Papers & Letters: 2022

Breaking down the argument that flavour cause teenage vaping

December 2022: Global
Magazine Article
The idea that e-cigarette flavors hook kids is simple, compelling—and false. I take aim at the simplistic (“bullshit”) narrative used to justify flavour bans and provide a longer, more nuanced (“asymmetric”) alternative narrative.

The weakness of New Zealand’s ‘endgame’ modelling

November 2022: New Zealand
Scientific paper
An analytical critique of the modelling of New Zealand’s proposed denicotinisation law:

Why tobacco harm reduction is an opportunity in Chile

November 2022: Chile
A short letter making the case for tobacco harm reduction in Chile.

Tobacco industry transformation and its enemies

October 2022: Global
Magazine Article
The twin strategies of migration away from combustible nicotine products and diversification into new businesses underpin the tobacco industry transformation. Why is there so much opposition?

Tobacco harm reduction policy options for Belgium

October 2022: Belgium
ETHRA wrote to the Belgian government to highlight the important role safer nicotine products can play in its upcoming inter-federal strategy for a smoke-free generation. The letter was co-signed by 19 independent experts in tobacco and nicotine science and policy, including me.

Arguing against the Netherlands’ proposed flavour ban

September 2022: Netherlands
Consultation Response
I responded to the Netherlands’ consultation on flavour bans: my submission [PDF]. The proposed “whitelist” approach to ingredients will amount to an almost complete ban on commercially viable vaping products. It will assist the continued dominance of the cigarette. The impact on public health depends on how current users and future potential users will respond to the measure. The government cannot just assume they will become abstinent. Simply removing one appealing aspect of one product category does not address the deeper drivers of nicotine, tobacco or substance use.

How would a strategy consultant approach tobacco harm reduction

September 2022: Global
Magazine Article
Innovation and creative destruction in the evolving tobacco market will render cigarettes obsolete and end the burden of smoking-related disease—if we let it.

Nicotine and the weirdness of harm

August 2022: Global
Magazine Article
The availability of nicotine with minimal harm justifies a complete rethink of our approach to this legal recreational drug.

A critique of the US FDA approach to regulating tobacco

August 2022: United States
Magazine Article
Persuasion: The F.D.A.’s Misguided War on Vaping. The government is putting stricter restrictions on vaping than on smoking. That’s bad for public health.

Critical comment on New Zealand ‘endgame’ measures

August 2022: New Zealand
Consultation Response
Smokefree Environments and Regulated Products (Smoked Tobacco) Amendment Bill – comment by Clive Bates. I give my views on three central proposals in the Bill.

The case against banning flavours

July 2022: Global
The case against banning flavours in vaping and other smoke-free products. Please see Version 1 of this 4-page briefing as a guide to the main arguments.

Brief supporting Juul’s appeal against FDA denial of its products

July 2022: United States
Legal Filing
Amicus brief filed in the DC Appeals Court in Juul vs FDA case. On 23 June 2022, FDA denied Juul’s applications to market its products in the United States. Juul is challenging this vindictive, arbitrary and capricious decision in court. David Abrams, Scott Ballin, Martin Jarvis, David Sweanor and I filed an amici curiae brief in support of Juul’s motion for a stay pending substantive review on public health grounds.

The case against Ireland’s proposal to ban flavours

July 2022: Ireland
Consultation Response
A letter and briefing opposing a proposal to ban flavours in tobacco and vaping products. Sent to the Health Committee of the House of the Oireachtas (parliament) in Ireland. Letter & briefing: Public Health (Tobacco and Nicotine Inhaling Products) Bill.

What lessons could regulators learn from the United States

June 2022: Global
Magazine Article
What lessons should regulators learn from the United States. In an article for Tobacco Reporter, I suggest six lessons regulators could learn from the approach to tobacco and nicotine taken in the United States. Mostly about what not to do.

Assessment of the European Union regulatory framework

June 2022: European Union
Consultation Response
ETHRA submission to European Union call for evidence. The European Union called for evidence to support its “Evaluation of the legislative framework for tobacco control”. Consultation page here.

The misguided attacks on tobacco industry transformation

May 2022: United States
Magazine Article
Fighting the wrong war. My piece in Tobacco Reporter on the counterproductive conflict between tobacco control and the tobacco industry as (some of) the latter attempts to transition away from combustibles.

Brazil consults on lifting its vape ban

May 2022: Brazil
Consultation Response
Response to ANVISA consultation of lifting the vaping prohibition. Brazil’s public health agency, ANVISA, has been consulting on whether the long-standing policy of prohibition of vaping products should be retained or lifted.

Analysis of the Canadian legislative framework

April 2022: Canada
Consultation Response
Response to Canadian Legislative Review of the Tobacco and Vaping Products Act. Canadian tobacco control legislation requires a periodic review of its relevance and effectiveness – commendable if taken seriously.

Twenty proposals to meet England’s smoke-free 2030 target

March 2022: England
Consultation Response
Submission to Independent Review of Tobacco Policy in England. This is the New Nicotine Alliance submission to the review of England’s tobacco policy conducted by Javed Khan OBE.

Why Scotland would be wrong to ban vape advertising

March 2022: Scotland
Consultation Response
Submission to Scottish Government review of advertising and promotion of safer nicotine products.

The problems of prohibition illustrated by a real world case study

February 2022: Global / Bhutan
Magazine Article
The Evil Twins: prohibition and illicit trade. My piece in Tobacco Reporter explores the different types of prohibition and wants wrong with them – including the all-out tobacco prohibition in Bhutan.

Commentary on a proposal for taxing ENDS

February 2022: South Africa
Consultation Response
Comments on National Treasury discussion paper on ENDS taxation.

Briefing on tobacco harm reduction and tobacco control

February 2022: European Union
European Tobacco Harm Reduction Advocates (ETHRA) briefing for European Commission stakeholder meeting on 10 February.

The arguments against ‘smoke-free generation’

February 2022: Malaysia
A letter describing the real-world weaknesses in the smoke-free generation proposal to the Prime Minister of Malaysia.

The unintended consequences of excessive smoke-free taxation

January 2022: Israel
A letter signed by 14 experts on the folly of raising taxes on vaping products.

Countering false and misleading anti-vaping arguments

January 2022: Ireland
A short set of evidence-based arguments for members to consider in response to a number of misleading and potentially damaging arguments made by abstinence-only campaigners to the committee.
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