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.
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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Canadian proposed regulatory flavour ban. Chapter 3
Regulatory analysis section - initial notes.
Disclaimer: I have no training in the complexities of modelling. I am certain there will be things I miss. There will also be things I note that later turn out to be inconsequential.
Let's talk about vaping/smoking relative risk statements in Canada. Why they are forbidden. How they were almost permitted and then disappeared, and why I think @PattyHajdu and @GovCanHealth are looking at RR statements from the wrong angle.
A Thread 1/16
May 2018. Tobacco and Vaping Products Act comes into force. Part IV, Div. 2, Sect. 30.43 (1) prohibits cessation claims (in Canada, cessation is considered an intervention). You can't say "quit" and you can't say "stop" with regards to smoking.
2/16
Sect. 30.43 (2) prohibits comparing vaping products and their emissions to smoking products or their emissions. You can't say better, less harmful, fewer toxins, or no smoke.
So Jennifer May, Vice President of Health Promotion & Govt. Relations for @LungSK gave the following OUTSTANDING quote to @ctvsaskatoon regarding vapour products taxation in Saskatchewan... (1/x)
Of course, no one thought to apply the basic principles of math and logic to the statement... so let us do that here shall we? I actually think I can make my point with just one publication from the Daily on the 2020 CTNS data www150.statcan.gc.ca/n1/daily-quoti… (2/x)
Two things to note to get started... 1: Adults aged 25 and up. 854,600 said they had vaped in the last 30 days, 20-24 (legally permitted access) was 309,100 (3/x)
A "Highschool Educated" logical look at Canada's Tobacco Strategy and its target of 5% smoking rates by 2035 (A thread for @PattyHajdu@GovCanHealth and my "new friend" @PamDamoff)