Thank you, Mr. Chair and committee members. We appreciate the opportunity to speak before you today.
My name is Alex Scholten. I serve as president of the Canadian Convenience Stores Association. Our association represents the over 25,000 convenience stores operating in Canada that employ 217,000 Canadians. Our stores serve over 10 million Canadians each and every day. Last year, the industry posted sales in excess of $55 billion.
We support customers based in urban and rural communities across the country. Our stores offer a wide array of products, including age-restricted items such as lotto tickets, tobacco, and, in some provinces, alcohol.
Today I'll be speaking about the sale of tobacco in our stores, our approach to the sale of e-cigarettes, and our recommendations on how we believe the sale of these cigarettes should be regulated by the federal government.
Convenience stores are the largest retailer of legal regulated tobacco products in Canada. The sale of tobacco in our stores is heavily regulated, and we take very seriously the responsibility of selling those products. To give you an idea of some of the requirements that our retailers have to comply with, I'll go through some of the things we do when we sell products.
First and foremost, tobacco products are hidden behind displays so that they are not visible to youth. Secondly, in order to prevent youth from being exposed to tobacco advertising or promotion, the marketing of legal tobacco products is strictly prohibited in Canada and, as such, there are no signs or images that promote tobacco inside or outside of our stores. When legal tobacco products are purchased, the packaging of these products is almost fully covered by warning labels that detail the consequences of smoking. Retailers are also required to check the age of consumers before selling any tobacco products, to ensure that youth do not acquire such products.
The Canadian Convenience Store Association actively discourages the sale of any tobacco product to minors, and this message is shared by our members. We offer retailer training on how to properly conduct age-testing when selling tobacco products, and we have our members sign a code of conduct whereby they commit to checking ID when selling tobacco products, and they agree not to sell tobacco to youth. We consider ourselves an active partner in government tobacco control strategies and believe our efforts in enforcing strict age checks have been instrumental in reducing youth consumption rates to all-time lows.
For several years, convenience stores have been selling electronic cigarettes that do not contain nicotine. It is a rapidly growing category. In the United States, sales of these products have doubled in each of the past three years. In Canada, there has been a sharp increase but not to the same degree as the United States, as there has been regulatory confusion on how the products are handled and sold.
In accordance with Health Canada rules and regulations, our stores have not been selling electronic cigarettes containing nicotine, nor have we promoted any potential health benefits associated with those products. In August of this year, our association proactively created a suggested retailer best-practice recommendation document specifically for the handling and sale of electronic cigarettes. That document is attached to our submission for committee members today.
The purpose of the document was to answer retailer questions on this new product category and also to promote what our association believes to be responsible retailing practices, just as it has done with the handling and sale of tobacco products. Our association's recommendations to this committee are primarily derived from the best practice document that is included in your package.
I'll go through some of those details now.
First and foremost, we recommended to convenience store owners across the country that electronic cigarette products should only be sold to adults. This approach was also adopted by the Ontario government this week when they released proposed legislation regarding the sale of e-cigarettes. We have already sought to implement these age restrictions in our stores and actively encourage all our retailers to follow what is outlined in our best practice document.
To be clear, the Canadian Convenience Store Association fully supports a ban on the sale of electronic cigarettes to youth. We already comply with bans on tobacco sales to youth, so convenience store staff are well trained to comply with those types of restrictions.
ln order for electronic cigarettes to fulfill their true potential as a viable or healthier option to cigarettes, we believe they have to be widely available where smokers buy their cigarettes. We believe that allowing the sale of electronic cigarettes in our stores presents this type of opportunity.
Not only do our stores provide a controlled and regulated environment for the sale of these products, but we have also heard consistently from our customers that e-cigarettes are more effective options than nicotine replacement therapies such as patches, gum, lozenges, and inhalers, because they replicate the behavioural aspects of smoking cigarettes and, as we've been told, they are less expensive options than some of those other products.
The reality is that Canadian consumers are already accessing e-cigarettes with nicotine in large numbers, not in our regulated and monitored stores, but through the many vape shops that are operating across the country and through online sales that are technically operating outside the law, although the law is not being actively enforced. This continues to put our law-abiding retailers who comply with Health Canada regulations at a disadvantage.
Our recommendation to government is to clarify the retail framework for e-cigarettes to create a level playing field for all retailers and to do so in a way that recognizes consumers want access to these products. There is nothing to be gained by imposing severe restrictions so that a black market for e-cigarettes is then created to go along with the already thriving black market in tobacco products.
While we agree with the Ontario government in limiting the sale of e-cigarette products to youth, we do not agree that these products should be treated in the same way as regular cigarettes. They are not tobacco products, and therefore we believe they should not be subject to display bans. Given the reduced harm potential for these products, it would be counterintuitive to hide these products from smokers looking to switch to these products.
As we understand it, there is a growing acceptance among public health professionals of the potential of nicotine-containing products to aid smoking reduction and cessation. As such, it would be more beneficial to permit broad freedoms for marketing to adult smokers and users of other nicotine products. If e-cigarettes are proven to be a less harmful alternative, then it is in the public interest for smokers to have easier access to them than regular cigarettes, which would be better accomplished by not restricting their display and advertising.
Our recommendation in that regard is that e-cigarettes should not be subject to retail display bans. This is a new category and we need to be able to educate adult consumers on the varieties and products available.
Finally, our stores need the government to quickly approve all e-cigarette products, including products with nicotine that are available in the United States, so that we can begin to sell them legally in a controlled environment. Right now, customers are acquiring e-cigarette products with nicotine from the Internet and from vape shops, and it's really the Wild West right now.
There are regulations, but they're not being enforced. I can tell you stories of smokers who have switched to e-cigarettes containing nicotine and don't come to our stores anymore. They tell us the reason is that we don't offer those products. As our stores look to find ways to wean customers off regular tobacco products, we need e-cigarettes approved so that we can begin to offer alternative products in our stores in a controlled and regulated environment.
Therefore, our recommendation is that the federal government move quickly to approve these products, including those containing nicotine, for sale in Canada so they can be regulated and controlled through already existing channels.
Thank you very much. I welcome any questions you may have.