Earlier today, Americans for Tax Reform wrote to Health Canada, urging the agency to not move forward with a proposed ban on flavored vaping products. Tim Andrews, ATR’s Director of Consumer Issues, wrote the letter, drawing the Canadian government’s attention to real-world evidence showing the damage that flavor prohibitions cause to small businesses and the public health. The full letter can be read below. 

Dear Minister Hajdu, 
On behalf of Americans for Tax Reform (ATR), a non-profit organization which advocates in the interests of taxpayers and consumers throughout the United States, we wish to draw your attention to recent evidence from United States directly relevant to your decision to ban flavored reduced risk tobacco alternatives such as e-cigarettes in Canada. In the interests of public health, it is imperative that the prohibition on flavored vaping products is not enacted. 
As demonstrated in a study coordinated by Yale University and published last week in the world’s leading pediatric journal, JAMA Pediatrics, empirical data now demonstrates conclusively that flavor bans, such as the one under, consideration have one effect only – drastically increasing the rate at which young people will smoke deadly combustible cigarettes. When a ban on flavored vaping products was introduced in San Francisco, California, youth smoking rates doubled, demonstrating that this policy is a clear public health disaster, and should serve as a cautionary tale to you as you consider enacting a similar measure in the Netherlands. 
In the study, Dr. Abigail Friedman of the Yale School of Public Health examined smoking rates in San Francisco school districts and compared them to rates in other major school districts like New York City, Miami, and Los Angeles. In the years before the flavor ban was enacted, San Francisco’s youth smoking rate was consistently declining and was lower than the rates in comparable districts. After the ban was implemented, San Francisco’s youth smoking rate skyrocketed to 6.2%. In the comparable districts, the smoking rate had fallen to 2.8%, an all-time low. This shows the distinct difference in smoking rates between a city that banned flavors in tobacco and vaping products and cities that followed the science and allowed flavors. 
Your proposed flavor ban is aimed at reducing youth vaping, even though flavors play no role in youth uptake of vaping. Academic studies have found that teenage non-smokers “willingness to try plain versus flavored varieties did not differ” and a mere 5% of vapers aged 14-23 reported it was flavors that drew them to e-cigarettes. National Youth Tobacco Survey results have shown no increase in nicotine dependency among youths since flavored products entered the market. 
ATR further submits that in addition to the public health disaster that reducing access to reduced risk tobacco alternatives will unleash, these proposals would also have devastating consequences on businesses, at a time when they can afford it least. At a time of great hardship due to the Covid-19 pandemic, this bill which would effectively outlaw sections of the Canadian economy. It would kill thousands of jobs and would cost business owners their livelihood. The total economic cost would be devastating
It should be noted that traditional combustible tobacco remains one of the leading preventable causes of death in Canada. The negative health effects of combustible tobacco come from the chemicals produced in the combustion process, not the nicotine. While highly addictive, nicotine is a relatively benign substance like caffeine and nicotine use “does not result in clinically significant short- or long-term harms”.  
Nicotine replacement therapies such as nicotine patches and gums have helped smokers quit for decades. In recent years, advancements in technology have created a more effective alternative: vapor products and e-cigarettes. These products deliver nicotine through water vapor, mimicking the habitual nature of smoking while removing the deadly carcinogens that exist in traditional cigarettes.  
Vapor products have been proven to be 95% safer than combustible cigarettes and twice as effective at helping smokers quit than traditional nicotine replacement therapies. As such, Vaping has been endorsed by over 30 of the world’s leading public health organizations as safer than smoking and an effective way to help smokers quit. 
Further, flavored vaping products are proven to be more effective at helping smokers quit the deadly habit of combustible cigarettes than un-flavored ones. A study from leading researchers on cancer prevention, tobacco control, and public health found that smokers who use sweet-flavored vapor products were 43% more likely to quit smoking than those who used unflavored or tobacco flavored vapor products. Of those who quit smoking, 48% quit nicotine use entirely. 
Your own agency has admitted that this proposal will substantially increase cigarette use among adult vapers. Going ahead with the flavor prohibition, knowing it will increase cigarette consumption, is incredibly irresponsible. Long-term combustible tobacco use is deadly, and you have acknowledged that this policy will lead to more smoking, and a result, more deaths. There is, in fact, evidence from Canada that shows this. Nova Scotia enacted a flavor ban in 2020 and cigarette sales increased by 21% within six months. A poll of vapers in Nova Scotia showed that 29% of them were at risk for relapsing to combustible cigarettes. 
Flavor bans also increase illicit, black-market activity when a product is banned. This drives down tax revenues from the sale of vaping products and increases the revenues of the multi-million-dollar crime syndicates that smuggle these goods. These same criminal organizations use their profits to fund terrorism while engaging in money laundering and human trafficking. Because of this, the U.S. State Department has determined that tobacco smuggling is a “threat to national security”. 
Additionally, banning flavors in e-cigarettes will have a tremendously negative impact on public health and would fail to decrease socioeconomic disparities by reducing access to products proven to help people suffering from mental health issues. A University of Glasgow study showed that e-cigarettes particularly help disadvantaged persons quit smoking and another new study demonstrated that high-strength electronic nicotine products are particularly helpful for smokers with mental health issues quit smoking, like people with schizophrenia who smoke at rates more than three times the national average. 
Policy making must be grounded in evidence. Dr. Friedman’s study, along with the countless others that demonstrate the importance of e-cigarettes, is further proof that a flavor ban would be a disaster for public health in Canada and lead to increased smoking rates among teenagers. With so many advocates of this proposal claiming that this will combat youth vaping, I urge you to consider what will truly occur if this bill is enacted. The evidence is clear. Youth smoking will increase, fewer adults will have access to lifesaving reduced harm products, and as a result, more people in Canada will die from tobacco-related illnesses. 
If you are interested in reading an overview of the study, Americans for Tax Reform published a short summary you can read here. If you would like to read the full study, it can be accessed here.
Policy must be enacted on the basis of evidence, not emotion, and the evidence is clear: Flavor bans are a public health disaster. We strongly urge you to not go ahead with this proposal.  
Tim Andrews 
Director of Consumer Issues 
Americans for Tax Reform 

A downloadable version of the letter can be accessed here