Numbers Without Methods: Inside Euromonitor’s Uganda Illicit Alcohol Report

The latest addition arrived in May 2025: Understanding the Illicit Alcohol Market – Uganda, a 38-slide Euromonitor presentation commissioned by the Uganda Alcohol Industry Association (UAIA). UAIA is the trade body whose members include Nile Breweries (owned by AB InBev) and Uganda Breweries (owned by Diageo) lobbying on behalf of Big Alcohol.

In this analysis I share insights into what the report actually says about how its headline numbers were produced. The short answer: almost nothing.

Lots of Fine Print, No Essential Information

At first glance, the methodology might look robust. The 38-slide presentation includes definitions tables, abbreviations, a value-chain flowchart, a fiscal loss formula, and an appendix listing secondary sources. The document has the visual signs of careful research.

Looking more closely however, the methodology only consists of five short steps, in Euromonitor’s own description:

• Step 1 – Alignment and desk research: “In-house analysis of legal alcoholic drinks data from Passport. We also reviewed secondary sources, including trade press articles, official national statistics and trade statistics for all alcohol categories.”
• Step 2 – Store visits and local interviews: “Euromonitor collected product information from 50 different outlets across various provinces in Uganda. During store visits, local analysts also engaged in pulse interviews with the local staff to gather local perspectives on the supply of illicit alcohol.”
• Step 3 – In-depth interviews: 15 stakeholders, concentrated in the alcohol industry – nine commercial producers, two industry associations, four government regulators. No independent public health researchers, no academics, no representatives of the rural producer communities whose output, according to the report, makes up most of the illicit market.
• Step 4 – Consumer survey: A 1,004-person online survey, limited to perceptions; respondents were not asked whether they themselves consume illicit alcohol. Many of the respondents are young, urban and educated – not representative of the general Ugandan population.
• Step 5 – Consolidation of results: “Euromonitor compared and cross-checked information collected through different methods to consolidate the key findings into a final report.”

This is the complete methodology. The actual model that turns these inputs into national volume estimates is never described.

This leaves a host of unanswered questions that matter greatly for the subject:

1. The document does not state how total alcohol consumption in Uganda was estimated independently of recorded legal sales.
2. It does not explain how rural household production of waragi, tonto, and malwa was measured.
3. It does not say how counterfeit volumes were separated from legal volumes when refilled bottles, in Euromonitor’s own description, look “exactly like the legal brands.”
4. There are no confidence intervals or error margins on any of the headline numbers, and
5. There is no indication that any independent consumption survey was used as a cross-check.

The headline volume figure for the illicit market – given to the nearest hectolitre – is the output of an undisclosed in-house model, presented as if it were a direct measurement.

The Fiscal Loss Calculation Has a Hidden Assumption

The one place the report shows its working is the fiscal loss formula. Illicit volume per category, multiplied by the excise duty per litre, equals the fiscal loss attributed to that category. The headline fiscal loss figure follows directly.

This formula contains a single, very large assumption that is never stated: every litre of illicit alcohol would, in the absence of illicit supply, have been bought as legal alcohol at the full excise rate. Replace illicit with legal at one-to-one substitution, the formula assumes, and the state collects the missing tax.

The concept the formula assumes away is price elasticity of demand – a foundational element of alcohol policy economics, and one that underpins WHO and World Bank guidance on alcohol taxation. The result is a fiscal loss figure built on a behavioural assumption that the established alcohol economics literature treats as unrealistic.

The fiscal loss headline therefore likely overstates alcohol tax revenue lost. The headline works as a political tool that matches the policy preferences of the report’s commissioning client.

What Independent Research Has Found

The lack of clarity about Euromonitor’s methods has been documented for over a decade in the tobacco control literature.

In 2015, Blecher and colleagues published a research letter in Tobacco Control examining Euromonitor’s data on the illicit cigarette trade. They observed that Euromonitor lists source categories – official statistics, trade associations, trade press, store checks, trade interviews – without specifying how these inputs are combined. They documented unexplained revisions to illicit trade figures between editions, and concluded that independent health survey data are preferable for policy purposes.

Where independent measurement has been carried out on the ground, Euromonitor’s figures have repeatedly been found to be too high. A 2023 BMJ Open study of cigarette retail in Ghana, based on pack analysis at 1,700 retailers, found illicit cigarette levels around 20% – well below Euromonitor’s published estimate. Similar gaps have been documented in Warsaw, Georgia, and Mongolia.

Who Pays the Bills

As Movendi International previously documented, Euromonitor’s own 2018 white paper acknowledged that SAB Miller and AB InBev had commissioned its illicit alcohol research over the previous seven years. The Uganda 2025 report sits in this lineage. UAIA, which commissioned it, is currently chaired by Nile Breweries – AB InBev’s Ugandan subsidiary – having previously been chaired by Diageo’s Uganda Breweries.

The same commercial pattern is also the subject of long-running academic criticism in tobacco control. The University of Bath’s Tobacco Tactics resource, drawing on disclosures from Philip Morris International and Foundation for a Smoke-Free World tax filings, has documented direct tobacco-industry funding of Euromonitor from 2019 onwards. PMI IMPACT, Philip Morris’s illicit trade fund, paid Euromonitor to develop policies to counter illicit trade. The Foundation for a Smoke-Free World – itself a Philip Morris-funded entity – paid Euromonitor approximately USD 3.5 million in 2019, USD 2.3 million in 2021, and USD 1.85 million in 2022. Euromonitor responded that this work was “firewalled” from the rest of the company. But tobacco control researchers have not accepted that claim, since the same analysts produce both the general database and the paid contract work.

What This Means for Ugandan Alcohol Policy

When a Ugandan parliamentarian, journalist, or treasury official receives a citation to “Euromonitor” in support of claims about the size of Uganda’s illicit alcohol market, they are receiving a precise-looking number produced by an undisclosed and flawed in-house model.

The number is supported only by interview inputs gathered from the alcohol industry’s view of its informal competition. It was commissioned by the alcohol industry front group whose members benefit when the illicit market is framed as the central and only problem Uganda needs to address concerning alcohol harm. And it sits inside a body of academic research that has consistently found industry-funded illicit trade estimates overstate the illicit market and distort reality.

Three questions should accompany any Euromonitor illicit trade citation:

• Who funded the research? UAIA, the alcohol-industry trade association.
• Is the methodology disclosed? No – the model that produces the volume figures is not described in the document.
• Can the findings be independently verified? No – the underlying data, sources, and modelling assumptions are not made available.

Until those questions can be answered, the Euromonitor Uganda 2025 figures should be understood as a consultancy product commissioned by an alcohol industry trade association, presented in research format, with the strategic purpose of polluting the policy debate at a moment when evidence-based alcohol policy in Uganda is receiving wide attention because of the country’s heavy and still unmitigated alcohol burden.