I have written to Ya’ara Saks, Canada’s Minister of Mental Health and Addictions, arguing against a resurgent interest in banning vape flavours.
The letter in PDF form is here: Banning flavoured vaping products – likely to do more harm than good
Covering email and summary
Dear Minister Saks
I have attached a letter regarding the proposed ban on flavoured vaping products, which appears close to a decision.
I am a long-standing UK-based public health advocate with a positive approach to the potential of tobacco harm reduction to substantially reduce the burden of disease and death caused by smoking.
I would like to recommend that you do not proceed with such a ban. The letter argues that any benefits are likely to be heavily outweighed by unintended consequences through additional smoking, illicit trade and risky workarounds. I highlight a significant flaw in the original 2021 analysis supporting the flavour ban policy. The analysis assumed a gateway effect from vaping to smoking and that reductions in vaping would also reduce smoking. The opposite is much more likely.
I recommend commissioning a detailed and neutral regulatory impact assessment. Should you still wish to proceed, I recommend focussing any policies on flavoured vapes to restrictions on flavour descriptors and child-appealing branding, not on ingredients or categories of sensory characteristics.
I have no relevant conflicts of interest, and no issues arise concerning Article 5.3 of the Framework Convention on Tobacco Control.