SUBMISSION TO FINANCE CANADA

PROPOSED NEW TAXATION FRAMEWORK FOR VAPOUR PRODUCTS Finance Canada
Email: fin.vaping-taxation-vapotage.fin@canada.ca

SUBMITTED BY RIGHTS4VAPERS JUNE 29, 2021

INTRODUCTION

In its 2021 Budget the Government of Canada proposed a new framework for taxing vaping products.

“The proposed framework would impose a single flat rate duty on every 10 millilitres (ml) of vaping liquid or fraction thereof, within an immediate container (i.e., the container holding the liquid itself). This rate could be in the order of $1.00 per 10 ml or fraction thereof, and the excise duty would be calculated and imposed based on the volume of the smallest immediate container holding the liquid.”

Rights4Vapers is pleased to provide Finance Canada with our views on this proposal.

ABOUT US

Rights4Vapers is Canada’s leading vapour consumer advocacy group. Our organization works to ensure that the option to vape remains available to smokers who choose to make the switch. We represent the vape consumer, 98 per cent of whom are former smokers, and boasts the largest survey data set of Canadian vapers with over 5,000 respondents. We are dedicated to the advancement of Canadian-based research on vaping.

We are an informal collection of committed advocates who believe that vapers and adult smokers deserve a less harmful alternative. We are guided by unpaid academic advisors.

We are a grassroots activist movement. We base our positions on the real-life experiences of adult vapers in Canada.

At the outset, we would like to stress that we do not think that minors should vape. Vaping products contain nicotine, an addictive substance. This being said, there is a question of access. Despite strict federal regulations that govern the sale of vapour products, and in particular the sale of these products to minors, minors are still vaping. The current federal and provincial regulations need to be better enforced.

We are not scientists. However, we follow the science of vaping where it leads. And the science tells us that vaping is less risky than smoking. We believe vapour products are the best and most effective alternative to smoking traditional combustible cigarettes.

In addition, Rights4Vapers reaches out to Canada’s vapers. We have the largest dataset of vaping behaviour in Canada. With over 5,000 respondents, we understand how adult vapers use their products and as a result understand how regulations will impact consumers.

Tens of thousands of Canadian smokers have turned to vaping as a way to reduce the health risks of smoking. Study after study has demonstrated that vaping is less harmful than smoking traditional combustible cigarettes. Public Health England published a paper in 2018 that states “vaping poses only a small fraction of the risks of smoking and switching completely from smoking to vaping conveys substantial health benefits.”1

We are concerned that the increasing number of proposed changes to vaping regulations across the country, particularly those banning flavours and imposing limits to nicotine strength, will deter smokers from choosing vaping as a safer alternative to smoking or push vapers back to smoking.

THE VOICE OF VAPERS

We fundamentally believe that putting more restrictions of vaping products will be detrimental to the health of adult Canadian smokers and to the health of current vapers who may return to smoking if they cannot find a product that meets their needs. This includes affordability.

VAPOUR PRODUCTS WILL SAVE LIVES

At the base of vapour products strategy, the Government of Canada must decide whether it believes that vapour products will save the lives of Canadian smokers. Other more progressive countries, like the United Kingdom, France or New Zealand have decided to put more of the regulatory weight on helping smokers give up the very unhealthy addiction of smoking.

Public health organizations around the world agree that vaping is less harmful than smoking. Vaping products are an alternative that smokers like. We should be making this product as available and as affordable as possible.

THE AFFORDABILITY QUESTION

The Government of Canada proposes that increasing the price of vapour products will reduce their attractiveness to youth. It is not our place to comment on this supposition.

Our opposition to the proposed increase in taxation is based on the premise that vapour products are an effective tobacco harm reduction tool and a proven method to help adult smokers quit smoking, as such they should remain as affordable as possible. Any increase in price closes the gap between vapour products and cigarettes. A cheaper vapour product is much more appealing to an adult smoker than a cigarette – especially to someone who is looking for an alternative to smoking.

If vapour products become unaffordable, smokers will do what they have always done, go to the unregulated black market for their products. Unfortunately, there is no way to make sure that the product consumers buy on the black market are manufactured in a safe and secure way.

TAXATION POLICIES REINFORCE THE STIGMA AROUND VAPING

More and more people think there is no difference between vaping and smoking. Punitive and unnecessary taxation policies further that confusion. When the average Canadian sees that the government is increasing the price of vapour products, they think that the product is bad.

The Angus Reid Institute released survey results on Canadians’ views on vaping. It found that the number of Canadians who believe vaping does more harm than good increased from 35% to 62% over the past year. That’s a doubling in the negative perception of vaping. 2

In addition, the poll indicated that there was strong support for further regulation, with 90% of respondents supporting a ban on advertising of vapour products in areas that young people frequent and 82% supportive of restricting flavoured vapour product sales to adult-only stores. Also, 46% said they would like to see vapour products banned entirely and 60% support a ban on flavoured products. As for usage, 25% of Canadians say they have vaped, up from 18% a year ago. Meanwhile, 17% of parents with children under 19 are aware of their children vaping.

Canadians don’t realize that their views are sentencing vapers and smokers to death and illness.

The latest Public Health England study also noted a trend towards people thinking vaping and smoking are more similar in terms of risks. “Increasingly incorrect perceptions among the public about the harms of vaping could prevent some smokers using vaping products to quit smoking,” the report said. The proportion [of smokers] who thought vaping was less harmful than cigarettes declined from 45 percent in 2014 to 34 percent in 2019.

Vapers themselves are feeling a stigma, which is profoundly unfair since we have made a healthier choice by switching to vaping a recognized less harmful alternative.

OUR POSITION

We speak for Canada’s adult vapers. We believe that vapour products should be available and affordable to any adult who is looking now or in the future for a less risky alternative to smoking. As such, we oppose any increase in taxation.

CONCLUSION

Vaping is an important part of Canada’s tobacco harm reduction agenda. Health Canada has stated that “if you are a smoker, vaping is a less harmful option than smoking.”

We believe that children should not vape. The problem is that youth are getting access to vaping products from friends and family. We need effective education and enforcement programs, not barriers that limit the choice of vaping products to adult smokers.

Vapers need to be confident that the product they are using complies with the highest product standards. The proliferation of black-market devices that can be tampered with is a growing concern. Just like with any other consumer good, e-cigarettes should adhere to safety and quality standards.

Finally, adult smokers need to know the facts about vaping. They need to know that vaping is less harmful than smoking. They need to know the science behind it. They need to know their options and how to use them.

We would welcome the opportunity to publicly present our positions. We trust that any changes to Canada’s federal excise framework take into consideration the many thousands of adult smokers who have chosen vaping as a way to quit smoking and reduce their risk of the health problems caused by smoking.

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1 https://www.gov.uk/government/news/phe-publishes-independent-expert-e-cigarettes-evidence-review

2 https://angusreid.org/vaping-trends-canada/