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 X Reasons/additional comments: definitely not – it needs to be far cheaper than cigarettes – you get enough revenue from us smokers as it is. The use of e cigs as a replacement should be encouraged and cheaper cost is a way of doing that. If you are going to tax it to hell like everything else then don’t bother regulating just make the nicotime huice legal and leave it alone! Q8 Do you think quality control of and safety standards for ecigarettes are needed? Yes x No Additional comments: Area of concern Yes No Reasons/additional comments Childproof containers x they already do Safe disposal of ecigarette devices and liquids x ditto Ability of device to prevent accidents x Good manufacturing practice x Purity and grade of nicotine x up to us to check – you don’t do that for smokes! Registration of products x A testing regime to confirm product safety and contents purity x Maximum allowable volume of e-liquid in retail sales x Our choice not yours Maximum concentration of nicotine e-liquid x As Mixing of e-liquids at (or before) point of sale x As above Q9 Are any other comments you would like to make? you should be making these a safe and easily accessible option for smokers like me who have tried patches, gum and twice tried medications that give us a 80% chance of a stroke to quit! This is a far better solution that meets our needs and will be more cost effective for govt health than anything else. Do not price it out of the reach of the normal worker – we don’t get Mp salaries!
Q7 Do you 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 X Reasons/additional comments: Products can be but should be taxed at a lower level to tobacco in order to encourage consumers to switch to the lower risk product. Q8 Do you think quality control of and safety standards for ecigarettes are needed? Yes X No Additional comments: Area of concern Yes No Reasons/additional comments Childproof containers X Safe disposal of ecigarette devices and liquids X Ability of device to prevent accidents X Good manufacturing practice X Purity and grade of nicotine X Registration of products X So long as appropriate standards exist A testing regime to confirm product safety and contents purity x Maximum allowable volume of e-liquid in retail sales X Maximum concentration of nicotine e-liquid X Let the market determine Mixing of e-liquids at (or before) point of sale Other Q9 Are there any other comments you would like to make?
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: Vaping is not harmful as cigarettes are (Reference Health UK Report which states e cigarettes are over 95% less harmful than cigarettes). 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: I think vaping should not be restricted as much. Indoors should still have some restrictions, but outdoor areas – definitely not. Also, this would open up the opportunity to have some indoor areas ok for vaping subject to adequate ventilation. 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 Vaping is not harmful so there is nothing to warn about! Prohibition on displaying products in sales outlets Vaping is not harmful Restriction on use of vending machines See above Requirement to provide annual returns on sales data It would be interesting to see the uptake of vaping and compare it to ‘downtake’ of cigarette sales Requirement to disclose product content and composition Regulations concerning ingredients (eg, nicotine content and/or flavours) Same as standard regulations for food Requirement for annual testing of product composition Prohibition on free distribution and awards associated with Prohibition on discounting Prohibition on advertising and sponsorship Requirement for standardised packaging Other
Q4 Do you it is important for legislation to control advertising of ecigarettes in the same way as it controls advertising of smoked tobacco products? Yes No X Reasons/additional comments: As a consumer 18+ product that is NOT tobacco, e-cigarettes should not be treated the same as combustible tobacco in any way shape or form. That being said, I do believe that as a consumer 18+ product it should not be promoted to those under 18+ the same as alcohol is restricted. 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 X Reasons/additional comments: Society has already demonised smokers, and the evidence that their second hand smoke is a health hazard. Which is precisely why there are additional taxes and excise on combustible tobacco. However, second hand vapour is not a health hazard and should not need to be prohibited, nor taxed for that matter, in the same manner. The fact of the matter is this: vaping and smoking are two completely different things and should not be grouped together under the same discriminatory label with the same punitive excises, restrictions and taxation. 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 X Prohibition on displaying products in sales outlets X Restriction on use of vending machines X Requirement to provide annual returns on sales data X Requirement to disclose product content and composition X Labelling on e-liquid should be standardised as to what is done in other countries: flavourings, nicotine level, PG/VG ratio and date of manufacture.
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 X Reasons/additional comments: 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 X Reasons/additional comments: Q6 Do you 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 X Prohibition on displaying products in outlets X Restriction on use of vending machines X Requirement to provide annual returns on sales data X Requirement to disclose product content and composition X Regulations concerning ingredients (eg, nicotine content and/or flavours) X Requirement for annual testing of product composition X Prohibition on free distribution and awards associated with sales X Prohibition on discounting X Prohibition on advertising and sponsorship X Requirement for standardised packaging X X
Q11 Would the Ministry of Health’s proposed amendments have any impact on your business? If so, please quantify/explain that impact. 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? 7 months Daily $7-$10NZD U.S.A.
Privacy We intend to publish all submissions on the Ministry’s website. If you are submitting as an individual, we will automatically remove your personal details and any identifiable information. If you do not want your submission published on the Ministry’s website, please tick this box: Do not publish this submission. Your submission will be subject to requests made under the Official Information Act. If you want your personal details removed from your submission, please tick this box: Remove my personal details from responses to Official Information Act requests. If your submission contains commercially sensitive information, please tick this box: This submission contains commercially sensitive information. Declaration of tobacco industry or vested interest As a party to the global tobacco control treaty, the World Health Organization Framework Convention on Tobacco Control, New Zealand has an obligation to protect the development of public health policy from the vested interests of the tobacco industry. To help meet this obligation, the Ministry of Health asks all respondents to disclose whether they have any direct or indirect links to, or receive funding from, the tobacco industry. The Ministry will still carefully consider responses from the tobacco industry, and from respondents with links to the tobacco industry, alongside all other submissions. Please provide details of any tobacco company links or vested interests below. None Please return this form by to: ecigarettes by 5 pm, Monday 12 September 2016. If you are sending your submission in PDF format, please also send us the Word document.
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 X Reasons/additional comments: Vaping likely presents none of the short, medium, and long-term negative health impacts that smoked tobacco does Some research is indicating it is also less addictive than smoking tobacco – it certainly feels less addictive to myself and most vapers I talk to Ecigarettes need to be lauded as an alternative method to quitting smoking tobacco Q5 Do you 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 X Reasons/additional comments: I think public education is more important. I choose not to vape in designated smokefree areas, but my reason is misunderstanding and lack of knowledge in others as many people assume vaping is the same as smoking tobacco. Research at this point indicates there are no second-hand vaping contamination risks to others, including vaping nicotine e-liquid Vapers do need to be considerate and respect the personal space and opinion of others around them 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 X Unsure what health risk be found to warn about except nicotine addiction Prohibition on displaying products in sales outlets X Smokers need to be encouraged rather than discouraged to switch to vaping. Treating vaping the same as smoking tobacco will serve to perpetuate public ignorance and misinformation about vaping facts Restriction on use of vending machines X Risk of sales to minors Requirement to provide annual returns on data X We need all the data we can get if vaping proves to be as effective as it appears it may be in assisting people to stop smoking tobacco Requirement to disclose product content and composition X Good practice, protect consumers
Regulations concerning ingredients (eg, nicotine content and/or flavours) X With caution. Eliquid should contain the strength of nicotine the packaging claims. Certain ingredients are less suitable for vaping than others, especially some flavouring additives. Requirement for annual testing of product composition X Prohibitive costs could stifle small business operators. Random quality control testing in conjunction with minimum standards legislation may achieve the same. Prohibition on free distribution and awards associated with sales X Provided it is not supplied to minors Prohibition on discounting X No reason to Prohibition on advertising and sponsorship X With caution, may require regulation in future Requirement for standardised packaging X We do require standardised labelling Other X The public needs to understand the exact benefits and potential risks of vaping compared to smoking cigarettes. The press tends to sensationalise and misrepresent study results, often misinforming the public about exaggerated risks of vaping 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 X Reasons/additional comments: Vaping research has evidenced the overwhelming benefits to health as an alternative to smoking cigarettes. Imposing a similar prohibitive tax on a healthier alternative will signify that tax is more important to our government than public health. It is important that NO excise duty is imposed on nicotine containing e-cigarettes, but instead a subsidy could be considered due to the health benefits and reduced cost to our health system Income tax and GST would still apply to traders and consumers of ecigarettes Q8 Do you think quality control of and safety standards for ecigarettes are needed? Yes X No Additional comments: Area of concern Yes No Reasons/additional comments Childproof containers X Safe disposal of ecigarette devices and liquids X