Thank you, Madam Chair and members of the standing committee. I represent the Small Guys Tobacco Group, but allow me for a moment to describe what we do as a group.
We are one company of that group. I represent House of Horvath; it's a family business. My wife's family has been in this business in Toronto, Ontario, manufacturing cigars since 1932, and we carry it on today.
The Small Guys Tobacco Group, as a group, represents the interests of the small cigar and pipe tobacco importers of Canada. The Small Guys Tobacco Group represents less than one-half of 1% of the total Canadian tobacco market, a number you've heard earlier today. We are made up of a number of independent companies, many of which are family owned and operated, with some tracing their origins back over 75 years.
Now, the Small Guys Tobacco Group is not new to Health Canada. We first came into being in 1998, I believe, which was...the Tobacco Act. That was the first time we had an opportunity to meet with Health Canada. Obviously, we were aware that regulations were going to come through, and we worked closely with the members here of the tobacco control team, along with the ministers of health. I want to say that this relationship has been a rewarding one for both of us because we're the industry that you're regulating. We're honest enough to share information with you and expect the same courtesy back. A business that's been around for 75 years has seen a lot of regulation over these times. So that's who we are as the Small Guys Tobacco Group.
I have some slides here. This is a presentation that we actually submitted to the standing committee, and I think the committee will get these.
I will be speaking to our points.
On a review of the general bill, in spirit, we are in agreement with it insomuch as little cigars, as we refer to them--and we'd like to make that distinction because cigars are all different in terms of the names and nomenclature used in the industry--are an American-style product with an acetate filter. So in spirit, we're happy that it's headed in a direction that these should not be done singly. They should be done in packs of 20, and that is our first goal there.
With respect to the amendments we would propose, it refers to paragraph 2.(2)(d). Just for easy reference, paragraph 2.(2)(d) reads:
has a cigarette filter or weighs no more than 1.4 g, excluding the weight of any mouthpiece or tip.
We have two recommendations under that paragraph. On the first one, it is kind of odd that it would come from an industry member, but we're suggesting that the Standing Committee on Health substitute the word “cigarette filter”, which is ambiguous or arbitrary.... Actually, in one regard, if I had a filter on a product, yes, I would call it a cigar filter, not a cigarette filter. So we would ask that you tighten that up to say “cellulose acetate filter or other filtering device”.
We would also strongly recommend that you either omit or eliminate the weight characteristic. You capture products that have been traditional in European cigar culture for hundreds of years. Certainly, we have heard from the ECMA group, which is the European manufacturers' council or cigar association in Europe. They're very nervous about this because you're capturing a product that they sell widely and only to adult consumers. It's an expensive product to begin with, so it's not in any of the kiddy-pack formats that you're talking about. A 10-pack of these would cost somewhere between $14 and $20, and if you're talking about the Cuban format of the same product, it would be over $27 a pack.
The second amendment we were looking at refers to proposed subsection 5.1(1), which reads:
No person shall use an additive set out in column 1 of the schedule in the manufacture of a tobacco product set out in column 2.
I'll read my notes, and you can probably follow the gist of it.
On a review of schedule 17, column 1, it is clear that the list of prohibited additives represents a total ban on all additives. The restrictive additive list goes beyond limiting the use of additives that may be deemed to be candy-like and appealing to youth, and captures additives that may be deemed essential to making the product you're trying to ban or regulate, one of which is just the presence of sugar. It really requires you to understand the concept of air-cured and flue-cured tobacco, and we have members here who can speak to that.
One of the processes takes the sweetness out of the tobacco and one leaves it in—or leaves a portion thereof in. On the cigar side of things you have to add that back. Again, I'm not a manufacturer and I'm not on the technical side, but I would suggest that there's a level that you'd have to add back. It may not be super juicy sweet, but it is a level that is necessary to make the tobacco palatable to smoke.
We would strongly recommend that the standing committee and Health Canada expand the list of exclusions from the prohibitive list in order to include those items that are considered essential to the manufacturing set out in column 2, such as item 10.
I'll point out, because I heard the menthol conversation in the debate, that there are many of the traditional flavourings that have been used in the cigar market for years that predate the Second World War as well.