The NNA tells Scotland’s ministers: “The New Nicotine Alliance is a non-profit UK charity representing the interests of current and future consumers of low-risk alternatives to cigarettes such as vaping products, nicotine pouches, smokeless tobacco, and heated tobacco products. We confirm we have no ties to any of the industries involved, and our engagement raises no issues under Article 5.3 of the Framework Convention on Tobacco Control.”
It points out:
- Vaping is much less harmful than smoking and may ultimately prove to have negligible risks. Extensive clinical and biomarker data support this point. We dispute some of the claims about vaping harms made in the consultation document.
- Vaping can be used to quit or displace smoking. Dual-use is often part of a transition from smoking to exclusive vaping. Multiple strands of evidence from RCTs, observational studies, market data, economic experiments and population data support this point.
- Advertising and promotion have several functions – to reach new users, shape the brand preferences of existing users, and create premium brands. In the case of regular vaping, new users are overwhelmingly drawn from the pool of smokers or those who would otherwise progress to smoking. The vast majority of regular vapers at any age are current or former smokers. The public health effect of vaping and its harm reduction impact rely on smokers deciding that vaping is an appealing alternative. Advertising has an important role to play in that. Our concern about the proposed restrictions is because vaping product advertising functions as anti-smoking advertising with the additional benefit of no cost to the public purse.
- All policies face the risk of perverse unintended consequences. In the case of vaping policies, it is easy to see how restrictive policies could lead to less switching from smoking to vaping and, therefore, to more smoking and more harm. The proposed bans amount to regulatory protection of the incumbent cigarette trade and will increase smoking-related harms by inhibiting the development and diffusion of safer alternatives.
- We believe that the public health objectives are best met by controls on the themes and placement of advertising and promotion, not by prohibitions.
The charity goes on to provide a detailed response the opposes the proposal: “The effect of tighter restrictions on marketing will be to protect the incumbent cigarette trade, increase smoking and cause more harm.”
To support the NNA’s work you can sign up as a support for free here, and you can donate directly or use Amazon Smile (Amazon will donate .05% of your eligible purchases to NNA).
Dave Cross
Journalist at POTVDave is a freelance writer; with articles on music, motorbikes, football, pop-science, vaping and tobacco harm reduction in Sounds, Melody Maker, UBG, AWoL, Bike, When Saturday Comes, Vape News Magazine, and syndicated across the Johnston Press group. He was published in an anthology of “Greatest Football Writing”, but still believes this was a mistake. Dave contributes sketches to comedy shows and used to co-host a radio sketch show. He’s worked with numerous start-ups to develop content for their websites.
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