Plain tobacco packaging duty on cigarettes fell by 3.4% in Australia in 2013 compared to 2012 when plain packaging was introduced. Some commentators referred to data provided by the tobacco industry and claimed that the tobacco sales volume had increased by 59 million sticks (individual cigarettes or their roll-your-own equivalents) during the same period. According to Philip Morris International, 2013 saw a 0.3% increase in tobacco sales compared to 2012. Other commentators however contradicted these claims based on data published by the Australian Bureau of Statistics in March 2014. A study conducted by KPMG for three major cigarette manufacturers had found that illegal
Plain tobacco packaging in EU countries in May 2016, the option for the Member States to introduce plain packaging. Legal scholars consider plain packaging to be consistent with primary European law and German law. The directive adopted April 3, 2014 explicitly states that 28 EU countries have the option of implementing plain packaging, a provision upheld on May 4, 2016 by the European Court of Justice as valid when dismissing a tobacco industry legal challenge. In December 2010, a UMP member of the French Parliament tabled a Member's Bill aimed at creating plain cigarette packaging. However, the bill did not pass despite ongoing