Media

Tobacco Control Directorate

Re: RBH Submission to the Consultation on New Health Related Labelling for Tobacco Products (General Comments)

Rothmans, Benson & Hedges Inc. (RBH) welcomes the opportunity to provide its comments on Health Canada's consultation regarding New Health Related Labelling for Tobacco Products.

Canada has been a worldwide leader in tobacco control for decades, and has reinforced that leadership role in recent years by recognizing the role of product innovation and tobacco harm reduction in its ongoing efforts to reduce smoking.1 As discussed in its recent submissions on proposed plain packaging measures and proposed statements for use in the promotion of vaping products, RBH welcomes and supports Health Canada's pursuit of regulatory policies that aim to regulate tobacco and nicotine products based on the continuum of risk.

The current proposal to update tobacco product labels is an important opportunity for Health Canada to further refine the regulatory framework for tobacco and nicotine products to ensure that adult smokers who do not quit smoking have access to and information about less harmful alternatives. This is particularly critical for innovative non-combustible tobacco products such as heated tobacco products. A compelling body of evidence supports the conclusion that switching to heated tobacco products presents less risk of harm than continuing to smoke,2 yet the current regulatory framework in Canada prevents adult smokers from understanding the risks of these products compared to continued smoking. Updated tobacco product labelling regulations could prevent further consumer confusion and misinformation by ensuring that all consumers, and particularly smokers, receive truthful, accurate and non-misleading information about the risks of different tobacco products, including how they compare to smoking, the most harmful form of tobacco consumption.

ABOUT RBH

RBH and other members of the Philip Morris International family of companies (PMI), are pursuing a business strategy that envisions a future where we stop selling cigarettes. To that end, PMI is dedicating itself to developing, scientifically assessing, and commercializing, a range of non-combustible alternatives to which adult smokers will switch completely.3 IQOS is the first in this series of innovative non-combustible products developed by PMI. It is a tobacco heating system comprised of the IQOS device and specially-designed tobacco heatsticks that RBH markets in Canada under the name HEETS. RBH began selling IQOS in Canada in December 2016. To date, thousands of adult smokers in Canada have switched to IQOS, and worldwide almost six million smokers have switched to IQOS.

NOT ALL TOBACCO PRODUCTS ARE THE SAME

Tobacco and nicotine-containing products are addictive and not risk-free. Yet, not all tobacco and nicotine-containing products present the same level or types of risk. Rather, there is uniform agreement among scientists and policy makers that tobacco and nicotine-containing products sit on a continuum of risk. Cigarettes and other combustible products are the most harmful because they bum tobacco and generate smoke. As Health Canada explains in its website for consumers: "Many of the toxic and cancer-causing chemicals in tobacco and the tobacco smoke form when tobacco is bummed."4 This is consistent with the conclusions of other regulators, including the U.S. FDA, which has concluded that "[c]igarettes are the tobacco product category that causes the greatest burden of harm to public health as a result of the prevalence of cigarette use and the toxicity and addictiveness of these products."⁵

In contrast, innovative non-combustible products such as heated tobacco products and e-cigarettes do not bum tobacco or generate smoke, and therefore are much less harmful than continued smoking, even if they contain tobacco. As Professor Abrams and colleagues note, "[a] diverse class of alternative nicotine delivery systems (ANDS) has recently been developed that do not combust tobacco and are substantially less harmful than cigarettes."6 These alternatives "have the potential to disrupt the 120-year dominance of the cigarette" and "may provide a means to compete with, and even replace, combusted cigarette use, saving more lives more rapidly than previously possible."⁷