Smuggling

Greece’s Tax Chief, Cigarette Company Team Against Tobacco Smuggling

2 February 2021 The National Herald     [...]

Tobacco Industry Manipulation of Data on and Press Coverage of the Illicit Tobacco Trade in the UK (2014)

Authors: Andy Rowell, Karen Evans-Reeves, and Anna Gilmore Abstract Background: In the UK, transnational tobacco companies (TTCs) have been arguing that levels of illicit trade are high and increasing and will rise further if standardised packaging is implemented. This [...]

Towards a Greater Understanding of the Illicit Tobacco Trade in Europe: A Review of the PMI Funded ‘Project Star’ Report (2013)

Authors: Anna Gilmore et al. Abstract Following a legal agreement with the European Union (EU), Philip Morris International (PMI) commissions a yearly report (‘Project Star’, PS) on the European illicit cigarette trade from KPMG, the global [...]

Public Policy Implications of Tobacco Industry Smuggling Through Native American Reservations into Canada (2008)

Authors: Max H Kelton Jr and  Michael S Givel Abstract From 1980 to 1994, the Canadian government enacted major tax increases on tobacco products. These actions initiated significant tobacco smuggling from the United States into [...]

Protecting Your Country’s Tobacco Track and Trace System From the Tobacco Industry (2019)

Executive Summary The Protocol to Eliminate Illicit Trade in Tobacco Products (ITP) requires a global tobacco tracking and tracing system.1 Packs of cigarettes and rolling tobacco need to be marked with a secure, unique ID [...]

Track and Trace Systems: Tobacco Industry Links (2019)

Read more: Global Center for Good Governance in Tobacco Control (GGTC) [...]

Tobacco Industry’s Elaborate Attempts to Control a Global Track and Trace System and Fundamentally Undermine the Illicit Trade Protocol (2019)

Authors: Anna B Gilmore, Allen W A Gallagher, and Andy Rowell Abstract Background: The Illicit Trade Protocol (ITP) requires a global track and trace (T&T) system to reduce tobacco smuggling. Given the tobacco industry’s (TI) historical [...]

Tobacco Industry Data on Illicit Tobacco Trade: A Systematic Review of Existing Assessments (2019)

Authors: Allen Gallagher, et al. Abstract Objective: To examine the quality of tobacco industry-funded data on the illicit tobacco trade (ITT) through a systematic review of existing assessments of industry-funded data on ITT. Data sources: Papers and [...]

Tobacco Taxation, Illegal Cigarette Supply and Geography (2019)

Author: Dardo Curti et al. Abstract Background: In Uruguay, real tobacco taxes increased significantly during 2005–2010 and 2014–2017 and decreased during 2010–2014. The effects of these tax changes on illegal and legal cigarette usage differed significantly [...]

Memoranda of Understanding: A Tobacco Industry Strategy to Undermine Illicit Tobacco Trade Policies (2019)

Authors: Eric Crosbie, Stella Bialous and Stanton A Glantz Abstract Objective: Analyse the transnational tobacco companies’ (TTCs) memoranda of understanding (MoUs) on illicit trade and how they could undermine the WHO Framework Convention on Tobacco Control [...]

Tobacco Industry’s Elaborate Attempts to Control a Global Track and Trace System and Fundamentally Undermine the Illicit Trade Protocol (2018)

Authors: Anna B Gilmore, Allen W A Gallagher, and Andy Rowell Background: The Illicit Trade Protocol (ITP) requires a global track and trace (T&T) system to reduce tobacco smuggling. Given the tobacco industry’s (TI) historical involvement [...]

Cigarette Smuggling: Using the Shadow Economy or Creating its Own? (2018)

Authors: Rajeev K. Goel and James W. Saunoris  Cigarette smuggling undermines policymakers’ efforts to curb smoking while also leading to tax revenue leakages. Policymakers around the world are trying to obtain a better understanding of [...]

Big Tobacco is consistently overstating black market in cigarettes – new findings

Author: Gallagher, A. and Gilmore, A. What’s the size of the black market in tobacco and who is behind it? These questions have dogged governments, public health advocates, researchers and the tobacco industry for years. [...]

Graduated Sovereignty and Global Governance Gaps: Special Economic Zones and the Illicit Trade in Tobacco Products (2017)

Authors: Chris Holden  Abstract Illicit trade in tobacco products has been a significant problem globally for many years. It allows cigarettes to be sold far below their legal price and thus contributes to higher consumption, morbidity [...]

An analysis of the Australian Illicit Tobacco Market (2017)

Authors: Mark Lauchs and Rebecca Keane  Abstract Purpose: This paper aims to provide an overview of the illicit tobacco market in Australia. It attempts to build a picture of the sources of demand, size of the market and [...]

Commentary on Joossens et al. (2010): Eliminating the Global Illicit Cigarette Trade – What do we really know? (2010) 

Author: Evan Belcher This paper by Joossens, Merriman, Ross & Raw is a timely addition to the public health literature, most notably because of ongoing negotiations on the Illicit Trade Protocol of the Framework Convention [...]

The Protocol to Eliminate Illicit Trade in Tobacco Products is live!

Yesterday, 27 June 2018, the conditions for the entry into force of the first legally binding instrument adopted under the WHO FCTC were met, paving the way to eliminate illicit trade of tobacco products The [...]

“Cigarette Smuggling for Greenhorns”: Recent Patterns of Illegal Tobacco Trade in the Czech Republic (2016)

Authors: Petr Kupka and Kateřina Tvrdá  Abstract One of the countries impacted to a lesser degree by the illegal trade in tobacco products is the Czech Republic. Recently the proportion of counterfeit or smuggled cigarettes [...]

The Illicit Tobacco Market in Sweden – From Smuggling to Warehousing (2016)

Authors: Johanna Skinnari and Lars Korsell  Abstract Research on the illicit tobacco market in Sweden is scarce. Actors in the licit tobacco market have made estimations of the size of its illicit counterpart and claim [...]

Content Analysis of Tobacco Industry Data on the Illicit Tobacco Trade in UK Newspapers During the Standardised Packaging Debate (2016)

Authors: Karen Evans-Reeves et al. Abstract Background: Standardised tobacco packaging, which commenced in the UK in May, 2016, has been vehemently opposed by transnational tobacco companies. Previous research has concluded that companies invoke the existence [...]

The Financial Management of the Illicit Tobacco Trade in the United Kingdom (2016)

Authors: Georgios A. Antonopoulos and Alexandra Hall Over the last two decades official and media discourses have paid increasing attention to the proceeds of ‘organized crime’. However, although there is a relatively sound understanding of [...]

Targeted Enforcement Against Illicit Trade in Tobacco Products (2016)

Authors: James Prieger,  Jonathan D. Kulick, and  Mark A. R. Kleiman Abstract Illicit trade in tobacco is a substantial and growing problem in the U.S., causing loss of tax revenue, damage to public health, and [...]

Smoking Out Illicit Trade: How Some Policies Intended to Limit Smoking Drive Illegal Trade (2016)

Author: Roger Bate Abstract The World Health Organization (WHO) states that smoking cigarettes is the largest cause of preventable premature death globally. The WHO Framework Convention on Tobacco Control (FCTC) entered into force in 2005 [...]

‘Where There’s Smoke, there’s Money’: An Introduction to the Special Issue on ‘the Illicit Tobacco Market’ (2016)

Author: Georgios A. Antonopoulos and Klaus von Lampe  This paper provides an introduction to the special issue of Trends in Organized Crime bringing forward numerous empirical research findings and theoretical accounts on the illicit tobacco market in [...]

Is the Illicit Cigarette Market Really Growing? The Tobacco Industry’s Misleading Math Trick (2016)

Author: Michal Stoklosa The tobacco industry regularly uses the threat of increased illicit cigarette trade to dissuade governments from implementing prohealth policies. Illicit trade is the number one argument used by the tobacco lobby to oppose [...]

Assessment of the European Union’s Illicit Trade Agreements with the Four Major Transnational Tobacco Companies (2016)

Authors: Luk Joossens et al. Abstract To address the illicit cigarette trade, the European Union (EU) has signed agreements with the four major Transnational Tobacco Companies (TTCs) that involve establishing extensive systems of cooperation. All [...]

Content Analysis of Tobacco Industry Data on the Illicit Tobacco Trade in UK Newspapers During the Standardized Packaging Debate (2016)

Authors: Karen Evans-Reeves et al. Abstract Background: Standardised tobacco packaging, which commenced in the UK in May, 2016, has been vehemently opposed by transnational tobacco companies. Previous research has concluded that companies invoke the existence [...]

The Tobacco Industry and the Illicit Trade in Tobacco Products (2016)

I. Introduction The illicit tobacco trade is a global problem that threatens the public health gains of tobacco control and the outcomes of the WHO Framework Convention on Tobacco Control (WHO FCTC). In addition to [...]

Tobacco Tax and the Illicit Trade in Tobacco Products in New Zealand (2015)

Authors: Ali Ajmal and Veng Ian U Abstract Objectives: To estimate the size of illegal tobacco trade and consumption and assess the impact of tobacco tax on the illicit tobacco market in New Zealand (NZ). [...]

Are the Tobacco Industry’s Claims About the Size of the Illicit Cigarette Market Credible? The Case of South Africa (2015)

Authors: Corné van Walbeek and Lerato Shai Abstract Background: The tobacco industry claims that illicit cigarette trade in South Africa is high and rising. This is often used as an argument not to increase the [...]

“It Will Harm Business and Increase Illicit Trade”: An Evaluation of the Relevance, Quality and Transparency of Evidence Submitted by the Tobacco Industry to the UK Consultation on Standardised Packaging 2012 (2015)

Authors: Karen Evans-Reeves et al. Introduction: Transnational tobacco companies (TTCs) submitted evidence to the 2012 UK Consultation on standardised packaging (SP) to argue the policy will have detrimental economic impacts and increase illicit tobacco trade. [...]

Illegal Trade of Tobacco Products: What You Should Know to Stop it (2015)

Overview The illicit trade of tobacco products poses major health, economic and security concerns around the world. It is estimated that one in every 10 cigarettes and tobacco products consumed globally is illicit. It is [...]

Approaches for Controlling Illicit Tobacco Trade — Nine Countries and the European Union (2015)

Authors: Hana Ross et al. An estimated 11.6% of the world cigarette market is illicit, representing more than 650 billion cigarettes a year and $40.5 billion in lost revenue (1). Illicit tobacco trade refers to any [...]

Use of Tobacco Tax Stamps to Prevent and Reduce Illicit Tobacco Trade — United States, 2014 (2015)

Author: Jamie Chriqui Tobacco use is the leading cause of preventable disease and death in the United States (1). Increasing the unit price on tobacco products is the most effective tobacco prevention and control measure [...]

Closing the Door on Illicit Tobacco Trade, Opens the Way to Better Tobacco Control (2015)

Author: Vinayak Prasad et al. This year we are celebrating with the world the 10th anniversary of the entry into force of the World Health Organization Framework Convention on Tobacco Control (WHO FCTC). Parties to [...]

European Watchdog is Failing to Hold Tobacco Industry to Account Over Smuggling (2015)

Author: Martin McKee What are agreements with the industry worth? For over a decade the European Union’s antifraud organisation, OLAF (Office Européen de Lutte Antifraude) has, controversially, engaged with the tobacco industry, ostensibly to counter tobacco [...]

Did the Tobacco Industry Inflate Estimates of Illicit Cigarette Consumption in Asia? (2015)

Author: Jing Chen et al. Abstract Objective: Estimates of illicit cigarette consumption are limited and the data obtained from studies funded by the tobacco industry have a tendency to inflate them. This study aimed to validate an [...]

Measures to Control Illicit Tobacco Trade (2015)

Introduction The tobacco market, like many other markets, is subject to illegal activities, primarily related to tax evasion and counterfeiting of legal products. Since a sizable illicit tobacco market can both deprive governments of much [...]

Controlling Illicit Tobacco Trade: International Experience (2015)

Introduction This report presents a series of case studies on the efforts of various governments to address illicit trade in tobacco. The countries for the case studies were selected based on meeting the following set [...]

A Critique of the ITIC/O Asia-14 Illicit Tobacco Indicator 2013 (2015)

Author: Hana Ross Executive Sumary The “Asia-14 Illicit Tobacco Indicator 2013” (Asia-14) report was published by the International Tax and Investment Center (ITIC) and Oxford Economics (OE) as a follow up to their previous attempt [...]

Contrasting Academic and Tobacco Industry Estimates of Illicit Cigarette Trade: Evidence from Warsaw, Poland (2014)

Authors: Michal Stoklosa and Hana Ross Abstract Objective: To compare two different methods for estimating the size of the illicit cigarette market with each other and to contrast the estimates obtained by these two methods [...]

Tobacco Industry Manipulation of Data on and Press Coverage of the Illicit Tobacco Trade in the UK (2014)

Authors: Amber Rowell et al. Abstract Background: In the UK, transnational tobacco companies (TTCs) have been arguing that levels of illicit trade are high and increasing and will rise further if standardised packaging is implemented. [...]

Countering the Demand for, and Supply of, Illicit Tobacco: An Assessment of the ‘North of England Tackling Illicit Tobacco for Better Health’ Programme (2014)

Authors: Ann McNeill et al. Abstract Background: Illicit tobacco (IT) undermines the effectiveness of tobacco control strategies. We assessed the implementation and impact of a new programme designed to reduce demand for, as well as [...]

The Transnational Tobacco Companies’ Strategy to Promote Codentify, their Inadequate Tracking and Tracing Standard (2014)

Authors:  Luk Joossens and Anna B Gilmore Introduction In 2011 INTERPOL, the world’s largest police organisation, accepted a donation from Philip Morris International (PMI) of €15 million, an 8% increase to its total annual budget (€60 [...]

Cigarette Smuggling and Terrorism Financing (2014)

Authors: Alexandra Hiropolous et al. Read more:  Crime Science Series [...]

The Empirical Analysis of Cigarette Tax Avoidance and Illicit Trade in Vietnam, 1998-2010 (2014)

Authors: Minh Thac Nguyen et al. Abstract  Illicit trade carries the potential to magnify existing tobacco-related health care costs through increased availability of untaxed and inexpensive cigarettes. What is known with respect to the magnitude [...]

Empirical Measurement of Illicit Tobacco Trade in the Philippines (2014)

Authors: Victor Abola et al. Abstract Cigarette smuggling reduces the price of cigarettes, thwarts youth access restrictions, reduces government revenue, and undercuts the ability of taxes to reduce consumption. The tobacco industry often opposes increases to [...]

Towards a Greater Understanding of the Illicit Tobacco Trade in Europe: A Review of the PMI Funded ’Project Star’ Report (2014)

Authors: Anna Gilmore et al. Abstract Background Following a legal agreement with the European Union (EU), Philip Morris International (PMI) commissions a yearly report (‘Project Star’, PS) on the European illicit cigarette trade from KPMG, the [...]

Change in Tobacco Excise Policy in Bulgaria: The Role of Tobacco Industry Lobbying and Smuggling (2014)

Authors: Valeria Skafida et al. Abstract Objectives: To examine how transnational tobacco companies (TTCs) tried to penetrate the Bulgarian cigarette market and influence tobacco excise tax policy after the fall of communism and during Bulgaria’s [...]

Corruption, Greed and Crime-money: Sleaze and Shady Economy in Europe and Beyond (2014)

Land of opportunities: The illicit trade in cigarettes in the United States, p. 267 Authors: Klaus von Lampe, Marin Kurti and John Bae Introduction The illegal cigarette trade is a global phenomenon. The smuggling and [...]

Economics of Tobacco Toolkit, Tool 7: Understand, Measure, and Combat Tobacco Smuggling (2013)

Author: David Merriman The intended purpose of this tool is to let readers gain the necessary knowledge about tobacco smuggling. With this knowledge, policy responses can be developed and further monitored in order to establish their [...]

Price and Tax Measures and Illicit Trade in the Framework Convention on Tobacco Control: What We Know and What Research Is Required (2013)

Author: Corne van Walbeek Abstract Introduction: Article 6 of the Framework Convention on Tobacco Control commits Parties to use tax and price policies to reduce tobacco use, whereas Article 15 commits Parties to implement measures [...]

Smoking Prevalence and Illicit Cigarettes Trade in 18 European Countries (2013)

Authors: Alessandra Lugo, et al.  Abstract In Europe, limited adequate data on tobacco, allowing for between-country comparisons, are available. Moreover, scanty information, other than those provided by the tobacco industry, is available on the quantitative [...]

“Shifting the Stuff Wasn’t Any Bother”: Illicit Enterprise, Tobacco Bootlegging and Deconstructing the British Government’s Cigarette Smuggling Discourse (2013)

Author: Xavier Duncan L’Hoiry Abstract This paper presents the results of interactions/interviews with an active tobacco bootlegger regarding his illicit entrepreneurial activity spanning his illegal career. This narrative is intended to portray a snapshot of [...]

 The WHO Protocol to Eliminate Illicit Trade in Tobacco Products: A Next Step in International Control of Tobacco Products (2013)

Author: Lukasz Gruszczynski  Abstract This report discusses the main provisions of the recently adopted WHO Protocol to Eliminate Illicit Trade in Tobacco Products. While recognizing the remarkable achievement of the global community in its efforts [...]

Strategies to Combat Illicit Tobacco Trade (2012)

Authors: Jess Alderman Introduction Illicit tobacco trade is a significant global problem. Experts estimate that more than 10 percent of cigarettes bought around the world are sold illegally,1 and in the United States alone smuggling costs [...]

Combating Counterfeit Medicines and Illicit Trade in Tobacco Products: Minefields in Global Health Governance (2012)

Author: Jonathan Liberman Abstract This article examines two spheres of global governance in which the World Health Organization (WHO) has sought to exercise international leadership — combating “counterfeit” medicines and illicit trade in tobacco products. [...]

 Tobacco Smuggling: A Review of the Literature (2012)

Author: Xavier Duncan L’Hoiry Read more: European Journal of Crime, Criminal Law and Criminal Justice [...]

Illicit Tobacco Trade Between the United States and Mexico (2012)

Author: John Colledge Abstract Objective: To provide a brief history of the illicit tobacco trade between Mexico and the United States. Materials and Methods: Research included a previously published study: “Cigarette taxes and smuggling: A statistical analysis [...]

 The Linkage Between Tax Burden and Illicit Trade of Excisable products: The Example of Tobacco (2012)

Authors: Adrian Cooper and Daniel Witt Abstract Illicit trade in tobacco is now a global phenomenon. Experience across both advanced and developing economies demonstrates that the key economic drivers influencing the illicit tobacco trade are excessive [...]

Tackling Cigarette Smuggling with Enforcement: Case Studies Reviewing the Experience in Hungary, Romania and the United Kingdom (2012)

Authors: János Nagy Abstract This paper provides an overview of the approaches taken to address cigarette smuggling and focuses on the experiences of Hungary, Romania and the United Kingdom to reduce illicit trade in tobacco [...]

Illicit Trade Protocol: The Weakest Link: Invited Commentary (2012)

Author: Deborah Sy The article ‘From cigarette smuggling to illicit tobacco trade’ exposes the modus operandi in illicit trade that highlights the need for global cooperation in eliminating the illicit trade of tobacco products (see page 230). [...]

‘It Will Harm Business and Increase Illicit Trade’: An Evaluation of the Relevance, Quality and Transparency of Evidence Submitted by Transnational Tobacco Companies to the UK Consultation on Standardised Packaging 2012 (2012)

Authors: Karen Evans-Reeves et al. Abstract Introduction: Transnational tobacco companies (TTCs) submitted evidence to the 2012 UK Consultation on standardised packaging (SP) to argue the policy will have detrimental economic impacts and increase illicit tobacco [...]

Illicit Cigarette Trade in Thailand (2012)

Author: Pirudee Pavananunt Abstract The sale and consumption of illicit tobacco increases consumption, impacts public health, reduces tax revenue and provides an argument against tax increases. Thailand has some of the best tobacco control policies [...]

The Changing Role of China in the Global Illegal Cigarette Trade (2012)

Author: Klaus von Lampe et al. Abstract This study explores the history of the illegal production, distribution, and smuggling of cigarettes in mainland China. Data were obtained from a content analysis of 931 media reports [...]

From Cigarette Smuggling to Illicit Tobacco Trade (2012)

Authors: Luk Joossens and Martin Raw Abstract Background: Tax policy is considered the most effective strategy to reduce tobacco consumption and prevalence. Tax avoidance and tax evasion therefore undermine the effectiveness of tax policies and [...]

Blood Cigarettes: Cigarette Smuggling and War Economies in Central and Eastern Africa (2011)

Authors: Kristof Titeca, Luk Joossens and Martin Raw Abstract Objective: To analyse cigarette smuggling practices in central and eastern Africa. Methods: Primary data were gathered during long-term qualitative field research in which about 400 interviews were [...]

Opportunities and Risks of the Proposed FCTC Protocol on Illicit Trade (2011)

Authors: Jonathan Liberman et al. Abstract Illicit trade in tobacco products presents a threat to public health because it undermines the use of tax and price policies, which are among the most effective mechanisms for reducing [...]

Tobacco Smuggling: Case Study of a Pro‐health Lobbying Initiative (2011)

Author: Lorna Jennings The Irish Cancer Society (ICS) is an organization with significant credibility in the health arena. As the national cancer charity, the Society since its foundation in 1963 has played a key role in [...]

The Illegal Cigarette Trade In: Natarajan M (ed.). International Crime and Justice (2011)

Author: Klaus Von Lampe Read more: Cambridge University Press [...]

Deliverable 5.2: Illicit Tobacco Trade in Europe: Issues and solutions (2011)

Author: Luk Joossens Executive Summary Definitions Tax avoidance refers to legal activities to pay less or no taxes. Tax evasion refers to illegal activities to pay less or no taxes. Smuggling refers to products illegally [...]

Adolescents’ Awareness of, and Involvement with, Illicit Tobacco in the UK (2010)

Authors: Crawford Moodie, Anne Marie Mackintosh and Robert West The trade in illicit tobacco, which includes counterfeiting, bootlegging (small-scale smuggling) and large-scale organised smuggling by criminal gangs, has flourished in the UK and worldwide in the last decade.1 The [...]

Recent Progress in the Development of a Protocol on the Illicit Trade in Tobacco Products (2010)

Author: Neil Boister Read more: Asian Journal of WTO and International Health Law and Policy [...]

The Impact of Eliminating the Global Illicit Cigarette Trade on Health and Revenue (2010)

Author: Luk Joossens et al. Abstract Aims: The purpose of this study was to update global estimates of the illicit cigarette trade, based on recent data, and estimate how many lives could be saved by [...]

A Mountain or a Molehill: Is the Illicit Trade in Cigarettes Undermining Tobacco Control Policy in South Africa? (2010)

Author: Evan Blecher Abstract This study estimates the size of the market for illicit cigarettes in South Africa between 1997 and 2007 in order to consider the impact of the illicit trade in cigarettes on [...]

Problems, Policies and Politics: A Comparative Case Study of Contraband Tobacco From the 1990s to the Present in the Canadian Context (2010)

Authors: Robert Schwartz and Teela Johnson  Abstract Contraband tobacco has been and continues to be a global public health policy concern, with special manifestations in Canada. Over the past 20 years, in two noteworthy instances [...]

Prevalence of Smuggled and Foreign Cigarette use in Tehran, 2009 (2009)

Authors: Gholamreza Heydari et al. Abstract Background: Iran is one of two main target markets for tobacco smuggling in the WHO’s Eastern Mediterranean Region. The Iranian government has a local tobacco monopoly but there is high [...]

Smuggling as the “Key to a Combined Market”: British American Tobacco in Lebanon (2008)

Authors: Rima Nakkash and Kwang Jae Lee Abstract Objectives: To understand the strategy of British American Tobacco (BAT) and other transnational tobacco companies (TTCs) to gain access to the Lebanese market, which has remained relatively [...]

“Key to the Future”: British American Tobacco and Cigarette Smuggling in China (2006)

Authors: Kelley Lee and Jeff Collin Cigarette smuggling is a major public health issue, stimulating increased tobacco consumption and undermining tobacco control measures. China is the ultimate prize among tobacco’s emerging markets, and is also believed [...]

Complicity in Contraband: British American Tobacco and Cigarette Smuggling in Asia (2004)

Authors: J Collin Abstract Objectives: To examine the complicity of British American Tobacco (BAT) in cigarette smuggling in Asia, and to assess the centrality of illicit trade to regional corporate strategy. Methods: Analysis of previously confidential documents from [...]

Preventing Organised Crime: The Case of Contraband Cigarettes

Authors: Klaus von Lampe Read more: Situational Prevention of Organised Crimes [...]

Progress in Combating Cigarette Smuggling: Controlling the Supply Chain (2008)

Authors: Luk Joossens and M Raw Abstract Background: The illicit tobacco trade results in huge losses of revenue to governments, estimated at $US40–50 billion in 2006, and in increased consumption and thus health problems because it [...]