In March 2016, SFP conducted an exercise of identifying tobacco interest representatives registered in the EU’s Transparency Register. The search aimed to identify human and budget resources declared by the tobacco industry as lobbying towards the EU institutions. The results were published at https://smokefreepartnership.eu/position-papers-briefings-reports/sfp-briefing-on-article-5-3-of-the-fctc.

A similar exercise was conducted in 2017, relating to the updated declarations in the EU transparency register related 2015-2016 tobacco industry lobby spending.

Methodology
The search started with the identification of the resources invested by the transnational tobacco companies and European trade associations in the tobacco sector. From there, SFP cross-referenced this information with membership organisations and associations for these companies, national tobacco industry associations and consultancies with tobacco industry clients. An additional free-text search for the terms “tobacco” and “cigarette” in English, French, German and Italian was conducted.

Findings
• In 2015-2016, the tobacco industry and its supporters (manufacturers, retailers, wholesalers, paper/filter manufacturers, growers and processors) declared a combined spending of between 8 and 10 million euros annually in interest representation. 
• Based on the same numbers, the tobacco industry had 106 people (equivalent to 54 full-time employees) employed in lobbying. However, only 29 persons are accredited to the European parliament, just over a quarter of the total employed lobbyists 
• In addition to that, various public affairs consultancies declared budgets of between 1.5 and 2.75 million euros for representing tobacco clients.

Limitations
• The EU lobby registry is voluntary and therefore may not contain all interests represented; certain categories of interest representatives are not requires to register. 
• There are limited compliance mechanisms to check the accuracy of registrations. 
• There are general organisations of business interests (e.g. chambers of commerce who represent also wider interests) who also work in the interest of the tobacco industry however it is difficult to identify the specific resources linked to their policy involvement. See below a list of all where the four largest tobacco companies disclose their membership. 
• There are also some language limitations for the search. 
• There are general organisations of business interests (e.g. chambers of commerce who represent also wider interests) who also work in the interest of the tobacco industry however it is difficult to identify the specific resources linked to their policy involvement that defends tobacco interests. See below a list of all where the four largest tobacco companies disclose their membership.

Conclusion
Tobacco industry lobby remains strong, with an increase in both spending and people invested in this activity.

Other resources 
We continued to refer to Lobbyfacts.eu for a historical perspective on transparency register entries. https://lobbyfacts.eu/articles/01-09-2016/2013-was-big-year-tobacco-industry-lobbying.