Thank you, Madam Chair.
Before I begin, I would just like to ensure that our submission has been received by the committee, both French and English versions. Thank you.
My name is Tamara Gitto. I'm associate general counsel at Imperial Tobacco Canada Limited. I am accompanied by my colleague, Mr. Gaëtan Duplessis, who is division head of research and development at Imperial.
We appreciate this opportunity to speak to Bill C-32. We've prepared a formal submission, and I hope you'll take the time to review it if you've not had the chance to do so already.
I think it's important to begin by clarifying the scope of our business. You've heard a lot about the tobacco industry and the tobacco business in the last few minutes. We do not manufacture or sell little cigars. We do not manufacture or sell flavoured cigarettes, except for menthol. We do not manufacture chewing tobacco.
Ordinarily, I would go on to tell you that Imperial is Canada's leading tobacco company. But I can't make that claim anymore. The manufacturers in Ontario and Quebec, the leading manufacturers in those provinces, are illegal manufacturers. Almost 50% of all tobacco purchased in Ontario is illicit, and this number reaches 40% in Quebec. Certain members have raised this issue in the debates on this bill, and rightly so.
Imperial Tobacco is here today to state its support for the original intent of this bill. We support the regulation of little cigars and we believe they should be regulated in the same manner as cigarettes. We also support reasonable regulation of overtly flavoured tobacco products.
We do have some reservations about the drafting of the bill, which has led to many unintended consequences, and these issues will be detailed by my colleague.
We also believe that the listed additives should be permitted in research and development, especially in the area of harm reduction. We believe that the development and commercialization of potentially risk-reduced products containing these additives should be allowed under appropriate government supervision.
We must unfortunately voice our disagreement with the proposal to ban print advertising, as it's currently outlined in the bill, in publications with at least 85% adult readership. The current legislation is sufficient and needs only to be enforced if Health Canada believes that an ad or any ad placement is inappropriate. Further legislation is unnecessary.
On top of that, illegal tobacco is openly advertised and available at pocket-change prices to whoever chooses to buy it. Banning print ads with severely restricted content in adult publications is not the true problem here, which leads me to my last point.
We are concerned about uniform enforcement of this bill and of all tobacco control measures. If the government enforcement policy does not change, flavoured products will simply appear on the black market and will defeat the objective of this bill.
These concerns have been detailed in
our submission at considerable length.
I would invite you to read it.
My colleague, Mr. Duplessis, will now address the technical issues that arise due to the unintended drafting issues in the bill.