Thank you.
Hello.
Beyond setting a minimum age, preventing cannabis use among young people depends in large part, as my colleague said, on establishing a strict legal framework for this product, which we consider to be no ordinary commodity, as certain public health stakeholders would say.
The creation of environments where the use of psychoactive substances is not stimulated or normalized is one of the best approaches to prevention. The measures taken by the provinces and territories with regard to authorized sale and consumption sites will be decisive in creating these environments. Certain measures in Bill C-45, however, and its subsequent regulations, will also be very important for the commercialization of cannabis, in particular among more vulnerable populations such as young people, be they under or over the age of majority.
The INSPQ would therefore like to take this opportunity today to repeat certain analyses that it presented in its brief submitted in August in order to ensure a better framework for marketing practices.
Research on commercial practices in the tobacco and alcohol industries shows to what extent sophisticated marketing strategies can affect consumption and the associated health problems. Research also shows that young people are particularly easy to influence. That is why the INSPQ is calling for an immediate ban on all forms of advertising and brand promotion, which raises four specific concerns related to youth and the bill under consideration.
First, packaging that is neutral and that provides information to allow for an informed decision on the nature of the product should be immediately required. Given that packaging is itself a tool for promoting the substance, the prohibition in clause 26 on packaging that could be appealing to young persons is neither clear nor sufficiently strong. The consultation report on plain packaging for tobacco products that was published in January 2017 should certainly be informative in this regard.
Second, promotional items should not be tolerated. Hats, socks, T-shirts and cups with hemp leaves or brands of medical cannabis on them are already popular, especially among young people, and help normalize cannabis. The display of a brand on “other things”, as provided in clause 17(6) of the bill, opens the door to branded derivative products. Once again, the prohibition intended to ensure that “other things” are not associated with or appealing to youth remains vague, and this brand promotion practice should be banned.
Third, clause 17(2) allows brand promotion in areas where minors are not permitted, which raises the same problem as packaging and derivative products. First, we know that minors often frequent such places. Young adults aged 18 to 25 are the group with the highest percentage of users. Moreover, we wonder whether the legal age should be raised. The fact that this group of young people can be exposed to advertising in bars, for instance, is inconsistent with a public health approach. This kind of promotion can not only encourage the use of cannabis, but also insidiously incite customers to consume cannabis and alcohol at the same time, which is a very high-risk behaviour, as you will agree, particularly as regards transportation safety.
Fourth, any effective strategy to regulate brand promotion and advertising should ideally include the Internet. Bill C-45 prohibits the publication and broadcast of advertising in the press and on radio and television, but is silent on measures to regulate this on the Internet. Yet it is mainly on digital platforms that youth and industry are already active, and this reality warrants particular attention in future regulations.
In short, there is reason to consider setting the minimum age above the age of majority. To the extent that the age of majority is a determinant of the age of initiation, this raises consistency issues as regards alcohol and tobacco, substances that are equally or more toxic than cannabis. Setting a minimum age above 18 for cannabis should therefore be part of a broader discussion of psychoactive substances and, indeed, of the age of majority.
In the meantime, the INSPQ maintains that certain provisions of Bill C-45 and its subsequent regulations can be amended or clarified in order to reduce the commercial promotion of cannabis to young people.
We hope that the considerations presented today will be helpful in this regard.
Thank you.