Published on 7 Oct 2025

Smoking Reduction Consultation

Sarah McDowell Regulatory Lead (AU) Contact me
Kylie Berg Director Business Development (AU) Contact me

Allen + Clarke partnered with Queensland Health to review, analyse and synthesise 180 stakeholder submissions on policy proposals aimed at reducing smoking rates. The consultation addressed environments promoting smoking, regulatory inefficiencies, and illicit tobacco trade. Our analysis supported Queensland Health's recommended policy options, ultimately informing new smoking control laws that will create healthier environments across Queensland.

Key Takeaways:

  • Our analysis of 180 diverse stakeholder submissions validated Queensland Health's original policy proposals, demonstrating the strong foundation of their initial recommendations.

  • The consultation addressed critical gaps in smoking regulation, from retail licensing to outdoor smoking area requirements and restrictions for minors.

  • The project supported new smoking control laws in Queensland, creating impact on public health outcomes.
Our understanding of tobacco control measures and regulatory frameworks positioned us to evaluate stakeholder submissions against both practical implementation considerations and broader public health goals. The project demonstrates how thorough stakeholder consultation, when paired with expert analysis, can strengthen regulatory frameworks and deliver lasting public health benefits.

The Challenge

Queensland Health, the state government department responsible for health services, faced the challenge of addressing persistently high smoking rates. The department needed to evaluate stakeholder feedback on proposed policy changes to the Tobacco and Other Smoking Products Act 1998. These proposals aimed to address environments promoting smoking uptake, inefficiencies in monitoring and enforcement frameworks, and illicit tobacco trade in retail settings.

The complexity of the task came from the need to balance diverse stakeholder interests while ensuring evidence-based policy recommendations. With 180 submissions from varied sources including the public, tobacco retailers, NGOs, and liquor licensed venues, Queensland Health required data analysis to synthesise this feedback effectively and determine which proposals would create the greatest public health benefit.

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Our Approach

Allen + Clarke brought expertise in policy analysis, public health regulation, and stakeholder engagement to address the consultation. Our understanding of tobacco control measures and regulatory frameworks positioned us to evaluate stakeholder submissions against both practical implementation considerations and broader public health goals.

Our methodical approach enabled rigorous attention to detail:


  • Systematic review - we evaluated all submissions to determine whether responses were within scope for the consultation.

  • Qualitative coding - submissions were imported into NVivo and coded according to a structured framework that captured key themes and concerns.

  • Evidence-based assessment - we evaluated feedback against assessment criteria informed by the Office of Best Practice Regulation's Regulatory Impact Statement requirements.

  • Recommendation development - our analysis culminated in a detailed report that summarised key messages and made evidence-based recommendations.

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Delivering meaningful impacts for Queensland communties

Our assessment criteria ensured recommendations were robust, considering whether each proposal addressed the regulatory problem, was supported by evidence, was proportionate to risk, supported efficient compliance practices, represented community benefit, and aligned with domestic and WHO smoking control policies.

Based on data analysis, we illustrated the merit of Queensland Health's original policy proposals. These included introducing a licensing scheme for wholesale and retail suppliers, modernising advertising provisions, restricting smoking product sales at licensed venues, prohibiting sale and handling of tobacco by minors, and implementing new outdoor smoking area requirements.

The consultation outcomes delivered meaningful impact for Queensland communities:


  • Policy influence - our analysis supported decision making on new smoking control laws in Queensland.

  • Transparent decision-making - the stakeholder consultation process ensured diverse perspectives were considered in policy development.

  • Improved public health outcomes - the resulting regulations supported healthier environments by reducing smoking rates and exposure to second-hand smoke.

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