Canadian Flavour Restrictions -initial thoughts and opinions
Chapter 2: Instrument choice
Or
The Nuclear option is the ONLY option.
Option 1:
Status Quo
My opinion.
Adult Consumer Access maintained.
Legitimate Industry Impact unchanged.
Black Market Impact unchanged.
Youth Access unchanged
HC Opinion
Not acceptable.
Option 2: Add “Fruit” flavours to prohibited category promotion list.
My Opinion:
ACA: Maintained - transfer of information impact
LII: Reconfigure labels and promotion 80% stock - SURVIVABLE
BMI: unchanged
YA: unchanged except in regards to curiosity on random encounters with product in environment.
HC opinion:
Not Acceptable.
Option 3: Add “All Flavours Except Tobacco” to prohibited category promotion list.
My Opinion:
ACA: Maintained - larger transfer of information impact
LII: Reconfigure labels and promotion 95% stock - SURVIVABLE
BMI: unchanged/small boost due to LII
YA: unchanged except in regards to curiosity on random encounters with product in environment.
HC Opinion: would remove promotion of mint/menthol - unfair to vapers/smokers
“Look at us! We care about adult users!”
Option 4: Prohibit promotion of all flavours except “Tobacco, Mint, and Menthol”. Prescribe standards to ensure that sensory attributes are limited to “Regulator’s perception” of tobacco, mint, and menthol.
My Opinion:
ACA: Negative impact. De facto flavour ban through sensory attributes.
LII: Reconfigure or remove 85% existing product from market. Survival unlikely.
BMI: Pretty decent growth
YA: Increased due to Black Market growth
HC opinion: “We demonstrated care for adult smokers and vapers in option 3. Why are you still here?”
Rejected.
Option 5. Ban all flavours except tobacco, mint, and menthol. Within tobacco mint and menthol severely restrict compounds that can be used to make those flavours. Sweeteners are out. Subjective sensory attribute standard applies.
My Opinion:
ACA: massive Negative impact. Only option outside of Tob. Mint/menthol is adulteration or black market
LII: Survival unlikely.
BMI: Explosive Growth
YA: Increased due to Black Market growth. Black market doesn’t do ID checks.
HC opinion: “Good job everybody. See you next week when we meet with treasury and try to figure out how to apply an excise tax to product being sold out of a van down by the river. I’m buying the first round at the pub tonight!”
Next up... cost-benefit analysis...
...and that is where things get really disturbing.
Please stand by.
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