Comments on the Tobacco and Vapes Bill – New Nicotine Alliance

A submission to the Parliamentary Bill Committee scrutinising the new legislation – The Tobacco and Vapes Bill– consumer group comments by the New Nicotine Alliance. The overview is reproduced below.

  1. Overview
  • In short, the Bill’s flagship anti-smoking measure hits the wrong target group with an ineffective policy. The Bill’s anti-vaping measures will cause more harm than good to the critical group for public health: current adult smokers. Neither measure will do much to reduce youth smoking or vaping. 
  • The Smokefree generation targets a largely irrelevant population of smokers. The Bill’s flagship measure, the Smokefree Generation, addresses a problem already solved mainly by smoke-free alternatives, such as vapes and pouches. That is because youth smoking is already in steep decline, and younger adult smokers will migrate to vaping (etc.) well before they have been smoking long enough to suffer significant smoking-related disease. Without the measure, few people it affects are unlikely ever to suffer the main consequences of smoking because few people born after 2008 will still be smoking by 2050.
  • The critical at-risk population is the existing adult smokers. The most important population from a public health point of view is the stock of 6.3 million adult smokers who are already over 18. This group is at far more imminent risk of serious harm. The Smokefree Generation does not affect them. Yet, for many in this group, it is the opportunity to switch from smoking to vaping or other smoke-free alternatives that will have the most significant impact on public health and health inequalities.
  • The anti-vaping measures will harm the main at-risk population. The problem with the anti-vaping elements of the Bill and the government’s tax policy is that it will negatively affect the critical at-risk population (principally middle-aged adult smokers in poorer communities) through the government’s anti-vaping measures, which will make switching from smoking to vaping more expensive, more difficult, and less appealing.
  • The Bill’s impact is extremely sensitive to unintended consequences arising from the anti-vaping measures. The Bill’s Impact Assessment did not attempt to quantify these adverse effects, so they do not appear in the headline claims for its cost-effectiveness. Yet a failure to quantify does not make them zero. However, the Bill’s cost-benefit case is extremely sensitive to small increases in smoking arising from the anti-vaping measures. Using the methodology of the Impact Assessment, we estimate a slight change in adult smoking prevalence from 12.9% to 13.0% arising from anti-vaping measures would have a monetised health and welfare cost of £3.5 billion – enough to outweigh any conceivable benefits.
  • Youth anti-vaping measures are possible. It is important to remember that the market for tobacco and nicotine products is dominated by adults compared to youth, in a ratio of approximately 16:1. Even in the market for disposable vapes, there are nine times as many adult users as youth, drawing on the most recent data available.  Nevertheless, youth vaping is a politically emotive subject, even if the health risks to youth are low and distant.  Three main strategies should be adopted to address youth vaping:
  1. Lawful supply. If the market does not meet the needs of adult consumers, it will become more saturated with illicit goods and workarounds. The criminal networks involved will supply a wide range of illegal products, engage young people in supply, and not observe any rules regarding age or responsible corporate behaviour. It is essential to design the legislation in a way that does not expand a lawless market. In our view, the Bill will likely expand illicit trade, and this risk should be a focus of the Committee’s scrutiny.
  2. Age-secure retailing.  It should be much harder for underage users to buy tobacco or vapes, and the consequences for retailers should be more serious.  The Bill is a missed opportunity to introduce a licensing scheme that would improve retaining behaviours in several ways. A more measured approach to age restrictions would be to increase the age of sale for combustible tobacco products to twenty-one instead of creating age stratification among adults.
  3. Responsible marketing. Here, it is essential to balance the need to communicate with and engage smokers in switching to new and unfamiliar products with an effort to prevent marketing targeted at youth. The Committee on Advertising Practice has managed such a balancing act for advertising. The same concepts could be applied to branding, trademarks, and flavour descriptors.

See also my blog: The Tobacco and Vapes Bill: A Misfire and a Backfire

1 thought on “Comments on the Tobacco and Vapes Bill – New Nicotine Alliance”

  1. Robert Harvey

    won’t just effect ‘principally middle-aged adult smokers in poorer communities’, i don’t think you would class my community as a poorer community, having said that i have always worked for minimum wage & will be retiring in a couple of months.
    being a very heavy smoker have always needed the strongest 18mg liquids using 10ml daily bought the lowest cost £1 to keep my outlay at about £30 a month as money is tight on my low income but when i retire i will only have state pension to live on & when the £1 liquid i use goes up to £4 for 10ml that would push my £30 costs up to £120, far too steep for my pocket & don’t expect illicit market if there is one will help any here.
    just don’t know what to do here, certainly can’t afford to smoke either.

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