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Tobacco Control Directorate Health Canada AL 0301A, 150 Tunney's Pasture Driveway Ottawa, Ontario K1A 0K9

Re: RBH Submission to the Health Canada’s Notice of Intent - Potential Measures to Reduce the Impact of Vaping Products Advertising on Youth and Non-users of Tobacco Products

Rothmans, Benson & Hedges Inc. (RBH) welcomes the opportunity to provide its comments on Health Canada’s potential measures to reduce the impact of vaping products advertising on youth and non-users of tobacco products.

Canada has been a worldwide leader in tobacco control for decades, and has continued to show its leadership by recognizing the role of product innovation and tobacco harm reduction in its ongoing efforts to reduce smoking.1 RBH supports Health Canada’s approach to the regulation of vaping products in a manner that ensures that youth and non-tobacco users are protected. Specifically, RBH supports restrictions on both the placement and content of advertising of vaping products, as well as retail promotions for vaping, to keep these products out of the minds and hands of youth. Vaping should never be advertised or promoted to youth. It should be responsibly regulated, marketed and sold only in a manner that would provide an alternative to cigarettes for current adult smokers. We appreciate that Health Canada is regulating vaping products different from combustible products.

Consequently, Health Canada has an opportunity here both to restrict the promotion of vaping to youth and non-tobacco users while at the same time making it clearer for adult tobacco users that vaping, and other innovative tobacco alternatives, could represent a better choice for today’s smokers. A complete ban on advertising and promotion of vaping may miss an opportunity to improve the health of thousands of Canadians who might otherwise continue to smoke cigarettes.

In striking the right balance between protecting youth and non-tobacco users and providing readily available and accurate information to smokers about less harmful alternatives, Health Canada should continue to be guided by the continuum of risk and the existing scientific evidence regarding the risks specific to each type of tobacco and nicotine-containing product.

RBH looks forward to providing more fulsome comments once Health Canada published draft regulations in Canada Gazette Part 1.

Sincerely,

Peter Luongo
Managing Director