Illicit and Non-Compliant Tobacco in Low- and Middle-Income Countries: Unpacking the Extent, Structure, and Regulatory Gaps with a Bangladesh Lens

Introduction
Illicit tobacco trade (ITT) undermines tobacco control by increasing affordability, reducing government revenue, and weakening regulation. Despite bearing a substantial tobacco burden, low- and middle-income countries (LMICs) lack robust evidence on the extent of ITT, particularly for smokeless tobacco (ST). This thesis aimed to assess the extent, structure, and associated factors of ITT and identify strategies for improving tobacco control in Bangladesh and other LMICs.
Methods
Four interrelated studies were conducted using multiple research methods: i) a systematic review and meta-analysis synthesised evidence on the share of illicit tobacco and the methods used in LMICs, ii) a cigarette pack analysis estimated the magnitude, structure and associated factors of illicit cigarette sales in Bangladesh, iii) a cross-country ST pack analysis assessed the extent of illicit ST in Bangladesh, India, and Pakistan, and iv) qualitative interviews with tobacco control stakeholders explored strategies for improving ST regulation and monitoring in Bangladesh.
Results
Illicit smoking tobacco accounted for an estimated 14.4% (95% CI: 10.5–18.9) of tobacco sales and/or consumption in LMICs. Evidence on ST was limited, although available studies suggested a higher illicit share. In Bangladesh, 5.6% (95% CI: 4.3–7.1) of cigarette packs were illicit, mainly due to domestic tax evasion. More than 90% of ST products in Bangladesh and India were non-compliant, while none of the packs in Pakistan complied with WHO FCTC-recommended packaging features. Stakeholders identified market informality, weak enforcement, and limited policy attention as key barriers to effective ST control.
Conclusions
Approximately one in seven smoking tobacco packs in LMICs is potentially illicit. Although the illicit share of ST may be higher, evidence remains limited. In Bangladesh, illicit cigarettes are relatively uncommon, whereas the ST market is dominated by non-compliant and potentially illicit products. Standardised packaging, licensing, and stronger enforcement are needed to improve ST control in Bangladesh.