Thank you, and good afternoon.
I'm a scientist, and for almost 20 years I've been conducting research on the impact of health warnings, product labelling, and the effect of branding and marketing in the areas of tobacco, food, and most recently, cannabis. I want to be clear that I don't accept any industry funding, and I don't represent any organization for or against cannabis legalization. I've also served as an adviser to the World Health Organization and regulatory agencies around the world and been an expert witness in tobacco litigation, including on behalf of the Government of Canada.
Now I'd like to focus on the public health implications of three areas. One is restrictions on branding and package, the second is health warnings, and the third is product labelling.
Of all the areas covered in the act, marketing and promotion can have the most direct impact on who uses cannabis, what types of products are used, and for what reason. The marketing restrictions proposed in the act are largely modelled on those for tobacco products in Canada. Like tobacco legislation, the cannabis act seeks a balance between allowing product information to reach adult consumers while prohibiting marketing that promotes use, especially among young people.
The question, of course, is how to balance and how to accomplish that balance, and I would like to touch upon several lessons from our experience with tobacco marketing over many decades.
The first lesson is that branding has the greatest impact on young people, those whom the act seeks to protect.
The second is that limited marketing restrictions have limited effectiveness. When most traditional forms of tobacco advertising were prohibited, the marketing expenditures didn't stop. They simply shifted to other channels, including packaging and the retail environment. For this reason, Canada and other countries are implementing what we call standardized or plain packaging of tobacco products that removes logos and brand imageries from packs, but allows product information to be displayed.
Plain packaging is an effective public health measure. Not only does it reduce the promotional appeal to young people, it also enhances the impact of health warnings. If the government were to pursue its objectives without implementing plain packaging, the government would find itself with the responsibility to police thousands of individual packages to ensure that brand imagery does not increase appeal among youth or promote a positive lifestyle. That's an incredibly resource-intensive and difficult task that has proved ineffective for tobacco products, as it almost certainly would for cannabis products.
The third lesson from tobacco is that, once marketing and promotion is allowed, it's very difficult to scale back through regulation or new legislation. Consider that it's taken 50 years and multiple legal challenges for Canada to achieve the current restrictions on tobacco marketing. It is much harder to restrict marketing after it's been permitted than it is to loosen restrictions, and once it's been allowed, the effects of promotion and marketing can persist long after removal. In short, it's very hard to put the genie back in the bottle.
The fourth lesson is that the removal of branding does not promote illegal or contraband sales. Testimony to this committee earlier this week suggested that restricting cannabis branding would make it more difficult for consumers to distinguish between illegal and legal products. That simply is not accurate. Cannabis products acquired through legal retail outlets will be clearly distinguished by health warnings and other labelling requirements. It's simply not credible to associate reduced branding with an advantage for illegal products. The same argument has been made by tobacco companies to oppose plain packaging laws, and these arguments have been refuted in multiple legal rulings. Overall, if the government wishes to prevent lifestyle advertising and promotion to young people, the act should include plain packaging.
Health warnings are another essential component of labelling policy. The question is, what should cannabis warnings look like? What does Canada want to say about the risks? Is driving high really all that risky? Does it really harm a baby when their mom uses cannabis when pregnant? Most Canadians are uncertain about the potential risks of these products, and they want this information.
Health warnings are the most cost-effective, self-sustaining way of communicating with Canadians about cannabis. Should cannabis warnings look like the ones on cigarette packs? Well, if they don't, they should at least incorporate the same basics of effective warnings. That is, they should be large, they should use colour, and include pictures. Large pictorial warnings are the most effective way to reach children and youth and the most vulnerable members of our society with low literacy.
Warnings aren't just about scaring consumers away from a product. They are about informing consumers, but they also provide an opportunity to provide support for those who need it, and for addiction. In Canada, every cigarette pack includes a telephone helpline number and a website for helping Canadians quit smoking. We have evaluated this, and it works well. I would urge the government to display the same services on cannabis packages to demonstrate its commitment to reducing addiction.
Lastly, I'd like to briefly discuss labelling of product contents and dose. I think there is strong consensus that THC levels should be displayed on packages, but we can't simply rely on providing numbers to consumers. How many people in the room today intuitively understand what 50 milligrams of THC means? Is that a little? Is that a lot? What does it mean in terms of different products or routes of administration?
Consider that Canada is about to start using what we call traffic-light labels or high/low symbols on food packages. We're going to be doing that because it's easier for consumers to understand and use. The same principles should apply to cannabis labelling. If it's important enough to use symbols for canned soup and sugary drinks, it's important enough for cannabis products.
I would argue that THC and dose labelling should also be reflected in the actual packaging. When edibles are eventually sold on our market, each dose should be individually packaged. Think about individual pieces of gum that are packaged within the larger packaging, or those little Halloween chocolate bars that we hand out, which are now sold, again, in a larger packaging.
To conclude, overall the public health impact of cannabis will largely be determined not simply by whether it's becoming legal, but by how it's regulated in a legal market. Comprehensive restrictions on marketing and promotion should be given precedence in the act and should include plain packaging. Large, clear health warnings that use images will provide governments with an efficient and highly cost-effective means of communicating with consumers. They should also be used to support Canadians who need help with addiction.
Regulations should also heed the lessons from Washington, Colorado, and other states that have legalized cannabis, to ensure effective labelling standards for edibles and different forms of cannabis. Collectively, these measures will demonstrate the government's commitment to ensuring that cannabis legalization benefits public health.
Thank you very much.