Hamilton, ON, May 28, 2020 — The Calgary Herald has published an op-ed, “Let’s prevent another public health disaster in Alberta by protecting youth from vaping products,” submitted by a group of health advocates and medical professionals. The op-ed urges the Government of Alberta to ban flavoured vapour products, ban retail advertising outside of specialty vape shops, require stores to be licensed, and tax vaping products. The Canadian Vaping Association is aligned on many of these points and agrees there is a need to protect youth, however banning flavours and taxing vapour products will have unintended consequences.
The CVA would like to clarify once again the misconception surrounding advertising and enforcement. Advertising does not require further restriction as it is already federally prohibited to advertise outside of age restricted spaces. What is required is consistent enforcement of the existing laws. Alberta vape shops are also federally regulated and are inspected by federal Tobacco Enforcement Officers. The CVA supports the addition of provincial inspections in combination with the existing federal regulation but would like to make it clear that Alberta vape shops are already operating with government oversight.
The idea that flavoured vaping products contribute to youth vaping is a common misconception that has been discredited by the Centers of Disease Control and Prevention (CDC). According to the CDC report “Tobacco Product Use and Associated Factors Among Middle and Highschool Students”, only 22.3 percent of young people indicated that they vape “because e-cigarettes are available in flavours, such as mint, candy, fruit or chocolate.” The most common reason for use among youth was, “I was curious about them.”
After intense criticism that flavours were attracting youth, Juul voluntarily removed flavours from the United States, leaving only tobacco, mint and menthol flavours available. A study by the American Cancer Society published in the American Journal of Public Health has proven that flavours do not impact youth vaping rates. After removing flavours, youth did not quit vaping but instead switched to tobacco, mint or menthol vape products.
While flavours are not the cause of youth uptake, they are a significant factor in what makes vaping more successful than other NRT products. This phenomenon is not unique to vapour products. It is well documented with other nicotine replacement therapy’s (NRT) that flavours reduce cravings and increase success rates. There has been no connection made between flavours and increased abuse potential. According to a study by the Behavioural Pharmacology Research Unit, John Hopkins University School of Medicine, “Both flavors of nicotine gum decreased craving during 2 h of abstinence. These effects were more pronounced in the adult group and mint gum was more effective than original gum. Younger subjects reported fewer withdrawal symptoms and lower ratings for drug effects and flavor. Improved flavor of nicotine gum does not increase abuse liability but may be associated with enhanced craving reduction.”
The rise in youth vaping rates here in Canada directly correlates to the entrance of Big Tobacco vape brands, such as Juul and Vype. With the entrance of tobacco owned vape brands came aggressive advertising campaigns which were not restricted to adult environments, a practise that has since been federally prohibited. Additionally, the products distributed by these brands have nicotine concentrations of 57 – 59 milligrams per millilitre, making them highly addictive, and the devices are very easily concealed. The UK has not seen a rise in youth vaping as a result of the nicotine limit that had been established in the European Union prior to the entrance of tobacco owned high nicotine vape brands; this nicotine limit meant that the high nicotine vape products distributed by companies like Juul and Vype were not available in the UK to entice youth.
While the CVA has always condemned the use of harm reduction products by youth, it is important to mention the study by the CDC, “Youth and Tobacco Use”, which reports that while youth vaping rates have risen there have been dramatic declines in youth smoking rates. Youth vaping rates increased 1.5% from 2011, while youth smoking rates declined 15.8%.
Lastly, it is essential to address the advocate’s call for vapour product taxation. While the op-ed is well intentioned, taxing a harm reduction product is counter productive as it discourages improvements to public health and increases sales of tobacco products, our nations leading cause of death. As the health advocates stated in their submission, tobacco is proven to kill one in two smokers, which is exactly why we must look at the data and enact data driven legislation.
Minnesota conducted a study, “The impact of E-cig taxes on smoking rates: Evidence from Minnesota,” which found that taxing vaping products would lead to an 8.1% increase in tobacco use and a decrease in the use of smoking cessation products of 1.4%. It also found that if vapour products had not been taxed, an additional 32,400 adults would have quit smoking.
Michael Pesko, a health economist and assistant professor at Georgia State University, cited a study by the National Bureau of Economic Research which found that “while cigarette taxes reduce cigarette use and e-cigarette taxes reduce e-cigarette use, they also have important interactions on each other”. He went on to explain, “e-cigarettes and cigarettes are economic substitutes. So, if you raise taxes on one product, you will increase use of the other.”
Pesko and other researchers drew upon sales data from 35,000 retailers across the nation for a seven-year period and concluded that for every 10 percent increase in e-cigarette prices, sales of vaping products dropped 26 percent. At the same time, the researchers concluded that the higher tax on e-cigarettes resulted in an 11 percent increase in sales of traditional cigarettes.
“We estimate that for every one e-cigarette pod no longer purchased as a result of an e-cigarette tax, 6.2 extra packs of cigarettes are purchased instead,” Pesko said. “The public health impact of e-cigarette taxes in this case is likely negative.”
We recommend looking to Ontario as an example of sensible, well advised legislation. The Government of Ontario has restricted both flavours and nicotine concentrations above 20 milligrams per millilitre to specialty vape shops. Thus, in Ontario, high nicotine and flavoured vapour products are only available in age restricted spaces, while adult smokers are still provided access to the products they require to quit combustible tobacco.
The CVA shares the concerns outlined in the op-ed, however it is imperative that they are appropriately addressed. Banning flavours and taxing vapour products have both repeatedly proven to be ineffective and counter productive. Vapour products are harm reduction tools intended for adult smokers. Future legislation must take the health of both current and reformed smokers into account. As there is extensive, conclusive evidence that high nicotine concentrations are the true driver for youth uptake, it is time to stop scapegoating flavours and to instead enact sensible nicotine limits.
Darryl Tempest The Canadian Vaping Association 6472741867 [email protected]