The policy implementation playbook: a cross-policy taxonomy of post-adoption tobacco industry tactics

Matthes et al. Globalization and Health (2026) 22:53 https://doi.org/10.1186/s12992-026-01220-0 Globalization and Health Open Access REVIEW The policy implementation playbook: a crosspolicy taxonomy of post-adoption tobacco industry tactics Britta K. Matthes1* , Karen Evans-Reeves1, Tom Gatehouse1, Rosemary Hiscock1, Iona Fitzpatrick1 and Anna B. Gilmore1 Abstract Background Tobacco industry interference during policy development is well documented, yet evidence on how the industry responds after policies are adopted and enter into force remains fragmented across policy domains and jurisdictions. This study systematically examines post-adoption tobacco industry conduct across key tobacco control measures and develops a cross-policy taxonomy of post-adoption tactics. We conducted a scoping review and qualitative evidence synthesis of peer-reviewed and grey literature, searching six data bases and Tobacco Control’s News Analysis archive. Using inductive coding, we identified recurring forms of post-adoption industry activity and synthesised these into a conceptual taxonomy – the Policy Implementation Playbook (PIP). Results We included 308 sources (210 peer-reviewed articles and 98 News Analysis items) spanning approximately 50 countries across all WHO regions, although documentation was concentrated in a limited number of settings. The PIP identifies five recurrent tactics. One – pre-emptive adaptation – occurs before a policy enters into force and includes stockpiling, transitional packaging, and early product or marketing adjustments. After a policy enters into force, the industry may disregard requirements, adopt token implementation that signals formal compliance while reducing practical impact, circumvent regulation through product-, design-, or channel-based tactics, or seek to influence implementation indirectly through retailers, hospitality actors, public authorities, and enforcers. Circumvention was the most frequently documented response across most policies, though its specific form varied across regulatory domains. Disregard and pre-emptive adaptation were also common, while token implementation was largely confined to health warning requirements. Smoke-free regulations more often elicited intermediary-focused strategies aimed at shaping interpretation, enforcement, and compliance. Conclusions By conceptualising policy implementation as a contested political arena and synthesising recurrent tobacco industry tactics across policies, the PIP extends existing models of corporate political activity. The taxonomy provides a structured basis for anticipating post-adoption corporate conduct and strengthening regulatory design, implementation, and governance in tobacco control and the regulation of other unhealthy commodities. Clinical trial number Not applicable. *Correspondence: Britta K. Matthes Full list of author information is available at the end of the article © The Author(s) 2026, modified publication 2026. Open Access This article is licensed under a Creative Commons Attribution 4.0 International License, which permits use, sharing, adaptation, distribution and reproduction in any medium or format, as long as you give appropriate credit to the original author(s) and the source, provide a link to the Creative Commons licence, and indicate if changes were made. The images or other third party material in this article are included in the article’s Creative Commons licence, unless indicated otherwise in a credit line to the material. If material is not included in the article’s Creative Commons licence and your intended use is not permitted by statutory regulation or exceeds the permitted use, you will need to obtain permission directly from the copyright holder. To view a copy of this licence, visit http://creativecom mons.org/licenses/by/4.0/. Matthes et al. Globalization and Health (2026) 22:53 Page 2 of 20 Keywords Tobacco industry, Policy implementation, Tobacco control Background Tobacco control policies have been adopted across a growing number of countries since the turn of the century, driven in large part by the World Health Organization Framework Convention on Tobacco Control (WHO FCTC), which entered into force in 2005 [1]. For example, by 2024, 107 countries had achieved the highest levels of WHO FCTC implementation – defined as the translation of the treaty into national or local policy – in at least two policy areas [2]. The tobacco industry remains a principal barrier to policy progress [3]. Research shows that transnational tobacco companies act to prevent, weaken, or delay regulation that threatens their profits, particularly in the early stages of the policy cycle [4–6], where opposition is perhaps most visible. Common corporate political activities include lobbying, mobilising third parties, creating doubt, disseminating industry-favourable information, and deploying legal threats and challenges [7–9]. Frameworks such as the Policy Dystopia Model (PDM) [4, 10] illustrate how discursive and action-based strategies are used to resist and reshape policy proposals. As tobacco control policies become more widespread and comprehensive, it is increasingly important to understand what happens after policy adoption. Evidence is clear that written policies can differ substantially from policies in practice, with studies indicating that key measures such as advertising bans and labelling requirements are often not fully enforced, particularly in lower-income settings [11–14]. Weak or uneven implementation can sustain commercial advantage and may reinforce industry claims of “anticipated failure” used to oppose regulation [8, 15]. In line with this, evidence suggests that tobacco industry interference does not cease once policies are in place. Studies document non-compliance [16–18], exploitation of loopholes [13, 19–21], and adaptive practices that preserve misleading connotations and can dilute policy impact [22–25]. However, this evidence remains fragmented across policy areas and jurisdictions, limiting the ability to identify recurring patterns or compare industry responses across different contexts. A notable exception is a systematic review of tobacco industry responses to excise tax policies, which mapped sophisticated pricing strategies used globally to undermine policy effectiveness [26]. While the PDM captures reputation and information management strategies that shape the policy environment across the policy cycle [4, 10], it does not systematically categorise the range of industry activities occurring once a policy has entered into force. The present study addresses this gap by systematically examining and synthesising tobacco industry conduct after policy adoption across key tobacco control domains: tobacco advertising, promotion and sponsorship (TAPS), packaging and labelling, product-related regulation, and smoke-free policies (Articles 8–11 and 13 of the WHO FCTC). Packaging and labelling include misleading descriptor ba (...truncated)