Thank you, Madam Chair, for this opportunity.
As mentioned already, we support the broad objective of elimination of overtly fruity or confectionery style of flavours in all tobacco products. So in that sense we don't have any complaint about the concept of coming up with a list of prohibited additives in relation to tobacco products.
We do have some difficulties, however. We believe these are unintended impacts of the wording used in the legislation. And all of this, of course, is related to technical interpretation of the language in the bill and more specifically in schedule 1.
Because of the way it's drafted, it de facto prevents us from using a large number of ingredients that truly have nothing to do with flavouring. So far, we have identified more than 20 ingredients that are used by our suppliers and are required in the making of our products. If the bill were to be adopted as it is currently written, in fact it would prevent us from continuing to manufacture cigarettes.
I'll give you a few examples. In relation to item 1 of the schedule, the FEMA list covers not only flavourants but all types of ingredients without flavour that are used by flavour manufacturers in making up their formulations.
Item 1 in the schedule does provide for some exemptions, but it doesn't capture everything. One example of that is a very simple one; it's a product called potassium sorbate. Potassium sorbate is a very well-known preservative used very widely in the food industry. It's used within the cigarette industry as an additive to adhesives, or glues if you prefer, just to keep mould from growing on the adhesive when it's stored in tanks.
Elsewhere in the schedule we see words like “sugars” being used. Well, sugars are not just sweetening agents. In technical parlance, “sugars” often refers to complex sugars. One of the most common complex sugars is starch, and as we well know, starch is not a sweet substance; it's also extracted from vegetables and fruits, of course the most common form of starch being cornstarch. This is again not exactly a problem from a flavouring standpoint. Starch, I should point out, is also used as one of the principal ingredients by several manufacturers of cigarette papers to create what we refer to as the “speed bumps” on the cigarette papers that are used to meet the low ignition propensity regulations in Canada.
Yet another example is the expression “vitamins and minerals”. We understand that was meant to refer to vitamins and minerals from the standpoint of nutrition. However, unfortunately—and we have to interpret this from a technical, scientific standpoint—the word “mineral” also encompasses calcium carbonate, or, if you prefer, chalk. Chalk, again, has nothing to do with nutrition, but chalk is used in cigarette papers to control the flow of air through the paper, and it plays a really important role, again, in our ability to meet the low ignition propensity regulations.
Furthermore, linseed oil and soybean oil are used in ink formulations as diluents in the ink, much in the same way as these products are used in inks and in the paint industry. But linseed oil and soybean oil are not there for any nutritional value. In fact, it would be ludicrous to make such a claim. They're simply there as a diluent, but they do contain essential fatty acids.
I don't believe it was the intent of the legislation, but the fact remains that this is the wording that is used currently, and we feel it certainly needs to be corrected. I won't go any further with examples. There are many more.
Our suggestion would be to create a list of additives that impart these fruity confectionery flavours, and let's have a ban on those additives. Alternatively, let's come up with a list of products that are permitted on the basis of functionality, provided these do not provide these overt flavours.