Thank you very much.
Good afternoon. Thank you for the opportunity to speak to the committee today. I'm appearing on behalf of provincial and territorial chief medical officers of health and am providing a collective public health perspective, not individual provincial-territorial jurisdictional positions.
To start, I would like to acknowledge the ongoing work of the federal government to continue to advance tobacco control in Canada. Bill S-5 is an important next step in that work. I would also like to thank all the federal political parties for their support at the second reading of Bill S-5.
Tremendous gains have been make in tobacco control in Canada, but the use of tobacco products remains our number one cause of preventable death. There is much more that needs to be done. As you heard from Minister Petitpas Taylor on February 14, the federal government is committed to the goal of reducing tobacco use rates to 5% by 2035. Reaching that goal will require a collective focus on two areas: preventing youth and young adults from starting to use tobacco products, and supporting current users to quit. Bill S-5 will make important advances in both areas, and is supported by the provincial-territorial chief medical officers of health. However, we would like to offer suggestions to strengthen the bill and maximize its impact.
I will start with plain packaging. Restricting the advertising and promotion of tobacco products has been a critical part of the success to date in tobacco control in Canada. Requiring plain and standardized packaging, as per Bill S-5, will remove one of the few remaining ways for tobacco products to be marketed to Canadians. It will prevent initiation and will support long-term cessation. If you look at the full body of evidence on the impact of plain and standardized packaging in other countries, as has been previously provided to the committee by the Canadian Cancer Society, it clearly shows the potential contribution that plain and standardized packaging could make in continuing to decrease the use of tobacco products in Canada. It has also clearly been established that claims by the tobacco industry that plain and standardized packaging increases the use of contraband tobacco products are inaccurate and exaggerated.
Two areas where Bill S-5 could be improved regarding plain and standardized packaging are, one, amend the bill to provide regulatory authority to allow health warnings directly on tobacco products in addition to packages, as the bill does for vaping products; and, two, amend the bill to provide regulatory authority to allow provisions of the act to apply to herbal smoking products, including herbal water pipes, in the future.
I'll now move to electronic nicotine delivery systems, ENDS, or as they're more commonly known, e-cigarettes.
Eight provinces have ENDS legislation covering areas such as legal age of sale, public use, retail sale, and point-of-sale advertising. Provincial and territorial chief medical officers of health are pleased that the federal government is moving forward with their legislation on these products, but we share concerns regarding the advertising and promotion already provided to this committee by other tobacco control organizations. The evidence to date on ENDS is that while they may help some individuals to be successful in cessation, ENDS may also inhibit cessation by facilitating the alternating use of ENDS and tobacco products. In short, the evidence on ENDS as a cessation product is at best equivocal. There is also growing evidence that, likely because of ultrafine particulate in inhaled vapour, the risk of cardiovascular disease from the use of ENDS is similar to that from smoking tobacco products. Furthermore, evidence from Canada and the U.S. shows that youth who use ENDS are at increased risk of starting to use tobacco products.
The regulatory approach to ENDS, including advertising and promotion, needs to find an appropriate balance based on existing evidence between any potential net benefit as a tobacco cessation product and potential risk to increasing youth initiation with tobacco products and inhibiting tobacco use cessation. In our opinion, as currently written, Bill S-5 does not provide that balance and is inconsistent with existing and proposed approaches to advertising and promotion for tobacco and cannabis respectively.
As it is currently written, Bill S-5 would allow widespread marketing and promotion of ENDS comparable to the 1960s tobacco industry voluntary code. We recommend that Bill S-5 be substantially strengthened by, one, requiring that ENDS advertising may only be information or brand advertising. This is the approach for tobacco in the Tobacco Act and the proposed approach for cannabis in the cannabis act. Our second recommendation is to remove provisions that allow lifestyle advertising in bars and in publications sent to adults. Third, restrict the provision of incentive promotions—for example, price discounts—to specialty ENDS retail stores. Fourth, place the same restrictions on the locations of ENDS advertising as are currently in the Tobacco Act and in the proposed cannabis act.
These amendments would create a much better balance between allowing those who currently use tobacco products to be informed about ENDS as a potential cessation support and protecting youth and young adult non-smokers.
I will end by noting that detailed language on these recommended regulatory changes has been supplied to this committee previously by the Canadian Cancer Society.
Thank you again for the opportunity to provide this information to you today.