Clearing the Air has published a great piece of investigative journalism looking into the shenanigans of a small Brussels-based anti-nicotine non-profit, Impact Unfiltered. 

Clearing the Air co-founder Peter Beckett and ACVODA’s Hans Molenaar have published an explosive article that examines Impact Unfiltered, an NGO whose stated mission is to “support and mobilise public-health advocates across the continent, ensuring they have the evidence, alliances, and voice to reclaim tobacco regulation in the public interest.”

Impact Unfiltered is a relatively obscure group, but their website is just as you might expect: bloodless copy littered with lanyard-class buzzwords. The non-profit seems to have oozed out of a foundation called The School of Moral Ambition. I’d well believe their graduates are teeming with burning ambition. But morality? Well, let’s see. 

Clearing the Air’s investigation

The investigation centres around a study that Impact Unfiltered conducted on a recent EU Consultation on the Tobacco Tax Directive. Politico, generally a reliable source, published an article that seemed to give credence to an Impact Unfiltered conspiracy theory that suggests over 40% of the 18,480 responses were “nearly identical submissions using the same 'illicit trade' talking points, sent anonymously from across Europe.”

A later article in Generation Sans Tabac went even further, claiming it was a “massive spam campaign from the tobacco lobby.” What’s more, the authors claim they found it highly suspicious that 6,000 responses referenced the concept of “harm reduction,” suggesting it was a tobacco industry term.

However, Beckett and Molenaar smelled a rat.

Desk scene showing analysed consultation data and highlighted NGO reports, representing investigation into claims of bot-driven submissions.

What the investigation found

While I’d urge anyone to read the Clearing the Air article or this X thread to get the full details, it’s fair to say they demolish many of the claims made by Impact Unfiltered. For example:

Claim:

Impact Unfiltered claimed 81% of submissions were anonymous.

Truth:

These submissions were anonymous to the public. Submitters needed to give details via the EU Login system to comment, which included their names.

Claim: The term harm reduction appears 6,000 times in the responses.

Truth: It appears around 1,300 times across 18,000 submissions.

Claim: The submissions are bots.

Truth: Most‑repeated texts are few in number, spread over hours or days, and attachments are rarely duplicated, which they say is inconsistent with mass botting.

Claim: Big Tobacco is subverting democracy.

Truth:  LLM sentiment analysis shows that most categories of respondents oppose the tax proposal.

Let’s be honest about what is going on here. The EU asked the public how they felt about tax rises on products, and they got an answer they didn’t like. Instead of accepting that these proposals are unpopular, a Vital Strategies-linked NGO has, through either malice or incompetence, spun a yarn about Big Tobacco bots in the hope of silencing stakeholders' opinions. This approach is entirely consistent with how the WHO treats vapers.

Tobacco control paranoia

Tobacco control paranoia is out of control. Too often, they appear more like the Substance D addicts in Philip K. Dick’s novel A Scanner Darkly than serious academics or whatever they’re supposed to be. Indeed, the threat perception has been pushed so far that objectivity is impossible.

The fact is, people don’t like tax hikes. When the EU Commission’s plans to strangle smoking alternative products were leaked, people who rely on these products were unhappy. You see, it’s one thing to lumber people with sin taxes for cigarettes, especially if a country has publicly funded healthcare. But to treat vapes in the same way is shortsighted and, frankly, unfair.

Groups like Impact Unfiltered are so out of touch with the public that they immediately assume that objections to being punished for vaping must be an orchestrated bot campaign. They don’t understand that there are a lot of people who are passionate about vaping because it helped them change the trajectory of their health. These are the type of people who will respond to campaigns that threaten to make vaping less accessible.