To analyse the political strategies employed by tobacco industry representatives to exploit their statutory position on the Tobacco Market Commission’s (TMC) Advisory Council (AC) to influence Spain’s tobacco control policies between 2023 and 2024.
A qualitative document analysis was conducted on all 22 official AC meeting minutes (January 2023–December 2024) obtained through a transparency request. From these records, 29 written statements by industry members were selected and systematically coded to identify political strategies of interference, guided by the Policy Dystopia Model.
Of the 29 statements analysed, most originated from the tobacco manufacturers’ association Asociación Empresarial del Tabaco. The most frequent strategy was obstructing or delaying policy implementation, particularly regarding plain packaging (14 statements). Other tactics included managing unfavourable information (seven statements), asserting a right to participate in policy discussions (five statements) and making veiled threats of legal action against proposed regulations (two statements).
The tobacco industry exploited its institutionalised role on the AC as a ‘Trojan horse’ to actively subvert public health policies, contravening Spain’s obligations under WHO Framework Convention on Tobacco Control Article 5.3. This legally sanctioned position creates a clear channel for policy interference. Urgent reforms are necessary to insulate public health policymaking from the vested commercial interests of the tobacco industry.