1  Removing tobacco from display will mean removing prices from display too. Trading standards officers have a statutory duty to enforce the Consumer Protection Act and the Prices Act (in England and Wales), which ensure clear pricing for shoppers. If traders can face a jail term for selling bananas in pounds and ounces, why is it OK to conceal prices in the highest-value consumer goods category? A display ban is also anti-competitive, and will make it virtually impossible for new brands or formats to enter the market. Leading brands will dominate and innovation in the sector will be stifled.

2 If the government really believes that the display ban will prevent smoking deaths, why are they not offering to fund it? According to Johnson, refitting each store could cost as little as £550, although the ACS estimates that the real cost is more like £5,000 per store. Even using the larger figure, the necessary refurbishment work would cost £250m, which is less than 4% of the £7bn the government receives in tobacco taxes each year. In other words, roughly 13 days tax take from tobacco would be enough to re-fit the entire c-store industry.

3  And, by the same token, if the government really believes that banning displays will prevent smoking deaths, why are they postponing it until 2013?

4  The consultation process failed to give appropriate weight to each submission. Each postcard or letter was counted as one response, regardless of how many people it represented. For example, the 49,507 pro forma responses sent in by Smokefree North West were all counted individually, while the detailed submission sent in by ACS, which represents 33,000 stores, was counted as just one.

5  Despite frequently being pressed, the government continues to refuse to outlaw proxy purchasing of tobacco. So it remains perfectly legal for an adult to buy cigarettes on behalf of a child.

6  Forcing tobacco products under the counter removes the distinction between legitimate and illegitimate stock, giving criminals greater opportunity to sell on counterfeit, smuggled or stolen tobacco products. An estimated 27% of the cigarettes smoked in the UK are currently non duty paid.

7  Alan Johnson's statement talks about "enticing, multi-coloured", packaging for tobacco, ignoring the fact that the most visible thing about a cigarette pack is the large health warning, which occupies 30% of the front. New pictorial health warnings are currently being rolled-out featuring graphic images of corpses and diseased organs, so why are these not being given a chance to make a difference before deciding about a ban?

8  Johnson's statement also says that youth smoking prevalence in Canada has fallen from 29% in 2002 to 19% in 2007 because of the display ban. But during this period, the restriction was not in place in the most populated parts of Canada. The first province to introduce the ban, Saskatchewan, saw an increase in smoking prevalence from 21% in 2002 to 24% in 2003 during the first 19 months after introduction. Tobacco sales volumes have remained steady in the four years since.

9  Youth smoking rates are already falling in the UK without a display ban. The latest figures shows that youth smoking prevalence has fallen, for the first time in five years, to 6%. According to Home Office statistics, Class A drug use among young people stands at 8% and has not declined for a decade. None of these drugs, of course, are on open display in retail outlets.

10  The operational difficulties and security risks inherent with forcing tobacco under the counter will impact on customer service and make retailers of all sizes less efficient. These increased costs, if they can be passed on at all, will be paid by all customers, not just smokers. Outlets that are essential but already under pressure, such as post offices, may be forced to close. By rejecting other means to control smoking (such as a clampdown on the illicit market, enhanced social education programmes and a ban on proxy purchasing) but forcing through a display ban, the government is effectively saying that it believes the main cause of youth smoking is the local shopkeeper.