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Submission to the Consultation on Reducing Youth Access and Appeal of Vaping Products: Potential Regulatory Measures

Manager, Regulations Division, Tobacco Products Regulatory Office, Tobacco Control Directorate

Controlled Substances and Cannabis Branch

Health Canada

Submitted via E-mail to hc.pregs.sc@canada.ca

Rothmans, Benson & Hedges Inc. (RBH) welcomes the opportunity to respond to the Government of Canada’s consultation on ways to limit the appeal and access of vaping to youth in Canada. 

We are emphatically clear: youth should never use any nicotine-containing product, including vaping. Nicotine is addictive, it is not risk-free, and it poses particular risks for youth. Restrictions to reduce the appeal and access of vaping to Canadian youth are not only appropriate, they are the right thing to do.

So our primary message with respect to the access and appeal of vaping products is simple:

Vaping products should only be for those adult Canadians who are currently smokers and are seeking a better alternative to smoking cigarettes.

We do not, and will not, market or sell our products to youth. RBH’s commercial practices are part of Philip Morris International’s (PMI) global “Good Conversion Practices.” This means our smoke-free products, including vaping or heated tobacco, are intended only for current adult smokers; we never offer our smoke-free products to people who have never smoked or who have quit.

When we do introduce a vaping product into Canada, we will not sell it to youth or non-smokers. 

We recommend the Government of Canada prohibit the sale of vaping products to youth.

Vaping products are not for non-smokers. Vaping products are not for former smokers who have successfully quit. Vaping products are especially not for youth.

Our message to smokers both in Canada, and globally through PMI, is that if you are not a smoker, you should never start using nicotine products. If you are a smoker you should quit nicotine entirely. If you do not quit, you should change to a better alternative.

But smoke-free alternatives such as vaping can and should be available to current adult smokers as a means to switch from cigarettes to better alternatives. 

In Canada, RBH has a product which, although it meets the definition of vaping product according to nearly every province, is considered a tobacco product under the Tobacco and Vaping Products Act because it contains tobacco – as opposed to products which contain nicotine derived from tobacco. As such, RBH does not yet sell a product which would be considered a vaping product in the context of forthcoming regulations. RBH expects to introduce a vaping product into Canada in the future.

Consistent with Health Canada’s goal of realizing the potential of vaping to offer Canada’s existing smokers a less-harmful alternative to continued smoking is the need to find a balance which provides the tools necessary to educate existing smokers about products and, indeed, products which are appealing to smokers but are not appealing to those who do not smoke. 

Finding the right regulatory balance is crucial: too restrictive and current adult smokers will continue to smoke cigarettes; too permissive and non-smokers may become nicotine users.

A balanced approach to regulations recognizes, for example, that some flavours are important for vaping products to facilitate switching existing smokers away from cigarettes. This is particularly important to understand because most vaping products do not have inherent flavour and require the addition of some sort of flavouring agent. 

Flavours that are particularly appealing to youth should be prohibited, but some flavors should be allowed to serve as a practical means to switch adult smokers from cigarettes. Responsible marketing practices for adult consumers should be developed.

The approach with IQOS, the heated tobacco product RBH sells in Canada, has been to attempt to replicate as completely as possible the taste, ritual and experience of smoking a cigarette while drastically reducing the exposure to toxic chemicals linked to diseases associated with smoking, notably lung cancer, cardiovascular diseases, emphysema, and chronic obstructive pulmonary disease (COPD). 

IQOS was authorized for sale in the United States this month by the Food and Drug Administration. 

In replicating this ritual and experience, IQOS has been designed to deliver a comparable amount of nicotine to that of a combustible cigarette, while also producing the taste of tobacco. The goal of this replication is to ease the transition of an existing smoker from cigarettes to this smoke-free alternative.

At RBH, we verify that each adult customer is an existing smoker and refuse to sell IQOS or heatsticks to those who are not. We believe similar restrictions should be made on vaping products. 

RBH supports measures which restrict the sale of vaping products to people who are existing smokers, to ensure that non-smokers – particularly youth – do not become addicted to nicotine.

Nicotine is crucial to the effectiveness of vaping products to be an acceptable alternative to existing smokers. Therefore, alternatives to smoking such as vaping should be able to deliver comparable levels of nicotine as cigarettes to facilitate a switch. 

Variations in product designs can make it challenging to determine how best to make comparisons with nicotine delivery from cigarettes. For example, IQOS works with heatsticks that are designed to deliver about the same amount of nicotine as a cigarette over a comparable amount of time or puffs. However, other types of systems which contain a reservoir of e-substance (either in solid or liquid form) that are used until depleted are harder to quantify in these terms. In considering questions relating to nicotine, Health Canada and others should be guided by science and give equal weight to the need to replicate the experience of a cigarette – and therefore the delivery of nicotine – in consideration of measures to place limitations on nicotine within these products. 

Nicotine content in vaping products should be set so products deliver nicotine in an amount commensurate with cigarettes, to allow them to function as an effective transition away from cigarettes.

Fundamentally, smoke-free alternatives to cigarettes such as vaping or heating should be restricted so as not to appeal or be accessible to youth, never-smokers or non-smokers. At the same time, vaping and heating provide current adult smokers with better nicotine alternatives to cigarettes and as such should not be regulated in the same manner. A pragmatic approach on vaping is needed that protects youth from nicotine addiction yet fosters an environment which enables individual adult smokers who are not yet ready to quit using nicotine to switch to better alternatives. 

RBH is committed to a smoke-free future in Canada where those who do not smoke never start, where those who smoke quit, and where those who do not quit, change. Vaping and heating products can be part of that practical change for existing adult smokers. Along with enabling government regulations, consumer adoption and societal acceptance, RBH is prepared to drive towards ending cigarettes and making Canada smoke-free by 2035.

Thank you for the opportunity to respond to this consultation.