (refer Figure 9). In 2023, total
legal domestic sales decreased by 18.8%, representing a 19.4% decrease in manufactured
cigarettes and an 18.3% decrease in roll-your-own products, as shown in Table 2. This is thelargest year-on-year reduction in a decade, both in percentage and volume.
Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 28

Figure 9: Legal domestic tobacco sales in Australia, 2013-2023

Source: Data provided by industry participants, Circana scan data.
Table 2: Annual growth of legal domestic tobacco sales, 2013-2023

Annualgrowth20132014

20142015

20152016

20162017

20172018

20182019

20192020

20202021

20212022

20222023

Manufactured

-2.8%

-1.0%

-6.1%

-8.9%

-6.8%

-9.1%

-8.5%

-14.1%-8.8%-19.4%

Roll-your-own

6.5%

4.4%

4.0%

5.6%

6.2%

2.1%

-3.3%

-13.2%-12.6%-18.3%

Total

-1.7%

-0.3%

-4.7%

-6.7%

-4.6%

-6.9%

-7.4%

-13.9%-9.6%-18.8%

Source: Data provided by industry participants, Circana scan data.

Market share by manufacturer
Figure 10 shows the market share of manufactured cigarettes and loose tobacco bymanufacturer across legal tobacco sales in 2023. BAT Australia Ltd (BATA) maintains the largest
share of manufactured cigarettes with 36.4%, followed by Philip Morris Limited (PML) with 34.2%
and Imperial Tobacco Australia (ITA) with 28.1%. Other smaller manufacturers make up 1.4% of
the market for manufactured cigarettes. ITA has the largest share of loose tobacco sales (46.1%),
followed by BATA (36.7%) and PML (16.2%). Smaller manufacturers make up 1.0% of the loose
tobacco market.

Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 29

Figure 10: Market share of manufactured cigarettes and loose tobacco by manufacturer, 2023

Source: Data provided by industry participants.

Sales of legally manufactured cigarettes by price category
Since 2013, low-priced cigarettes have continued to become more popular among consumers.
This trend has continued in 2023, with low-priced cigarettes now making up 79% of the market –an increase of 3 percentage points from 2022 (see Figure 11). Consumption of medium-priced
cigarettes decreased by 5 percentage points to 15%, while consumption of high-price cigarettes
increased by 2 percentage points to make up 6% of the market.
Figure 11: Market share of manufactured cigarettes (legal) by price category, 2008-2023

Source: Circana scan data, supplied by industry participants.

3.3 Legal non-domestic consumption
Legal non-domestic tobacco refers to tobacco that is purchased legally, either overseas or dutyfree, and brought into Australia by travellers within their legal limit (25g or 25 sticks in Australia).
Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 30

This is estimated using two key parameters: ‘inbound’ travellers and ‘outbound’ travellers. Ourestimates include only travellers from the 2023 key source countries.30
Inbound travellers are non-Australian residents entering Australia for a short-term visit. In 2023,
ABS data estimated that 2.9 million inbound travellers entered Australia. We have used
Euromonitor data to estimate, for each country, the adult (or ‘of smoking age’) population andthe proportion of those who smoke. We have then multiplied these figures by the legal traveller
allowance (25g) to generate an estimate for the total legal tobacco consumed by inboundtravellers – 7.3 tonnes in 2023.
Outbound travellers are Australian residents returning from overseas visits. ABS data estimatedthat in 2023 around 2.7 million outbound travellers entered Australia. Using the Australiansmoking participation rate, an estimated 3.4 tonnes of legal tobacco was brought into thecountry by Australian residents.
In total, Australian inbound and outbound travellers consumed an estimated 10.7 tonnes of legal
non-domestic tobacco in 2023. This reflects an increase of 67.0% since 2022 following therecovery of travel post the COVID-19 pandemic.
Despite this large increase, this component is very small compared to domestic legal
consumption.

3.4 Key drivers
Increasing domestic excise on legal tobacco products
Since 2010, the Commonwealth Government has regularly increased the rate of excise on
tobacco as a key tobacco control strategy (Figure 12).31 In 2014, Australia changed its approach
to indexing tobacco excise rates by linking increases to average weekly ordinary time earnings(AWOTE), rather than the Consumer Price Index (CPI).32 Indexation occurs in March and
September each year.
Legislative amendments in 2016 resulted in a further four annual increases of 12.5% in excise to
be applied in September each year from 2017 to 2020, in addition to the AWOTE adjustment.
Tobacco excise is charged on a per stick basis for manufactured cigarettes, whereas all othertobacco products including loose tobacco is taxed on a per kilogram basis. To better align theexcise on manufactured cigarettes and loose-leaf tobacco, from 2017, adjustments were also
made to the (assumed) grams of tobacco content per manufactured cigarette.33 This resulted in

30

Key source countries are those with the highest non-domestic incidence, as determined by EDPS results. In 2023,
the key source countries were China, Malaysia, South Korea, UK, Japan, Taiwan, USA and Philippines.
31
Department of Health and Aged Care, “Tobacco control timeline,” Department of Health and Aged Care (10 May
2018), https://www1.health.gov.au/internet/publications/publishing.nsf/Content/tobacco-control-toc~timeline.
32
Ibid.
33
In 2016, excise was calculated for loose-leaf tobacco on the basis that each manufactured cigarette contained
0.8 g of tobacco. The rate was adjusted gradually over four years from 0.8 g per stick in 2016 to 0.775 g per stick in
2017, 0.75 g per stick in 2018, 0.725 g per stick in 2019, and 0.7 g per stick in 2020, which was closer to the weight ofa manufactured cigarette.
Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 31

an increase in the excise rate for loose-leaf tobacco beyond the regular indexation applied on 1
September each year (Figure 12).
From September 2023, the Commonwealth Government further increased tobacco excise by 5%
per year for three years (refer Figure 12).
Excise rates have continued to increase between January 2023 and January 2024, from $1.14 perstick to $1.24 per stick. Following an excise increase in September 2023, the excise per 20-packof cigarettes was $36.80. This has led to an increase in the retail price of tobacco at a rate thatexceeds the WPI. For example, between January to December 2023, the price of a pack of 20
Marlboro cigarettes purchased in Australia increased by 18.5%, while the price of a 25-pack ofWinfield cigarettes increased by 11.0%.

1.4
1.2
1.0
0.8
0.6
0.4
0.2
0.0

2000
1600

800
400

AUD/kg12000Mar-08
Sep-08Mar-09Sep-09Mar-10
Sep-10Mar-11
Sep-11Mar-12
Sep-12Mar-13
Sep-13Mar-14
Sep-14Mar-15
Sep-15Mar-16
Sep-16
Mar-17
Sep-17Mar-18
Sep-18Mar-19Sep-19Mar-20
Sep-20Mar-21
Sep-21
Mar-22
Sep-22Mar-23
Sep-23

AUD/stickFigure 12: Tobacco excise and customs duty, Mar 2008 - Sep 2023

AUD/stick

AUD/kgNote: This figure shows key increases in excise rates over time including a 25% increase in excise rates in April 2010, 12.5%
increase in excise duty in December 2013 and increases every March and September from 2014 – 2020. A 3.3% increase in excise
duty applied from March 2021 to September 2022 based on AWOTE, and increases to excise duty in March 2023 and September
2023 based on AWOTE, in addition to the first of three 5% increases from 1 September 2023.
Source: Tobacco in Australia, www.tobaccoinaustralia.org.au.

Declining relative cost of illicit tobacco
While the price of legal tobacco increased in 2023, by comparison the price of ‘contraband’
cigarettes, ‘unbranded (loose)’ and ‘unbranded (in tubes)’ decreased (refer Figure 13). The priceof ‘unbranded (in tubes)’ fell in 2023 by 20.9%, while contraband prices fell by 4.3% and‘unbranded (loose)’ fell by 1.6%. As a result, the price of illicit products relative to legal cigarettes
decreased in 2023.
Unbranded tubes fell to 15.4% of the Winfield 25-pack price in December 2023. This has
increased the motivations for adult consumers to seek out and switch from legal tobacco to illicit
tobacco sources.

Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 32

Price of tobacco products equivalent inweight to Winfield 25s (AUD)

Figure 13: Price of tobacco products equivalent in weight to Winfield 25s (AUD), 2013-2023
65
60
55
50
45
40
35
30
25
20
15
10
5
0

Winfield 25s

Contraband

Unbranded (in tubes)

Unbranded (loose)

Source: Industry data supplied to FTI Consulting.

Lower tobacco prices in neighboring countries
The price of legal cigarettes in Australia is very high compared to a range of other neighbouring
countries. The significant difference in prices (including high excise rates) for legal tobaccoprovides an incentive for illicit traders to supply their product in Australia at the expense of
legitimate importers and traders of tobacco products. This price differential enables traders in
the illicit market to be extremely competitive, whilst also making large profits.
Figure 14 shows the vast difference in pricing between Australia and selected markets in the
Asia-Pacific region. For example, in January 2024, a 20-pack of Malboro cigarettes bought inAustralia for AU$48.59 could be bought in China for the equivalent of AU$5.30.
There are at least 13 countries in the region where the same pack of cigarettes costs less than
AU$10.00, including across countries with the highest manufactured cigarette inflows toAustralia (as shown in Figure 14).

Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 33

Figure 14: Retail sales price (RSP) of a pack of 20 Marlboro cigarettes in Australia and selected markets in the Asia-Pacific region,
January 2024

RSP of a Marlboro 20 pack (AUD)

60
50Countries with the highest
manufactured cigarettes flow toAustralia

48.6
40.2

40
30
20
10

27.9
18.1

14.7 14.5 12.6
6.3

6.0

5.5

5.3

5.1

5.1

4.1

4.1

4.0

3.9

2.3

1.8

1.6

0

Source: FTI Consulting analysis using industry partners’ data, exchange rate as on 15 January 2024.

Alternatives to legal tobacco with lower prices
A contributing factor to the decline in legal tobacco consumption is the large difference in pricebetween legal and illicit products.
Table 3 shows that illicit vape products are at least 18 times cheaper to consume than legal
cigarettes:■ a smoker who smokes a 25-pack of Winfield cigarettes each day is likely to spend $22,488 on
cigarettes per year, while a ‘low’ price brand would cost $16,380 per year34■ a vaper’s yearly expenditure to consume the equivalent of a ‘pack-a-day’ is estimated ataround $650-$912.35
Similarly, it is approximately 5-6 times cheaper to consume unbranded tobacco (loose), with an
expected yearly spend of $4,550 for a ‘pack-a-day’ equivalent smoker.36 This was estimated bytaking market prices for legal manufactured cigarettes (Winfield 25s, specifically), unbranded
loose tobacco and illicit vape products, and determining the cost to consumers on a ‘per puff’basis. This allows for clearer comparison of the true cost to consume smoking/vaping products.

34$1.80 per cigarette, or $45 per pack.
Vape pricing data provided by industry participants.
36
FTI Consulting, using data provided by industry participants.
35

Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 34

Table 3: Price comparison of legal manufactured cigarettes versus illicit tobacco products, 2023

Price per year for a‘pack-a-day’smoker/vaper2

Product

Price per puff

Price per pack ofequivalent puffs

Legal manufactured
cigarettes1$0.2537$61.61$22,488

Unbranded loose$0.05$12.50$4,550Illicit vapes$0.01-$0.010$1.79-$2.50$650-$912

1 Estimated using the price of Winfield 25s.
2 By assessing relative retail cost to the consumer for each product across a year, based on the same number of puffs consumed

across each product.
Source: FTI Consulting analysis of data provided by industry participants.

Rising ease of access to and awareness of illicit products
In 2023, consumers reported increasing awareness and ease of purchase of illicit tobacco
products. In fact, since Q4 2020, survey respondents have, in every consecutive quarter, said that
it was easier to purchase unbranded tobacco than in the previous quarter (see Figure 15). Thismeans, year-on-year, access to unbranded tobacco has increased considerably, contributing toincreased consumption of this illicit substitute.
Figure 15: Ease of purchasing unbranded tobacco, 2015-2023
100%

8%

2%

10%

10%

7%

8%

8%

7%

9%

12%

6%

5%
20%

80%

25%

25%

37%
35%

24%

31%

28%

27%

26%

24%

21%

35%
24%

40%

20%

30%

27%

34%

33%

35%

27%

5%

4%

15%

17%

37%

34%

44%

45%

5%
21%

3%
17%

38%

39%

38%

38%

31%

30%

33%

32%

37%

40%
30%

41%

20%

2%

32%

60%
37%

2%

33%
22%

37%
27%

31%

32%

29%

30%

40%

44%

47%

0%
Q2 Q3 Q4 Q2 Q4 Q2 Q2 Q4 Q2 Q4 Q2 Q4 Q2 Q4 Q2 Q4 Q2 Q42015 2015 2015 2016 2016 2017 2018 2018 2019 2019 2020 2020 2021 2021 2022 2022 2023 2023

EasierSame/No change

HarderDon't know

Source: Previous studies of Illicit tobacco in Australia, 2013-2022, and Roy Morgan Research consumer survey, 2022 and 2023.

37

Based on an average of 10 puffs per cigarette: Benowitz NL, Jacob P, Herrera B, “Nicotine intake and dose
response when smoking reduced nicotine content cigarettes,” American Therapeutic Society (2006).
Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 35

This growing awareness and ease of purchase of illicit tobacco is further evidence of theincreasing availability of illicit tobacco, as estimated in this study.
Tobacconists remain the largest sellers of unbranded tobacco, with 42.5% of unbranded tobaccopurchased at tobacconists (see Figure 16). Supermarkets and convenience stores are the next
largest, with 11.1% and 8.8% of unbranded sales, respectively.
Figure 16: Main purchase outlets of unbranded tobacco, 2023

Source: Roy Morgan Research consumer survey data, 2023.

‘Other’ sources include hotels and motels, fast food and takeaway businesses, newsagents, ande-stores or online shopping (which made up 3.0% of unbranded sales).
In Q4 2023, 71.0% of survey respondents said they were aware that unbranded tobacco wasavailable to purchase – an increase of 11.6 percentage points since Q4 2022 (see Figure 17).
Figure 17: Proportion of respondents aware of unbranded tobacco, 2013-2023

Source: Previous studies of Illicit tobacco in Australia, 2013-2022, and Roy Morgan Research consumer survey data for 2022-2023.

Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 36

4. Illicit Tobacco
Consumption

Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 37

4 Illicit Tobacco Consumption
Key points■ In 2023, consumption of illicit tobacco in Australia increased by 9.5%.
■ Illicit tobacco now makes up 28.6% of Australia’s total tobacco consumption.
■ If excise was collected on this volume of illicit tobacco, it would generate $4.85 billion in
additional government revenue based on 2023 excise rates.
■ Although counterfeit tobacco reduced by 1.6%, consumption of unbranded tobacco andcontraband increased by 6.5% and 15.7%, respectively.

4.1 Summary of total illicit tobacco consumption in Australia
The estimated volume of total illicit tobacco consumption in 2023 (2.8 million kg) is at its highest
level since 2019 (refer Figure 18). This is driven by:■ consumption of unbranded tobacco at volumes not observed since 2010
■ a return to pre-COVID-19 levels of ‘normal’ passenger and freight movements following the
re-opening of borders and supply chains, contributing to a rebound in the consumption ofcontraband cigarettes.
Figure 18: Total illicit tobacco consumption in Australia, 2009-2023

Illicit tobacco consumption ('000kg)

3.5
3.0

3.0

2.6
2.4

2.5

2.4

2.8
2.5

2.4

2.2

2.5
2.3

2.0
1.5

1.8

0.4

0.2

1.2

0.4

0.5

1.4

1.4

2.2

2.1

2.0

2.1

1.6
1.1

0.9

1.3

1.2

0.9
1.0

1.1

1.1

0.6

2.2

1.0
1.5
0.5

1.4

1.4

1.4

1.0

1.1

1.3
0.9

1.1

1.4

1.5

1.6

2021

2022

2023

0.0
2009

2010

2011

2012

2013

2014

Unbranded

2015

2016

Contraband

2017

2018

2019

2020

Counterfeit

Source: Previous studies of Illicit tobacco in Australia, 2013-2022, and FTI Consulting analysis of 2022 and 2023 data from various
sources.

The consumption of counterfeit tobacco remains a small component of illicit tobacco.
Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 38

If excise was collected on this volume of illicit tobacco, it would generate $4.85 billion in
additional government revenue based on 2023 excise rates.
After remaining steady between 2013 and 2018, the proportion of total tobacco consumption
made up of illicit products has increased dramatically year-on-year, except for 2019 wherecontraband consumption was reported to be abnormally high. Since 2021, illicit tobacco as aproportion of total tobacco consumption has steadily increased from 22.9% to 28.6% (see Figure
19).
Figure 19: Illicit tobacco as a proportion of total tobacco consumption in Australia, 2009-2023

Proportion of total tobacco consumption

35%
28.6%

30%
23.5%

25%
20.4%
20%
12.8% 12.2%

15%

10%

19.3%
16.9%

13.5%

14.7% 14.4% 14.3% 14.7% 14.0%
16.7%

11.5%

22.9%

18.2%

9.1%

5%
0%
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023
2024 AIHW Update illicit tobacco %Illicit tobacco % of total consumption

Previously forecast illicit tobacco %Source: Previous studies of Illicit tobacco in Australia, 2013-2022, and FTI Consulting analysis of 2022 and 2023 data from various
sources.

This was driven by the continued decline in legal tobacco consumption and an increase in thevolume of illicit tobacco consumed.

4.2 Components of illicit tobacco consumption
In 2023, the proportions of illicit tobacco comprised of both unbranded and counterfeit havedecreased slightly (by 1.7 and 0.3 percentage points, respectively), while the share of contraband
has increased by 2.1 percentage points (refer Figure 20). The proportional increase in contrabandis expected as international travel continues to increase after the re-opening of borders post
COVID-19 closures.
Figure 20 refers to the proportions of illicit tobacco components – whereas estimated volumes
have increased for both unbranded and contraband, and decreased slightly for counterfeit, asshown in Figure 18. These will be discussed further in subsequent sections.

Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 39

Figure 20: Share of illicit tobacco consumption by category, 2013-2023

100%

5.9%

80%

0.3%

1.3%

2.1%

45.3%

44.2%

38.5%

1.9%

2.1%

2.4%

3.4%

2.6%

31.1%
51.1%

53.6%

54.1%

53.9%

2.8%

2.5%

37.2%

39.3%

60.0%

58.3%

2022

2023

46.7%

60%

40%
54.4%
20%

54.5%

66.2%

59.4%

40.5%

46.8%

44.0%

43.8%

2017

2018

2019

50.0%

0%
2013

2014

2015

2016

Unbranded

Contraband

2020

2021

Counterfeit

Notes: Percentages may not sum to 100 due to rounding. Market share of manufactured cigarettes is established using the yearly
averaged price per cigarette. The low, medium, and high price categories are adjusted yearly to reflect the average growth inprices across cigarettes in that category between years. For example, the average growth in low cigarette prices from 2022 to2023 was 7% and, as such, the low category cutoff price was adjusted accordingly, from $1.68 to $1.80 per cigarette.
Source: Previous studies of Illicit tobacco in Australia, 2013-2018, FTI Consulting analysis for 2022 and 2023 (and re-estimation of2020-2022) using updated AIHW smoking incidence.

4.3 Unbranded tobacco
Figure 21 shows that in 2023, consumption of unbranded tobacco decreased slightly from 1,673
tonnes in Q4 2022 to 1,606 tonnes in Q4 2023. However, the consumption of unbranded tobaccoremains significantly higher than pre-COVID-19 levels.
Unbranded tobacco consumption has consistently grown since 2020. Figure 22 shows a 6.5%
increase in blended unbranded tobacco consumption from 1,515 tonnes in Q4 2022 to to 1,613
tonnes in Q4 2023).38
As described in Chapter 1, the AIHW National Drug Strategy Household Survey indicates that thedaily smoking population has fallen faster than expected. As a result, the corresponding figuresduring 2020-2022 referenced in this study may not align with previously released figures. The
charts below present updated estimates alongside previous estimates.

38

Blended consumption refers to the average consumption across the current and previous period (i.e., for Q4 2023,
the blended consumption is an average of the actual consumption for Q2 2023 and Q4 2023).
Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 40

Figure 21: Actual consumption of unbranded tobacco, 2013-2023

Source: Previous studies of Illicit tobacco in Australia, 2013-2018, FTI Consulting analysis for 2022 and 2023 (and re-estimation of2020-2022) using updated AIHW smoking incidence.
Figure 22: Blended consumption of unbranded tobacco, 2013-2023

Source: Previous illicit tobacco studies in Australia (2013-2018), FTI Consulting analysis for 2022 and 2023 (and re-estimation of2020-2022) using updated AIHW smoking incidence.

Purchase of unbranded tobacco
The proportion of consumers surveyed by Roy Morgan Research who reported purchasing
unbranded tobacco increased from 32.7% in Q4 2022 to 37.3% in Q4 2023.39

39

A key element of the approach to estimating unbranded tobacco consumption is the parameter for the proportionof respondents who reported purchasing unbranded tobacco. FTI Consulting has adopted the approach used inprevious years which draws on survey responses in the Roy Morgan Research Consumer Survey. Responses arecollected on the consumption behaviour of daily smokers and applied to the daily smoking population, andtherefore exclude consumption of unbranded tobacco by non-daily smokers.
Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 41

Figure 23: Proportion of respondents who reported purchasing unbranded tobacco, 2013-2023

Source: Roy Morgan Research consumer survey data.

Average purchase volume and frequency
Consumers are buying smaller amounts of unbranded tobacco, although more frequently. This
corresponds to the increasing ease of purchase reported by unbranded tobacco consumers,
shown in Chapter 3.
In Q4 2023, the average volume of unbranded tobacco purchased per occasion decreased by
10.5% compared to Q4 2022 (see Figure 24), while the average frequency of purchase increased
by 6.1% over the same period (Figure 25). The blended quantity of unbranded tobacco purchased
per person (across Q2 and Q4) has remained relatively constant between 2022 and 2023.
This might suggest consumers are more confident that they can access unbranded tobacco.
Figure 24: Average volume of unbranded tobacco purchased per occasion (kg), 2014-2023
0.3
0.26
0.24

0.25

0.24

Unbranded Tobacco (kg)

0.20
0.2

0.18

0.18

0.20

0.19
0.17

0.19

0.18

0.18
0.15

0.14

0.16

0.1

0.18

0.17
0.14

0.15

0.14

0.14
0.14

0.13

0.15
0.14

0.05
0

Source: Roy Morgan Research consumer survey data.
Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 42

Figure 25: Average frequency of unbranded tobacco purchase per annum, 2013-2023
20
18

16.8

Purchases per annum

16
14

12

16.3
15.5

14.0

16.8
15.0

14.5

14.7

14.0

13.0
12.1

17.7

16.2

17.5

17.0

16.5

15.5

13.5 12.8
11.9

12.1

10

18.3

11.1

10.1

8
6
4
2
0

Source: Roy Morgan Research consumer survey data.

4.4 ContrabandContraband was the second largest component of illicit tobacco consumption in 2023, making up
39.3% of total illicit consumption. Prior to the COVID-19 pandemic, contraband comprised ofmore than half of the total illicit tobacco consumption (circa 52%-54%), however its share wasdisrupted in 2020-2022 and it is yet to fully return in the consumption profile.
The estimated total of contraband tobacco consumed (1.1 million kg) has increased by 15.7%
since 2022, comprising:■ 852 tonnes of contraband (including non-domestic illicit whites) – which has decreased by
1.1% since 2022 and■ 235 tonnes of domestic illicit plains – which has increased by 202.1%.40
Non-domestic incidence of manufactured cigarettes
Non-domestic incidence data indicates the prevalence of manufactured cigarettes that do notcomply with domestic packaging regulations. A portion of non-domestic incidence comprises
non-domestic legal (reflecting travellers entering Australia carrying the allowable tobacco limit),
but non-domestic incidence predominantly comprises contraband.
In 2023, the inflow of non-domestic manufactured cigarettes increased from 12.3% in 2022 to
14.8% in 2023 (Figure 26). In 2023, China accounted for 39.2% of all non-domestic inflows, while
the proportion of inflows from ‘Unspecified’ countries increased to 32.3%. This increase is driven
primarily by a significant rise in inflows from ‘Unspecified’ countries, which represent the second
largest contributor to total inflows in 2023.

40

Presenting contraband as a combination of illicit white products is consistent with previous illicit tobacco studies.
Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 43

Figure 26: Total non-domestic incidence as a percentage of total manufactured cigarette consumption by country of origin, 20202023

Non-domestic incidence of cigarettes

18%
15.6%

16%
14.0%
14%
12%
10%
8%

13.0%
0.9%

11.7%

1.4%

0.6%

8.8%

1.3%

3.7%

6.3%
0.3%
0.1%
0.5%
0.7%

6%
4%

13.0%

2.8%

7.3%

1.1%
0.8%

0.4%
0.5%

2.4%

0.8%
1.1%

2.9%

2%

2.7%

1.6%

Unspecified

2020 Q4

China

0.5%
1.1%

0.7%

0.5%
0.4%

0.4%
0.4%

2.6%

2.0%

4.7%

5.8%

6.9%
6.7%

3.4%
5.8%

2.0%
3.1%

3.4%

3.1%

2022 Q2

2022 Q4

4.8%

3.8%

1.5%

0%
2020 Q2

0.9%
0.7%

0.8%

0.4%
0.2%

0.5%
0.2%

0.7%
0.3%
0.3%
1.3%

14.8%

0.7%

2021 Q2

Duty Free

2021 Q4Japan

Malaysia

South Korea

2023 Q22023 Q4

United Kingdom

2023 (Agg.)

USA

Others

Source: WSPM empty discarded pack survey data.

The incidence of non-domestic brands increased across Australian population centres between
Q4 2022 and Q4 2023 (Figure 27). The non-domestic incidence in non-major population centres41
saw the largest increase, rising from 8.6% to 12.6%. Non-domestic incidence is still larger in the
major population centres, rising to 16.6% in Q4 2023, with Sydney being the population centre
with the highest non-domestic incidence of 22.0%.

41

Major population centres are Brisbane, Sydney, Melbourne and Perth.
Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 44

Figure 27: Total non-domestic incidence of manufactured cigarettes by population centre

Source: WSPM EDPS data.
Figure 28: Weighted non-domestic incidence by population centre, Q4 2021, Q4 2022, Q4 2023
18%

16.6%

16%

14.1%

14%

12.6%

12%
10%

8%

8.6%

7.7%
5.2%

6%
4%
2%
0%

Major 4 population centres

Other population centres
2021

2022

2023

Source: WSPM EDPS data.

Among all non-domestic brands, the inflow of the Manchester brand of cigarettes has grown
substantially from 1.9% in Q4 2022 to 4.6% in Q4 2023 (refer Figure 29). Conversely, Double
Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 45

Happiness has seen a decrease over the same period, from 4.7% to 3.3%. Most Double Happiness
imports originate in China and a smaller portion from the Middle East, while Manchester
primarily comes from the Middle East and sometimes Southeast Asia.
Figure 29: Total non-domesetic incidence by brand flows as a percentage of total manufactured cigarette consumption, 20202023
15.9%

15.6%

16%

14.0%

14%
12%

13.0%
7.1%

10%
8%
6%
4%
2%

0%

1.5%
2.1%

6.3%
2.6%

1.0%
1.0%
1.5%

0.5%
0.8%

2020 Q2

2020 Q4

1.2%

7.3%
3.1%
0.5%

2.4%
0.5%
0.7%
1.1%
1.3%

3.5%

8.8%
1.3%

3.8%

11.7%

2.8%

0.6%
0.5%
0.8%
1.4%

1.9%

1.1%

1.8%
0.5%

Others2.1%

Mevius0.7%
1.1%

Marlboro

1.9%
1.2%

Hongtashan
4.6%

2.5%

Manchester

1.4%

1.4%
1.1%
1.4%
0.5%

0.7%
0.6%
1.3%
0.8%

2021 Q2

2021 Q4

2.0%

Esse

4.7%

3.4%

3.3%

0.5%

0.9%

1.3%

2022 Q42023 Q22023 Q4

Double HappinessCounterfeit

1.4%

2022 Q2

Note: In years where non-domestic incidence is lower than 0.5% in any period, labels have been removed.
Source: WSPM EDPS data.

4.5 Counterfeit
Consumption of counterfeit cigarettes decreased slightly in 2023, from 70 tonnes in 2022 to 69
tonnes in 2023 (equivalent to a reduction of 1.6%). As counterfeit cigarettes account for only
2.5% of total illicit tobacco consumption in 2023, its reduction has a marginal impact on thegrowth of total illicit tobacco.

4.6 Domestic illicit plains
Illicit whites are manufactured cigarettes produced legally in one country and exported toAustralia illegally. These cigarettes do not have a legal distributor in Australia, and more
importantly, they are sold without paying applicable excise and customs duties to the AustralianGovernment.
Domestic illicit plains are one of the two components of illicit white cigarettes which contributes
to the total illicit consumption. It refers to the flows of illicit whites brands that usually havepackaging designed for the domestic Australian market. Domestic illicit plains are a separate
contributor to the illicit tobacco consumption model and should be added to the other illicit
tobacco consumption components to estimate the total illicit tobacco consumption in Australia.
Domestic illicit plains make up 8.5% of total illicit tobacco consumption in 2023, equivalent toaround 235 tonnes. This represents an increase of 202.1% from 2022. Domestic illicit plains areincluded in the total contraband estimation (in section 4.4 above on contraband estimation).
Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 46

4.7 Seizures
The trend of increased consumption of illicit products is consistent with data on tobacco seizuresfrom both the Australian Border Force (ABF) and the Australian Taxation Office (ATO). Total
seizures increased by 21.7% from 2021-22 to 2022-23, to 2,178 tonnes. Almost all seizures ofillicit tobacco (96.9% of total seizures in 2023) were made by the ABF (see Figure 30).
Figure 30: Total illicit tobacco seizures, 2017-18 - 2022-23

Note: ABF refers to the Australian Border Force; ATO refers to the Australian Taxation Office.
Source: Previous illicit tobacco studies in Australia for historical data, and Illicit Tobacco Task Force for 2022-23.

Of the 2,111 tonnes of illicit tobacco seized by the ABF, 1,244 tonnes were made up of cigarettes,
while the remaining 868 tonnes was loose tobacco (refer Figure 31). The detection of loose-leaf
tobacco was not proportionate to the increase in unbranded tobacco consumption; the ABF
seized 3.3% less loose-leaf tobacco in 2022-23 than in 2021-22, contrary to the 6.5% increase inunbranded consumption.

Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 47

Figure 31: Composition of ABF seizures, 2019-20 - 2022-23

Source: Previous illicit tobacco studies in Australia for historical data, and Illicit Tobacco Task Force for 2022-23.

In 2018, the Commonwealth Government established the Illicit Tobacco Taskforce (ITTF) to
combat imports of illicit tobacco products. As Figure 32 shows, border seizures of illicit tobacco
have increased since the ITTF was established. However, this is driven by an increase in the total
amount of tobacco being brought into the country; despite rising seizures, illicit tobacco
consumption has continued to increase since 2020. A summary of key seizures in 2023 isprovided in Appendix D.
Figure 32: Estimated total illicit tobacco consumed and seized, 2017-18 to 2022-23

Source: Previous illicit tobacco studies in Australia for historical data, and Illicit Tobacco Task Force for 2022-23.

Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 48

5 Conclusion
5.1 Rising consumption of illicit tobacco
Total tobacco consumption in Australia reduced from 2022 to 2023, driven by the decline in the
consumption of legal tobacco products. The proportion of total tobacco consumption that is illicit
has increased significantly and now stands at 28.6% of total tobacco consumption. This
represents an increase of 5.7 percentage points from 2022 and exceeds pre-pandemic levels ofaround 14%.
These trends are a product of both a decline in the AIHW’s estimated daily smoking incidence
and an increase in the volume and proportion of illicit tobacco products in total tobacco
consumption. The decline in legal tobacco consumption is only partly reflective of the decline in
the daily smoking population. Between 2019 and 2023, the decline in the daily smoking
population was 24.5% compared to the decline in legal tobacco sales of 41.6%.
Consumption of illicit tobacco has continued to grow significantly relative to the legal market
across this period (2019-2023), in addition to rising vape use which is not estimated in this study.

5.2 Access to illicit tobacco
The increasing trend towards consumption of illicit tobacco corresponds to rising ease of accessto and uptake of unbranded tobacco. These observations around illicit markets access anduptake in the consumer surveys were also made in the empty disposable pack surveys, showing
an increase in the prevalence of manufactured cigarettes not designed for the legal tobacco
market in Australia.
■ Almost half of consumer survey respondents (46.9%) said it was easier to purchase unbranded
tobacco in Q4 2023. This reflects a trend towards increasing ease of purchase in each survey
period.
■ In addition, the popularity of substitute products (e-cigarettes) rose significantly.

5.3 Profitability of illicit tobacco
Australian law enforcement agencies have continued to seize increasing quantities of illicit
tobacco. Despite rising seizures, illicit tobacco consumption has continued to increase since2019, indicating more illicit product is entering Australian borders.
In 2023, it was highly profitable to engage in illicit tobacco trade. Industry analysis suggests theillicit market value of a 40-foot container of illicit tobacco products lies between $7 million andAustralian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 49

$13 million.42 Prices of legal cigarettes in Australia are now amongst the highest in the region andare now almost 10 times the prices paid in other countries.
These market dynamics create strong incentives for traders to import significant volumes oftobacco to Australia without paying the necessary excise and duties. This underscores why theillicit tobacco trade is often associated with organised crime. The social costs of illicit tobacco canbe observed in this year, in particular arson and violent crime.

5.4 Further regulation and enforcement required
For as long as illicit tobacco products remain easily available, high prices for legal tobacco are
expected to continue to encourage consumers to turn to these much cheaper alternatives. As aresult, there is a need for much more targeted regulatory and enforcement action to stay aheadof the illicit tobacco trade.
The consumption profile within the tobacco market is impacted by appropriate licensing
requirements, monitoring activity around licence compliance and enforcement activity. At
present, strategies related to illicit tobacco remain insufficient to deter participation.
In the first half of 2024, it remains difficult for states to limit the supply of illicit tobacco into thetobacco market while not all states have implemented a licensing scheme. Both the Victorian andQueensland Governments have committed to rolling out licensing scheme in 2024.
In 2024, new regulations related to vaping are being implemented to address the shortcomingsof the previous regulatory model on e-cigarettes. The effectiveness of these reforms will dependon the implementation of an effective monitoring, compliance and enforcement frameworkacross both tobacco and e-cigarettes.43
Recognising that the excise value of illicit tobacco (calculated on 2023 excise rates) is
substantive, estimated at $4.85 billion, and broader community and economy-wide impacts, itwould be appropriate to consider further targeted measures to address the illicit tobacco tradein Australia.

42

Mark Buttler, “Smoking out the jackpot,” Herald Sun (3 April 2024).
The National Vaping Working Group (NVWG) will oversee the development and implementation of a National
Vaping Enforcement Framework in 2024.
43

Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 50

Appendices

Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 51

Appendix A: Estimating Unbranded Tobacco
Consumption
Total illicit tobacco consumption consists of four major elements, including unbranded,
contraband, counterfeit, and domestic illicit plains. Unbranded tobacco currently represents overhalf (58.3%) of illicit tobacco consumption.
The approach used to estimate unbranded tobacco consumption is consistent with the method
undertaken by FTI Consulting in 2022, and by KPMG LLP (2013-2021), Deloitte (2010-2011), andPricewaterhouseCoopers (2007 and 2009). The explanations provided on our approach toestimating unbranded tobacco consumption can be read along with previous guidance included
on the methodology in the FTI Consulting report, Illicit tobacco in Australia 2022.
We acknowledge that due to the nature of the qualitative analysis required for somecomponents of the unbranded tobacco consumption, there might be minor discrepancies
between FTI Consulting results and KPMG LLP results, which do not meaningfully affect the final
estimates.

Key data sources and approachTo estimate unbranded tobacco, the key data sources are the Roy Morgon Research consumer
survey, the AIHW National Drug Strategy Household Survey, and the ABS Census and population
estimates.
The consumer survey
The consumer survey is primary market research used to estimate the size of the unbranded
tobacco market in Australia. The consumer survey was conducted by Roy Morgan Research. Over
21,000 people took part in the latest AIHW household survey, held in 2022 and 2023, andreleased in 2024.
In 2022, there were 2,250 eligible participants in Q2 and 2,261 eligible participants in Q4 thatcompleted the survey. The number of participants in 2023 were 2,117 in Q2 and 2,145 in Q4.
Hence, fewer participants have completed the survey in 2023.
Key elements of our methodology consistent with previous years include:■ Validation of the survey respondents’ overall smoking and unbranded smoking behaviour. For
instance, a participant’s unbranded smoking volume in a year could not exceed their overallsmoking volume per year. This results in some responses being eliminated to achieve moregenuine outcomes.
■ Implementation of the weighted sample data44 which are best representatives of the whole
population of Australia.

44

Application of Roy Morgon Research rim weights to the participants’ responses using criteria it collects from
respondents, such as location, age, gender, income, occupation and work status.
Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 52

■ Application of previous methods for estimating participation of the daily smoker population in
unbranded tobacco consumption.
To ensure the comparability of the results between years, FTI Consulting maintained asconsistent an approach as possible in this study compared with 2022, and with the approach
adopted by KPMG LLP in previous years. This raises two important considerations in relation to
the methodology for estimating unbranded tobacco consumption:■ the participation rate in unbranded tobacco consumption (the proportion of unbranded
tobacco users as a share of the total smoking population) is a key driver of estimates of
unbranded tobacco consumption.
■ unbranded tobacco consumption is estimated based on the daily smoking population, andtherefore the consumption of unbranded tobacco by non-daily smokers is not reflected in theestimates. This is noteworthy in this study given the increase in “dual use” (of illicit vaping andsmoking).
AIHW
The AIHW’s National Drug Strategy Household Survey is undertaken every three years andprovides smoking incidence that is used in the estimation of unbranded tobacco consumption.
The survey focuses on attitudes and behaviours across a wide range of health and drug related
issues and includes questions on smoking prevalence for 14 years of age and older smoking
population in Australia.
The latest survey results released by AIHW cover the 2022-23 calendar year. Whereas, at thetime of the previous report we continued using a compound annual growth rate (CAGR)
approach to forecast the 2020-2022 smoking population using previous AIHW survey results, thisstudy adopts the smoking incidence for 2023 as 8.3%. We have therefore rebased the smoking
population for all estimations conducted between 2019 – 2022 using the updated AIHW survey
results.
ABS
Estimates of Australia’s adult population are extracted from the ABS and adult smoking
population in Australia (in percentage terms) from the AIHW household survey. ABS updates its
data every five years through the Census. In census years, we have used actual adult population
data released by ABS in the consumption model. The last ABS population data was collected in
2021. For other years, such as 2023, we have used the CAGR method to forecast the adult
population.

Components of unbranded tobacco consumption estimates
As explained above, Roy Morgon Research conducts its consumer survey on a six-monthly basis(in Q2 and Q4). The unbranded tobacco consumption for the corresponding year (named
blended unbranded tobacco consumption) equals the simple average of the estimated volume ofunbranded tobacco consumptions in each survey ‘quarter’.
We applied the percentage of the adult smoking population for 2023 using the latest AIHW
survey to the ABS population estimates.
Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 53

Table 4 sets out the parameters and estimates related to unbranded tobacco consumption for
2023.
Table 4: Unbranded tobacco consumption estimation approach

Step Parameter

Reference

Q2 2023

Q4 2023

1

Quantity of unbranded
tobacco purchased per
occasion per consumer (g)RMR consumer survey,
Bi-annual (Q2 and Q4)

136

148

2

Frequency of unbranded
tobacco purchased perannum per consumer (#)

RMR consumer survey,
Bi-annual (Q2 and Q4)

17.0

16.5

3

Quantity of unbranded
tobacco purchased perannum per consumer (g)(1) x (2)

2,300

2,430

4

Adult population in Australia(‘000) (see note)

ABS – Annual forecast

21,344

21,3445% adult smoking populationin Australia (%)

AIHW – Actual

8.3%

8.3%

6

Number of adult smoking
population in Australia (‘000)(4) x (5)

1,772

1,772

7

% Australian adult smoking
population who consume
unbranded tobacco (%)

RMR consumer survey –Bi-annual (Q2 and Q4)

39.8%

37.3%

8

Number of unbranded
tobacco consumers inAustralia (‘000)(6) x (7)

705

661

9

Quantity of unbranded
tobacco consumption inAustralia (‘000 kg)(3) x (8)

1,621

1,606

2023

1,613

Notes: The adult definition in the AIHW survey is different from that in the Roy Morgon Research consumer survey. While theconsumer survey considers Australians 18 years of age and older as adults, AIHW applies a definition of 14 years of age andabove. We use the 14+ population from the ABS for consistency with AIHW.
Source: FTI Consulting.

Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 54

Appendix B: Empty Discarded Packs Survey andEstimating Other Illicit Components
As discussed in chapter 2, the total illicit tobacco consumption consists of four major elements,
including unbranded, contraband, counterfeit, and domestic illicit plains. In 2023, consumptionof contraband, counterfeit and domestic illicit plains made up almost 42% of the total illicit
tobacco consumption together. The empty discarded packs survey is the major data source forthese illicit components, however, other primary and secondary data sources such as the Roy
Morgon Research consumer survey, AIHW, ABS and Circana scan contribute to the final figures ofthese parameters.
The methodology used is consistent with the approach undertaken by the 2022 FTI Consulting
report and KPMG LLP in previous years. This appendix briefly covers key elements of ourestimation methodology. FTI Consulting’s Illicit tobacco in Australia 2022 report provided further
detail about the methodology adopted.

The empty discarded packs survey
The empty discarded packs survey (EDPS) is an independent bi-annual study undertaken by
WSPM. The survey collects 16,000 empty discarded cigarette packs across 16 population centresin Australia. As the survey is not subject to respondents’ behaviour, it is considered as a survey
with considerably less sampling error. The survey covers locations comprising of over 75% ofAustralia’s population.
For each pack collected, WSPM identifies its brand and country of origin, and domestic or nondomestic packaging. Also, after consultation with the participating manufacturers in Australia(ITA, BATA and PML), it identifies whether a collected sample is genuine or counterfeit. Among
all, the most important outputs of the survey for our modelling purposes include the number ofcollected packs and the number of weighted sticks per pack.
EDPS results provide key inputs to our estimations of non-domestic manufactured cigarettes,
counterfeit consumption, domestic illicit plains, non-domestic illicit whites, contraband andseveral other inputs to the analyses. EDPS results are available for Q2 and Q4 in each year. In
many cases, we use the simple average of the parameters calculated based on Q2 and Q4 data
sets.

Counterfeit consumption
The method implemented to estimate the volume of counterfeit consumption in Australia
includes extracting the counterfeit incidence from the EDPS results for each survey (Q2 and Q4)Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 55

in percentage terms and applying it to the volume of total manufactured cigarettes consumption
in kg terms.45
Following the formula provided in Table 5, we use legal sales of domestic manufactured
cigarettes and total non-domestic manufactured cigarettes to arrive at the total manufactured
cigarettes. The volume of counterfeit cigarettes is then estimated by applying the averagecounterfeit incidence to the total manufactured cigarettes.
Table 5: Counterfeit consumption estimation process

Step

Parameter

Reference2023

1

Legal sales of manufactured cigarettes(‘000 kg)

Circana scan, Main
manufacturers data - Annual

5,364

2

Average non-domestic incidence (%)

EDPS - Bi-annual (Q2, Q4)

14.8%

3

Total manufactured cigarettes
consumption (‘000) kg(1) / (100% - (2))

6,296

4

Average counterfeit incidence (%)

EDPS - Bi-annual (Q2, Q4)

1.09%

6

Counterfeit consumption (‘000 kg)(3) x (4)68.9

Source: FTI Consulting.

Domestic illicit plains consumption
Domestic illicit plains are one of the two components of illicit white cigarettes which contributeto the total illicit consumption. It refers to the flows of illicit whites brands that usually havepackaging designed for the domestic Australian market.
The primary data source used to estimate domestic illicit plains is EDPS results. The methodology
involves:■ extracting a list of brands primarily identified as domestic illicit plains from the EDPS results■ using secondary data sources to validate the list of domestic illicit plains brands■ after identifying the volume of domestic illicit plains, we calculate the proportion of thesebrands from the volume of total EDPS packs using the weighted number of sticks for thesebrands, to arrive at the domestic illicit plains (in percentage terms).

45This parameter includes the volume of legal domestic manufactured cigarettes and total (legal and illicit) nondomestic manufactured cigarettes.
Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 56

This percentage is then applied to the consumption of total manufactured cigarettes to arrive at
the volume of domestic illicit plains in tonnes. Table 6 presents our estimates of the consumptionof domestic illicit plains.
Table 6: Domestic illicit plains consumption, 2023

Step

Parameter

2023

1% Volume of domestic illicit plains from EDPS (%)

3.7%

2

Consumption of total manufactured cigarettes (‘000 kg)

6,296

3

Domestic illicit plains consumption (‘000 kg) ((1) x (2))

235

Source: FTI Consulting.

Contraband consumption
The method to calculate contraband consumption is to deduct counterfeit consumption fromtotal non-domestic illicit consumption (refer Table 7). Several components are estimated in thisprocess, as explained in our 2022 Report.
Table 7: Contraband consumption estimation process

Step

Parameter

Reference

2023

1

Counterfeit consumption (‘000 kg)

See counterfeit
consumption section

68.9

2

Legal sales of manufactured cigarettes (‘000kg)

Circana scan data, main
manufacturers’ data

5,364

3

Consumption of total manufactured
cigarettes (‘000 kg)

See counterfeit
consumption section

6,296

4

Non-domestic legal inbound consumption(‘000 kg)

EDPS, ABS, Previous
years’ estimates

7.3

5

Non-domestic legal outbound consumption(‘000 kg)

Consumer survey
results, EDPS, AIHW, ABS

3.4

6

Non-domestic legal consumption (‘000 kg)(4) + (5)

10.7

7

Total non-domestic consumption (‘000 kg)(3) – (2)

931.8

8

Non-domestic illicit consumption (‘000 kg)(7) – (6)

921.2

9

Contraband consumption (‘000 kg)(8) – (1)852.3

Notes: Consistent with the estimation approach adopted in previous years, we have applied a 10% uplift to the estimated nondomestic legal outbound. For the estimation of legal inbound and outbound consumption, we updated the list of key source
countries. Consistent with 2022 estimates, we excluded Indonesia which as a key source country. 2023 key source countries were
China, Japan, Malaysia, Korea, UK, USA, and Taiwan, and 2020 estimates for Indonesia and Philippines.

Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 57

Appendix C: Non-Domestic Illicit Whites
Illicit whites include domestic illicit plains and non-domestic illicit whites. Unlike domestic illicit
plains, non-domestic illicit whites do not have plain packaging designed for the Australiandomestic market.
Non-domestic illicit whites are a component of non-domestic illicit consumption. While it hashistorically been estimated separately, it is included in estimate of contraband consumption.
Like domestic illicit plains, EDPS is the main data source for its estimation. Our methodology is to
identify a primary list of non-domestic tobacco manufacturers and their corresponding
manufactured brands using EDPS data in Q2 and Q4. We then identify whether the distributor ofthese products is registered legally in Australia and use secondary data sources to further refine
the primary list and arrive at a final list of non-domestic illicit tobacco manufacturers.
Table 8 presents estimated non-domestic illicit whites consumption. In 2023, non-domestic illicit
whites accounted for 63.0% (or 537 tonnes out of 852 tonnes) of contraband consumption.
Table 8: Non-domestic illicit whites, 2023

Step

Parameter

2023

1% Volume of non-domestic illicit whites from EDPS (%)

8.5%

2

Total manufactured cigarettes consumption (‘000 kg)

6,296

3

Non-domestic illicit whites consumption (‘000 kg) ((1) x (2))

537

Source: FTI Consulting.

Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 58

Appendix D: Key Seizures in 2023
February: The ATO with support from Victoria Police seized and destroyed 42 acres of illicit tobacco
crops in regional Victoria with an estimated excise value exceeding $31 million46
March: ATO and Victoria Police seized and destroyed approximately 11,458 kilograms of illicit tobacco
plants in Bunbartha, Victoria with estimated excise value of more than $19 million 47
April: ATO and NSW police seized and destroyed approximately 16,000 kilograms of illicit tobacco incentral west NSW with an estimated excise value of $28 million 48
May: Led by ATO officers and supported by the NSW Police, the Illicit Tobacco Taskforce (ITTF) seizedand destroyed 77,000kg of illicit tobacco in Binnaway NSW, with an estimated excise of $11.9 million49
May: In a joint operation with the ATO and NSW Police (Operation Junglevine2), the ITTF destroyed
more than 26,670 kg of illicit tobacco in Braidwood, NSW with an estimated excise value of $4.4 million50
August: Officers from the CCC, QPS, ATO, Queensland Health, the Therapeutic Goods Administration(TGA) and Australian Border Force (ABF) executed a coordinated day of operational activity and seized 8
million cigarettes, approximately 3.74 tonnes of loose-leaf tobacco with a total estimated excise value of$14 million from a man in Queensland51
August: The ABF supported by members of the Gold Coast Joint Organised Crime Team executed
warrants at 11 properties across South East Queensland, Tweed Heads, and Coffs Harbour regions
seizing 2.8 million cigarette stick approx. 380 kilograms of loose-leaf tobacco with estimated excise valueof more than $3.8 million and suspected counterfeit empty plain packaging 52
October: 16 warrants were executed by the VIPER taskforce in regional Victoria, in conjunction with
police from the Shepparton, Seymour, Yarrawonga and Ballarat Crime Investigation Units, and officers
from the ATO and the ITTF resulting in the seizure of 1,324,268 cigarettes with an estimated excise valueof $1.6 million and approximately 901 kg loose-leaf tobacco ($1.6 million)53
October: Police from the VIPER Taskforce, Crime Command and North West Metro Region, andrepresentatives from ABF, ATO, Australian Federal Police, TGA and Sherriff's Office seized 524,851
cigarettes representing a $400,000 profit and 30kg of loose tobacco 54

46

Australian Taxation Office, “Tip-off pays off as illicit tobacco uprooted in joint raids,” Australian Taxation Office (23February 2023), https://www.ato.gov.au/media-centre/tip-off-pays-off-as-illicit-tobacco-uprooted-in-jointraids#ato-FactsforJournalists.
47
Australian Taxation Office, “Illicit tobacco case studies,” Australian Taxation Office (27 February 2024),
https://www.ato.gov.au/about-ato/tax-avoidance/the-fight-against-tax-crime/news-and-results/case-studies/illicittobacco-case-studies.
48
Australian Taxation Office, “Investigation into illicit tobacco syndicate – Central West NSW,” Australian Taxation
Office (11 April 2023), https://www.ato.gov.au/media-centre/investigation-into-illicit-tobacco-syndicate-centralwest-nsw.
49
Australian Taxation Office, “Operation Junglevine2 slashes second tobacco crop,” Australian Taxation Office (2 May2023), https://www.ato.gov.au/media-centre/operation-junglevine2-slashes-second-tobacco-crop.
50
Australian Taxation Office, “Third major illicit tobacco bust for Operation Junglevine2,” Australian Taxation Office(2 May 2023), https://www.ato.gov.au/media-centre/operation-junglevine2-slashes-second-tobacco-crop.
51
Australian Taxation Office, “Multi-million-dollar money laundering investigation smashes illicit tobacco and vapesupply,” Australian Taxation Office (31 August 2023), https://www.ato.gov.au/media-centre/multi-million-dollarmoney-laundering-investigation-smashes-illicit-tobacco-and-vape-supply.
52
Australian Border Force“Cash, vapes and illegal tobacco seized in huge multi-agency tobacco raids,” Australian
Border Force (10 August 2023), https://www.abf.gov.au/newsroom-subsite/Pages/Cash,-vapes-and-illegal-tobaccoseized-in-huge-multi-agency-tobacco-raids.aspx.
53
Australian Taxation Office, “Lunar and VIPER seize over $2 million of illicit tobacco products,” Australian Taxation
Office (27 October 2023), https://www.ato.gov.au/media-centre/lunar-and-viper-seize-over-2-million-dollars-ofillicit-tobacco-products.
54
Australian Border Force, “Warrants executed across Melbourne targeting illicit tobacco,” Australian Border Force(19 October 2023), https://www.abf.gov.au/newsroom-subsite/Pages/Warrants-executed-across-Melbournetargeting-illicit-tobacco.aspx.
Australian Illicit Tobacco Study 2023, May 2024 FTI Consulting Inc. 59

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