RAS Blog

Category: Cigarette Smuggling

  • RAS Reports Huge Jump In Tobacco Purchased At Duty-Free Or Abroad | Checkout.ie

    September 29, 2025

    There has been an increase in consumers purchasing tobacco at duty-free or abroad, according to a new poll commissioned by Retailers Against Smuggling (RAS).

    In the poll, carried out by Amárach on behalf of RAS, the proportion of customers solely buying tobacco abroad or in duty-free has more than doubled – from 8% in May to 19% in August 2025.

    RAS notes that these figures illustrate that Ireland’s Tobacco Products Tax is ‘incentivising’ more consumers to purchase tobacco abroad at a lower cost.

    The group added that the lack of enforcement capacity by Revenue means that large volumes of cigarettes coming back to Ireland are in breach of duty-free and travel allowances.

    These findings further add to concerns over the scale of untaxed and illicit tobacco already in circulation, which is hurting legitimate retailers and causing a financial loss to the Exchequer.

    The Revenue Commissioners’ Illegal Tobacco Product Research Surveys 2024 found that 37% of cigarette packs in circulation carried no Irish stamp duty.

    Including roll-your-own tobacco, this represented a tax loss of €934 million in 2024 alone.

    RAS warned that, unless effective action is taken against purchases made in excess of travel allowances, smuggling and illicit trade will continue to erode legitimate retail business and undermine Exchequer returns.

    Now RAS is calling on the government to take decisive action in Budget 2026 to tackle the sale of illicit tobacco in Ireland.

    It suggests that the government introduce a freeze on excise duty on tobacco products, in a bid to halt the growth of Ireland’s untaxed tobacco market, and recruit an additional 250 members of Revenue Commissioner frontier staff to provide a visible and effective deterrent and enforcement capacity at Dublin’s ports and airports.

    ‘A Direct Blow’

    RAS spokesperson Benny Gilsenan commented on the results of the poll, saying, “The poll blatantly shows that Irish consumers are increasingly sourcing tobacco outside the state.

    “Every purchase made abroad or in travel retail in excess of legal limits is a direct blow to the bottom line of retailers and the Exchequer, and even more so when these products are sold on the black market.

    “It’s time for the government to recognise that the behavioural shift is directly driven by successive excise increases and take meaningful actions to tackle this behavioural shift by consumers while protecting legitimate retailers.”

  • RAS Launches New Website To Tackle Unprecedented Smuggling Figures | Checkout.ie

    September 24, 2025

    Retailers Against Smuggling (RAS) have launched a new website to tackle the issue of smuggling in Ireland and its impact on the retail sector.

    The group is also hosting a pre-budget reception in Doheny Nesbitts on Baggot Street this evening, Wednesday 24 September, for political officials and local retailers to spotlight how the documented surge in tobacco smuggling in recent years is undermining retailers’ revenues and costing the state millions of euros.

    The newly launched RAS website lays bare the figures, which charts the rising values of seized tobacco, which ballooned from €63 million in 2023, to €128 million in 2024, as well as the estimated €934 million in total lost revenue from tobacco products last year.

    In April, the Revenue Commission published a survey which revealed a staggering 37% spike in illicit market cigarettes alone, which now account for more than one in four (26%) of all cigarettes in circulation in 2024, compared to less than one in five (19% in 2023, and were worth over €590 million in lost taxes.

    As well as a steep rise in the prevalence of illicit and non-duty paid tobacco, RAS’s own surveys conducted by Amárach this year found a shift in consumer behaviour.

    Between May and August this year, the percentage of consumers purchasing tobacco and vape products exclusively abroad or in duty free, as opposed to Irish retailers, has more than doubled, rising from 8% to 19%.

    ‘Legitimate Retailers Cannot Compete With Criminals’

    RAS spokespersons Benny Gilsenan and Philip Craddock will speak at the event.

    In his speech, Gilsenan will say, “RAS acknowledges and welcomes the efforts of Revenue to tackle smuggling, but the reality is: it’s simply not enough.

    “Legitimate retailers cannot compete with criminals reselling illegal products at a fraction of the price.

    “This is destroying livelihoods, distorting the market, and undermining public finances.

    “Tonight, as we launch our new website and share our (Pre-Budget) Submission, we send one message: the Government must act now to get on top of this problem before it gets any worse.”

    Ahead of next week’s Budget, the group is calling for a freeze on the excise on cigarettes – which is the highest in Europe – as well as increased staffing and scanner resources to detect illegal tobacco being smuggled into Ireland and increase in the fines and prison sentences for court convictions for illegal smuggling.

  • One third of cigarette packs are illicit or non-duty paid – Drinks Industry Ireland

    Thirty-seven percent of 1,000 respondents to a recent Irish Thinks survey admitted to being open to buying goods or services from illicit sources

    25 July 2025

    In the Tax Strategy Group’s paper on General Excise, it is recognised that, despite rate increases to Tobacco Products Tax (TPT) in successive budgets, there has been a noticeable decline in receipts while smoking prevalence remains the same. 

    The forecasting of tobacco tax returns has become increasingly difficult due to the alarming rate at which illicit trade and smuggling of non-Irish duty paid products is taking place. 

    The Tax Strategy Group warns that “the notable increases in the volume of products being consumed outside the scope of Irish excise duty raises concerns that price increases may be creating greater incentive for black market activity.”

    Black market activity

    RAS has welcomed the admission by the Tax Strategy Group that excessive excise duty is likely increasing black market activity, which may help explain the tsunami of cigarette smuggling which Ireland is currently facing.

    The connection between hikes in excise duty on tobacco products and increases in black market activity is verified by the level of seizures of illegal cigarettes in the first six months of this year.  

    Major seizures

    In 2023, a total of 31 major seizures came to the value of €58 million, at a loss of €45 million to the exchequer. 

    So far, in the first half of this year alone, there have been 27 major seizures, worth a total value of around €53 million and a loss to the exchequer of €40 million.  

    The latest Illegal Tobacco Products Research Survey from 2023 indicates that more than one third of cigarette packs consumed in the State are illicit or non-duty paid. 

    Notable increases in the volume of products being consumed outside the scope of Irish excise duty should raise concerns within Government that price increases are serving to drive more consumers to the black market and are making Ireland a target destination for criminal gangs selling illicit products.  

    Illicit trading

    Price increases across the economy are playing a major role in the normalisation of illicit trade activity, with 37% of 1,000 respondents to a recent Irish Thinks survey admitting to being open to buying goods or services from illicit sources, if the price was substantially lower than the legal market value. 

    RAS believes these trends should be a key consideration in the context of Budget 2025. RAS also contends that with tobacco receipts regularly exceeding €1 billion annually, it is not unreasonable that more of this revenue should be spent on enforcement with a view to protecting the revenue source. 

    In its 2025 pre-budget submission, RAS is calling on the Government to:

    • Reduce/freeze consumer taxes including tobacco excise
    • Increase funding for detection and enforcement of smuggling
    • Amend the Finance Act to prosecute all suspected smugglers at Circuit Court level or higher

  • Taxpayers lose nearly a billion to black market tobacco – Dublin People

    25 July 2025

    Retailers Against Smuggling (RAS) has called for urgent action to be taken to combat black market tobacco as the Tax Strategy Group (TSG) Papers for 2026 admit that the prevalence of illicit and non-Irish duty paid tobacco illustrate that increases to excise duties ‘may not lead to increased revenue’, reinforcing that excise increases are fuelling a booming black market, rather than reducing smoking rates. 

    The papers follow on from Revenue’s recently published Illegal Tobacco Products Research Survey 2024- independently conducted by Ipsos MRBI- which revealed a staggering total loss of roughly €934 million in taxpayer money to illegal tobacco products last year alone. 

    The TSG publication, which sets out options for tax policy changes, acknowledged that annual figures show the excise on tobacco products, which has increased by steadily increased by €3.75 since 2019, is having the opposite of its intended effect– pushing consumers to purchase illicit or non-duty paid tobacco, while the revenue generated by Tobacco Product Tax falls year on year. 

    Despite intentions to increase revenue to the Exchequer through increased Tobacco Product Taxation, figures show that TPT revenue has in fact plummeted from €1.32 billion in 2020, to just €976 million in 2023- a loss of €342 million to the taxpayer. Even more concerning, the TSG Papers note that three quarters of this yield was collected prior to the Budget 2025 excise increase. Meanwhile, Revenue statistics show the value of tobacco seizures doubled between 2023 and 2024, to €130 million. 

    The TSG papers also call-out and discuss RAS’ pre-budget submission, which highlights this trend of tax loss in comparison to excise increase, and submits that a freeze on excise and improved detection and enforcement of illicit trade is the best option to increase TPT revenue and to put money back into taxpayer pockets. 

    Reference is made to the stark Revenue Commissioner survey published this April, which revealed a whopping 37% spike in illicit market cigarettes. These accounted for 26% of all cigarettes in circulation in 2024 compared to 19% in 2023, and were worth over €590 million in lost taxes. RAS estimates that a further €249 million was lost on the survey’s reported 11% travel purchases of cigarettes in 2024. No Irish excise or VAT has been paid on any of these cigarettes and Retailers Against Smuggling is concerned that many of these ‘legal’ cigarettes are being brought in breach of duty free and travel allowances. RAS estimates that a further €95 million was lost in taxes on RYO Tobacco in 2024, bringing the total taxpayer losses on tobacco products to an astounding €934 million in one year alone.1 

    RAS National Spokesperson Benny Gilsenan stated: 

    “As admitted by the Government in the latest Tax Strategy Group Papers, it is clear that increasing excise on tobacco products is not only having no effect on smoking rates– with €934 million in lost taxes on tobacco products, the scale of Ireland’s untaxed tobacco market is staggering – and it’s taking business away from legitimate Irish retailers. 

    “Continuous increases in excise are driving people to purchase the cigarettes from the black market or abroad, and we are seeing less money from the Tobacco Products Tax every year it is increased. It has become clear it is no longer a financially viable approach, and it is time for the Government to focus on tackling illicit trade, rather than taking measures which affect legitimate retailers and the taxpayer.” 

    In its pre-budget submission, Retailers Against Smuggling are calling on the Government to: 

    • Freeze excise on cigarettes, which is already the highest in Europe, and is clearly fuelling tobacco smuggling; 
    • Increase staffing and scanner resources to detect illegal tobacco being smuggled into Ireland, including through our airports through breaches of duty-free allowances; 
    • Increase the fines and prison sentences for court convictions for illegal smuggling. 

  • Ireland’s untaxed cigarette market now worth €790 million, retailers say – Breaking News

    01 May 2025

    Retailers Against Smuggling (RAS) has said that the Revenue Commissioner’s Illegal Tobacco Products Research Survey 2024 proves that the Government is losing the battle against Ireland’s booming market in illicit tobacco, stating that the untaxed cigarette market is now worth €790 million.

    Wednesday’s Revenue Commissioner survey found that 37 per cent of cigarette packs in circulation had no Irish excise duty paid as they were either illegal or purchased outside Ireland.

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    This marks an increase from 34 per cent in 2023. In the case of the roll-your-own tobacco market, the proportion of products in circulation with no Irish duty paid was a massive 49 per cent.

    The regulated cigarette market in Ireland – for which excise duty was paid – had a total retail value €1.34 billion in 2024, meaning that untaxed cigarette market – making up the 37 per cent of the cigarettes in circulation according to this week’s survey – had a retail value of €790 million in 2024, RAS said.

    €550 million of this was accounted for by illegal cigarettes. The Revenue Commissioners successfully seized €96 million in illegal cigarettes in 2024, meaning they seized less than one in five of all illegal cigarettes in circulation in Ireland last year.

    RAS spokesperson, Benny Gilsenan, said: “With a retail value of €790 million, the scale of Ireland’s untaxed tobacco market is staggering – and it’s taking business away from legitimate Irish retailers.

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    “It is clear that the Government has lost control of Ireland’s tobacco black market; and their current rate of seizure is only the tip of the iceberg. Ireland needs a new strategy to tackle illegal cigarette smuggling.”

    “One of the main reasons Ireland’s untaxed cigarette market has grown so large is because continuous increases in excise are driving people to purchase the cigarettes from the black market or abroad, a trend being allowed by a serious lack of enforcement of duty free and travel allowances.”

    Retailers Against Smuggling siad they are calling on the Government to:

    • Freeze excise on cigarettes, which is already the highest in Europe, and is clearly fuelling tobacco smuggling;
    • Increase staffing and scanner resources to detect illegal tobacco being smuggled into Ireland, including through our airports through breaches of duty-free allowances;
    • Increase the fines and prison sentences for court convictions for illegal smuggling.

  • Government loses almost a billion euros in taxes ‘as black market tobacco sales explode’ – Shelflife

    Less than one-in-five illegal cigarettes were seized during 2024: RAS

    30 April 2025

    Government loses almost a billion euros in taxes as black market tobacco sales explode, noted Retailers Against Smuggling (RAS).

    RAS has said the publication today (30 April) of the Revenue Commissioner’s Illegal Tobacco Products Research Survey 2024 proves that Government is losing the battle against Ireland’s booming market in illicit tobacco.

    Cigarettes

    Less than one-in-five illegal cigarettes were seized during 2024, research shows.

    Today’s Revenue Commissioner survey finds that 37% of cigarette packs in circulation had no Irish excise duty paid as they were either illegal or purchased outside Ireland.

    This marks an increase from 34% in 2023. In the case of the Roll-Your-Own tobacco market, the proportion of products in circulation with no Irish duty paid was a staggering 49%. The numbers indicate that the illicit trade in RYO tobacco has increased by 53% when compared to last year’s findings.

    The Revenue Commissioner survey reveals that illicit market cigarettes accounted for 26% of cigarettes in circulation in 2024 and was worth over €590 million in lost taxes.

    RAS estimates that a further €249 million was lost on the 11% travel purchases of cigarettes in 2024.

    No Irish excise or VAT has been paid on any of these cigarettes and Retailers Against Smuggling is concerned that many of these ‘legal’ cigarettes are being brought in breach of duty free and travel allowances.

    RYO

    Half of all Roll-Your-Own (RYO) tobacco in circulation had no Irish duty paid, RAS highlighted.

    RAS estimates that a further €95 million was lost in taxes on RYO Tobacco in 2024.

    Commenting on the findings, Benny Gilsenan, Spokesperson, RAS National, stated: “With €934 million in lost taxes on tobacco products, the scale of Ireland’s untaxed tobacco market is staggering – and it’s taking business away from legitimate Irish retailers.

    “One of the main reasons Ireland’s untaxed cigarette market has grown so large is because continuous increases in excise are driving people to purchase the cigarettes from the black market or abroad, a trend being allowed by a serious lack of enforcement of duty free and travel allowances.”

    Further findings

    Polling conducted by Ireland Thinks on behalf of RAS in November 2024 showed that a sizeable majority (58%) of those who bought cigarettes bought some or all of them from abroad, up from 45% in March 2024.

    RAS’s concerns have been confirmed by the Revenue Commissioner’s survey which recognises “a notable increase in illicit trade attributed to informal imports sourced through friends.”

    The survey found that the percentage who sourced cigarettes from “Friend brought them home from a trip abroad” nearly doubled from 15% in 2023 to 27% in 2024.

    The regulated cigarette market in Ireland – for which excise duty was paid – had a total retail value €1.34 billion in 2024, meaning that black market cigarettes (making up the 26% of the cigarettes in circulation according to today’s survey) were worth over €550 million in 2024.

    The Revenue Commissioners successfully seized €96 million in illegal cigarettes in 2024, meaning they seized less than one in five of all illegal cigarettes in circulation in Ireland last year.

    ‘Exorbitant excise rate’

    RAS claim that Ireland’s exorbitant excise rate on tobacco, which is the highest in Europe, is fuelling the increase in black market activity.

    “The Government has its head in the sand on the impact that the huge excise burden on tobacco is having on the legitimate market,” Gilsenan added.

    “What’s worse, these 2024 Revenue figures only reflect the 2023 excise increase of 75 cents on cigarettes. In late 2024, Government lumped a whopping €1 excise on cigarettes.

    “This means that the current levels are most likely much higher than the 2024 figures.

    “The last three Revenue Commissioner illegal tobacco surveys have found the highest ever illicit figures recorded for tobacco in Ireland; year on year the problem is just growing, and legitimate retailers are losing out. In spite of this, Government lumped on the highest ever excise increase last year, it’s just a baffling response to this clear loss of control of the black market.”

    RAS are calling on the Government to:

    Freeze excise on cigarettes, which is already the highest in Europe, and is clearly fuelling tobacco smuggling;

    Increase staffing and scanner resources to detect illegal tobacco being smuggled into Ireland, including through our airports through breaches of duty-free allowances;

    Increase the fines and prison sentences for court convictions for illegal smuggling.

    Read more: Retailers Against Smuggling welcome budget 2025 tax strategy paper

  • RAS Notes That 60% Of Tobacco-Related Convictions Are Untracked – Checkout.ie

    April 22 2025

    Retailers Against Smuggling (RAS) has called attention to the fact that less than half (40%) of fines issued for summary prosecutions for tobacco smuggling are being tracked for payment or non-payment.

    The organisation blamed the gulf on an ad-hoc system of coding of prosecutions.

    It has now called on the Revenue Commissioner and Courts Service to urgently address serious gaps in the data relating to the payment of fines for tobacco-related convictions.

    An analysis by RAS shows that over the five years from 2020 to 2024, there were a total of 316 summary convictions at District Court Level for tobacco offences, on charges such as smuggling or evasion of excise duty and illegal selling.

    This resulted in 285 fines being issued.

    However, the Courts Service can only provide data on whether fines were paid in relation to 114 of these convictions, amounting to only 40%.

    This analysis is based on data sourced from a Freedom of Information request and answers to parliamentary questions.

    Prosecution Codes

    In response to RAS’s Freedom of Information request, the Courts Service advised that it can only provide data in relation to fines for which offence codes were used on the system by prosecutors.

    Prosecutors may have used uncoded free text for some offences and thus, data is unavailable in these instances.

    RAS has stated that it believes the ad-hoc system of prosecutors being able to enter any code they wish is inadequate and, given the importance of the quality of data to policy making and public service management, this practice must be addressed to ensure prosecutions are accurately coded.

    The organisation has reached out to the government asking that they urgently address the ad-hoc system of coding to plug serious data gaps relating to the payment of fines for tobacco and related offences.

    ‘Adequate Enforcement’

    Speaking about this call to action, RAS national spokesperson Barry Gilsenan said, “Fines for tobacco smuggling in Ireland are pathetically low, and we don’t know if they’re all being paid.

    “Smuggling and illicit trade are increasingly prevalent and those caught engaging in these illegal acts must be properly held to account.

    “Accurate data will allow policymakers to understand the state of the black market.

    “RAS are calling for increased penalties levied on offenders and adequate enforcement of those penalties.

    “As it stands, a majority of offenders are off the hook for their crimes, as they face no repercussions for their crimes.

    “We must deter black market tobacco trade and protect legitimate retailers in the process.”

  • RAS: Factory Discovery Highlights ‘Out Of Control’ Illegal Tobacco Trade – Checkout.ie

    RAS: Factory Discovery Highlights ‘Out Of Control’ Illegal Tobacco Trade – Checkout.ie

    06 March 2025

    A spokesman for Retailers Against Smuggling (RAS) has highlighted the “out of control” illicit tobacco trade in Ireland, following the discovery of an illegal cigarette factory in Co. Louth.

    RAS congratulated the Revenue Commissioners and An Garda Síochána for their success in discovering and shutting down the highly sophisticated factory, where almost €600,000 worth of cigarettes were seized.

    The spokesman for the retail group has warned that this seizure is the “tip of the iceberg”, and that tobacco smuggling is “out of control”.

    Headline figures recently released by the Revenue Commissioners show that Irish authorities seized €128 million worth of illegal tobacco in 2024, compared to €63 million in 2023.

    In total, 112 million cigarettes were seized by Irish authorities in 2024, with the amount nearly doubling in one year.

    In 2024, the Revenue Commissioners published a survey that showed that 34% of cigarettes in circulation in Ireland were non-duty paid.

    RAS national spokesman Benny Gilsenan – who is also a retailer in North Dublin – said, “This factory closure and the massive scale of seizures last year represent only the tip of the iceberg.

    “Tobacco-smuggling is out of control in Ireland.

    “The new government must massively increase their efforts to tackle tobacco-smuggling, starting with increased scanning and detection at our ports, and adopting a zero-tolerance approach to illegal cigarettes being sold in our communities.

    “Tobacco-smuggling is costing millions in lost revenue to both legitimate retailers and the Irish Exchequer.

    This factory closure is welcome, but more is needed to get on top of the problem.”

  • Record €128m In Illegal Tobacco Seizures In 2024 “Tip Of The Iceberg” – RAS | Checkout.ie

    Record €128m In Illegal Tobacco Seizures In 2024 “Tip Of The Iceberg” – RAS | Checkout.ie

    Retailers Against Smuggling calls on incoming government to tackle rising illicit trade

    January 29, 2025 12:00 PM

    Retailers Against Smuggling (RAS) have congratulated the Revenue Commission and Gardaí for their successes in seizing illegal tobacco, but warned that this is just the “tip of the iceberg.”

    The retail group has warned that the increase in seizures is simply a factor of the increase in illegal, non-duty paid tobacco in circulation in the state.

    RAS has now called on the new government to commit to tackling smuggling in Ireland.

    ‘Out Of Control’

    Headline figures released by the Revenue Commissioners show that Irish authorities seized €128 million worth of illegal tobacco in 2024, compared to €63 million in 2023.

    This means that the value of seizures doubled in just one year, based on figures from Revenue’s Headline Results Publications for 2023 and 2024.

    RAS national spokesman Benny Gilsenan, who is also a retailer on Dublin’s northside, said, “€128 million was only the tip of the iceberg.

    “Tobacco smuggling is out of control in Ireland. The country is being engulfed by a tsunami of smuggling.”

    The Revenue Commissioners published a survey in 2023 which found that some 34% of cigarettes in circulation in Ireland were non-duty paid.

    The 2024 seizures data suggests that illegal smuggling is particularly acute in the capital region, with 58% of all seizures in 2024 occurring in Dublin.

    ‘Posing Serious Risk’

    RAS has called for more resources to detect smuggling by organised criminal gangs, but it warned that the focus on large-scale seizures must also be matched by a new drive to tackle widespread non-compliance with duty-free travel allowance.

    A new survey from Ireland Thinks on behalf of RAS found that the proportion of all those purchasing cigarettes who bought them while abroad has increased from 45% to 58% between March and November 2024.

    This indicates a surging trend towards increased import of cigarettes in Ireland.

    Due to a lack of checks and enforcement at Irish ports and airports, passengers can walk through arrivals with thousands of non-paid cigarettes in their luggage.

    They can then illegally sell these smuggled cigarettes on the black market, taking business away from legitimate Irish retainers.

    The Irish exchequer, in turn, misses out on tax revenue.

    RAS have called on the new government to tackle the rising illicit trade in cigarettes, which it says is “posing serious business risks to small Irish retailers, from convenience stores and forecourts to local pharmacies.”

  • Retailer lobby group warns of surge in cigarette and medicine smuggling | The Irish Times

    Retailer lobby group warns of surge in cigarette and medicine smuggling | The Irish Times

    Retailers Against Smuggling calls on incoming government to tackle rising illicit trade

    27 December 2024

    A survey published earlier this year by the Revenue Commissioners found 34 per cent of cigarettes in circulation in Ireland were non-duty paid.


    The number of Irish smokers buying cigarettes from overseas and avoiding taxes as a result climbed significantly over the course of the year, according to a survey conducted by a retail lobby group.

    Some 58 per cent of Irish cigarette smokers bought from abroad in 2024 up 13 per cent since March, according to an Ireland Thinks poll conducted on behalf of Retailers Against Smuggling (RAS).

    The survey also found that 11 per cent of consumers bought medicines or supplements from unofficial or irregular sellers over the past 12 months, up from 7 per cent in March.

    The group called on the incoming government to tackle the rising illicit trade in medicines and cigarettes which it says is “posing serious business risks to small Irish retailers, from convenience stores and forecourts to local pharmacies”.

    It said the poll reinforced “anecdotal feedback from retailers around Ireland who have observed how the circulation of illegal tobacco has surged” this year.

    A separate survey published earlier this year by the Revenue Commissioners found 34 per cent of cigarettes in circulation in Ireland were non-duty paid.

    RAS spokesman Benny Gilsenan said Ireland’s street are “flooded” with tobacco products on which duty was not paid.

    He said the problem “shows no sign of abating” and the incoming government must “commit to taking action against smuggling and the illicit trade” of such products.

    Due to rising tobacco prices, Mr Gilsenan said “it’s no surprise that consumers are turning to the importation of cheaper products from abroad”.

    In addition to the loss to the exchequer, he said the trend of people buying cigarettes in breach of duty-free allowances or medicines from unlicensed sources “poses serious risks to legitimate Irish retailers as well as to consumers who are potentially putting their health at risk”.