Fontem Ventures submits its views on e-cigarette regulation to the Norwegian Government

Amsterdam, 20 January 2016 – Fontem Ventures this week submitted its response to the Norwegian Ministry of Health and Care Service’s consultation on the implementation of the EU Tobacco Products Directive.

We believe Norwegian authorities should embody a regulatory approach aimed at preventing uptake of e-cigarettes by under 18s while encouraging tobacco smokers to shift to e-cigarettes that meet high quality and manufacturing standards.

Distinguishing between vaping products and conventional tobacco

Misinterpretation of up-to-date science leads many authorities to propose treating e-cigarettes in the same way as conventional tobacco products. This is a mistake. From the outset, all regulatory proposals must take into account the clear and fundamental differences between e-cigarettes and tobacco products. That is, the very clear fact that e-cigarettes do not contain tobacco.

Restricting access to under-18s

Fontem Ventures fully supports legislation that restricts the access of e-cigarettes among children and young people, and welcomes the fact that the sale of e-cigarettes to under-18s will be banned in Norway. In addition, our marketing standard ensures that our advertising is of minimal attraction to under-18s, and we clearly mark on our products’ packaging that they should not be sold to this age group. This is a stance shared by all responsible manufacturers.

The facts about ‘gateway’ and ‘renormalisation’

There is no credible scientific evidence that show e-cigarettes are undermining the long-term decline in tobacco smoking among adults and youth; they may in fact be contributing to it.

An estimated 2.6 million adults in the UK currently use e-cigarettes with 60% current smokers and 40% ex-smokers. Despite some very limited experimentation among never smokers, regular use among never smokers is extremely rare and estimated around 0.2%. Interestingly, a recent scientific study by academics at the University of Cardiff studying e-cigarette use in young people in Wales (funded by the Welsh Government’s Public Health Division) concluded that: “the very low prevalence of regular use […] suggests that e-cigarettes were unlikely to be making a significant direct contribution to adolescent nicotine addiction”. This is further evidence that suggests e-cigarettes are not renormalising the act of smoking or serving as a “gateway” to traditional tobacco products, particularly among youngsters.

Moreover, the use of e-cigarettes is likely to contribute further to the de-normalisation of smoking by reducing the number of smoking role models, reducing frequency of public smoking and by providing a role model for the rejection of smoking. For that reason, e-cigarettes are likely to act as a gateway out of tobacco use. As e-cigarettes are not a gateway to smoking but a gateway from smoking, heavy regulation by restricting access to e-cigarettes risks encouraging continued use of tobacco smoking.

Vaping in public places

E-cigarettes do not contain tobacco, do not burn, and do not smoulder unlike tobacco products. As a result, bystanders may only be exposed to aerosol exhaled by the consumer into the air but not to smoke. Numerous reviews of the scientific literature, including the Public Health England 2015 report, have concluded that exposure to nicotine and other chemicals that may be present in exhaled e-cigarette aerosol is negligible, below indoor air quality standards, with all chemical analyses to date indicating exhaled e-cigarettes aerosol does not warrant a concern to bystanders. Moreover, a recent study demonstrated that following a single puff on an e-cigarette, up to 99% of the nicotine inhaled is retained by the e-cigarette user and thus the nicotine concentration exhaled (to which a bystander may be exposed to) is negligible.

To read the full consultation paper, including all references and our views on other related issues please click here.

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