Philip Morris GmbH v. Land of Bavaria

Philip Morris International’s German subsidiary appealed a city authority's decision to ban the tobacco company’s “Don’t Be a Maybe - Be Marlboro" advertising campaign launched in Germany in 2011. The tobacco advertising contained six different forms of a theme - the words “Maybe” or “Be” and short phrases containing these words, coupled with images of young people engaging in daring and rebellious activities.  The administrative court upheld the ban and found that the Marlboro campaign encouraged teenagers as young as 14 years of age to smoke in violation of Germany’s tobacco advertising laws. Additionally, the administrative court found that the campaign created an unfair advantage for Philip Morris International as compared to tobacco companies that abided by the advertising regulations. In its decision, the administrative court stated “the advertising specifically targets risk-taking, rebellious youths” and found that Philip Morris International’s argument that the purpose of "Be Marlboro" advertising was to encourage adult smokers to switch to Marlboro cigarettes was not credible based on the fact that “there is already a high degree of brand loyalty in this group of persons.”

Philip Morris GmbH v. Land of Bavaria, M 18 S 13.4834 (2013)

  • Germany
  • Dec 11, 2013
  • Bavarian Administrative Court in Munich
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Parties

Plaintiff Philip Morris GmbH

Defendant Land of Bavaria

Legislation Cited

Tobacco Product Ordinance of November 20, 2002

Public Health Service and Consumer Protection Act

Related Documents

Type of Litigation

Tobacco Control Topics

Substantive Issues

Type of Tobacco Product

None

"The group of youths is heterogeneous and the advertising specifically targets risk-taking, rebellious youths. Even youths who are already smokers must still be protected. The statement by the Applicant that the purpose of her advertising is to encourage adult smokers to switch to the Marlboro brand is not credible since there is already a high degree of brand loyalty in this group of persons. The Applicant’s argument implies that it is no longer possible to exercise an enforcement of the law. The motifs of the campaign are to be seen in the context of the entire campaign. Advertising for tobacco products is prohibited in general or in isolated cases if it is especially suitable for encouraging youths and adolescents to smoke. Prohibition of the terms “MAYBE” and “BE” is legitimate since these words appeared on all advertising mediums. Without the ban, additional illegal variations of the campaign would be possible. The Applicant could also not disapprove of the continuation of the campaign. Discretion has been appropriately exercised. It no longer depends on the assessment of individual motifs since the entire campaign has been evaluated as illegal. The Respondent was in contact with the Applicant in order to discuss the respective stage of the proceedings and the legal concept. Consent was not given on the part of the Respondent with regard to the procedure under inclusion of the German Agency to Combat Unfair Competition. The order under Cl. 1b) is also given since it is clearly recognizable that the order refers to all of the motifs within the scope of the motifs used. Public interest is given through the top-priority of the protection of youths and adolescents. On the other hand, the right of the Applicant to the freedom of expression is not affected since it only affects her during the distribution of her goods. The freedom to practice a profession can also be restricted by a law. The Applicant can advertise through another campaign. Furthermore, the interests of the Applicant are only of an economic nature. Since October, the Applicant has also been using other posters. In as much as the Applicant contests the long wait for a decision by the Respondent; he apparently was checking the legal position with regard to the effects in an intensive and time-consuming manner."