Q9 Are there any other comments you would like to make? In general I feel that the proposal in its entirety is well thought out and backed with evidence. I do have some concern about some statements meant to appease opponents that are simply fear of things that “may happen”, which is irrational hand-waving when unaccompanied by evidence. You can make an infinite number of arguments against something based on fear, society would ground to a halt if we were to try to accommodate every potential one. Additional information on sales and use Q10 Can you assist us by providing information on the sale of ecigarettes in New Zealand (for example, size of or range of products for sale on the local market)? In large centres generally as good as that available via overseas Internet retailers. Q11 Would the Ministry of Health’s proposed amendments have any impact on your business? If so, please quantify/explain that impact. No Q12 If you are using nicotine ecigarettes: how long have you been using them, how often do you use them, how much do you spend on them per week and where do you buy them? How long have you been using them? How often do you use them? How much do you spend on them per week? Where do you buy them? 3 years daily $5-10 internet
Prohibition on free distribution and awards associated with sales Prohibition on discounting Prohibition on advertising and sponsorship It should not be allowed to be advertised (in the same way as tobacco products). However, it would be impracticable and overly bureaucratic to prevent retailers from displaying, or representing their product in store and online. Requirement for standardised packaging There needs to be a standardised label that describes nicotine levels in the However any other standardisation should not be required. ‘Branding’ should be allowed. Q7 Do you think it is important for legislation to impose some form of excise or excise-equivalent duty on nicotine e-liquid, as it does on tobacco products? Yes No Reasons/additional comments: Whilst providing an excellent nicotine replacement and reduction regime, e-liquid and represent an incredibly economical option for users in wanting to give up tobacco products and are part of an important pathway ongoing for those in smoking cessation. By imposing excise (aside from standard GST) would likely make e-smoking a less attractive solution (cost-wise) and may well result in tobacco smokers deciding not to ‘switch’. A critical incentive (for me, as a heavy tobacco smoker of 30 years) was the cost benefits…over time I was able to sensibly reduce nicotine levels using e-cigarette regime from 2.4 to 1.8 to 1.2 to 0.6 and within a year had titrated to negligible nicotine consumption. Savings of over $100 per week were a critical incentive. I would caution around the highly negative impacts of turning this into a ‘tax-take’ (as would be seen by consumers at least). Q8 Do you quality control of and safety standards for ecigarettes are needed? Yes No Additional comments: Area of concern Yes No Reasons/additional comments Childproof containers Safe disposal of ecigarette devices and liquids cigarettes
Policy Options for the Regulation of Electronic Cigarettes Consultation submission 71 Your details This submission was completed by: (name) [redacted] Address: (street/box number) [redacted] (town/city) [redacted] Email: [redacted] Organisation (if applicable): Richmond Discount Ltd Position (if applicable): [redacted] (Tick one box only in this section) Are you submitting this: as an individual or individuals (not on behalf of an organisation)? on behalf of a group, organisation(s) or business? (You may tick more than one box in this section) Please indicate which sector(s) your submission represents: Commercial interests, including ecigarette manufacturer, importer, distributor and/or retailer Tobacco control non-government organisation Academic/research Cessation support service provider Health professional provider Pacific provider Other sector(s) (please specify): (You may tick more than one box in this section) Please indicate your ecigarette use status: I am using nicotine ecigarettes. I am using nicotine-free ecigarettes. I currently smoke as well as use ecigarettes.
Q4 Do you think it is important for legislation to control advertising of ecigarettes in the same way as it controls advertising of smoked tobacco products? Yes No Reasons/additional comments: Unsure. I don’t it would do any harm to advertise it – it would show people that there is a helpful way to quite soking and possibly where it is sold. However if it was not allowed to be advertised, I think word of mouth would get around anyway. Q5 Do you think it is important for the SFEA to prohibit vaping in designated smokefree areas in the same way as it prohibits smoking in such areas? Yes No Reasons/additional comments: Yes and no. Vaping is not as harmful as smoke so its not really dangerous in terms of But I guess it would be fair to put it under the same category as smoking and have designated areas for it. Q6 Do you agree that other controls in the SFEA for smoked tobacco products should apply to ecigarettes? For example: Control Yes No Reasons/ additional comments Requirement for graphic health warnings ✔ All the e-liquids really need to say is “contains nicotine” Prohibition on displaying products in outlets ✔ As a nicotine product, it should not be displayed Restriction on use of vending machines ✔ As an R18 product, it shouldn’t be in vending machines Requirement to provide annual returns on sales data ✔ For statistics Requirement to disclose product content and composition ✔ Yes, of course it should say what’s in it Regulations concerning ingredients (eg, nicotine content and/or flavours) ✔ Requirement for annual testing of product composition unsure Prohibition on free distribution and awards associated with sales unsure Prohibition on discounting unsure Prohibition on advertising and sponsorship Answered above Requirement for standardised packaging Answered above
Good manufacturing practice ✔ No. We do not recommend that full pharmaceutical industry GMP standards should be required, as this is unlikely to be feasible for EC manufacturers (particularly independent manufacturers) in NZ or elsewhere. An alternative that has been proposed is that EC specific standards are developed that are practicable whilst ensuring a reasonable standard of specific EC manufacturing practices such as handling of chemicals, levels of nicotine purity etc. This would again require an analysis of best international practice, and requiring compliance with these standards as a condition for products to be approved for sale in New Zealand. Purity and of nicotine ✔ Yes. We recommend that requirements for purity and grade of nicotine are introduced aligned with best international practice, and that compliance with these standards is a condition for products to be approved for sale in New Zealand. Registration of products ✔ Yes We recommend that registration of products and demonstration of compliance with international standards is a condition for products to be approved for sale in New Zealand. A testing regime to confirm product safety and contents purity ✔ No. Resources to implement a comprehensive high quality testing regime in New Zealand are unlikely to be available. Maximum allowable volume of e-liquid in retail sales ✔ Yes. We recommend a maximum purchase/sale regulation is introduced in line with what is reasonable for personal use. The rationale for this is that bulk purchase is likely to be for the purposes of supplying/selling to others, which would circumvent the restrictions on sales and supply (particularly to minors) and the requirement that sales staff can provide expert advice in use of ECs and brief smoking cessation advice and referral.