published between 2016 and 2019
NOT PEER REVIEWED Thanks for Mr. Middleton's information that there are local tobacco
manufacturers in Hong Kong. I made a mistake when reading the materials. I
have amended this in the updated version.
It does not affect the analysis as the government taxes based on
number of cigarettes sold rather than manufactured, but I sincerely
appreciate your valuable advice.
For the analysis part, it is not easy...
For the analysis part, it is not easy to have an "official figure" of
illicit cigarette consumption. During the peer review stage, I indeed have
discussed with the reviewers which source is preferable. I adopt the
figures provided by the tobacco sellers, but also list the Euromonitor a
reviewer suggested for readers' reference. Noted that these figures lead
to the same result, as the total tobacco consumption (tax + illicit) drops
after the tax increasing, which rebuts the traditional economic view that
tobacco duty is not an effective method because of smuggling.
It is also not an easy job to determine how much price is affordable
for people esp youngsters. However when we find out that smuggling shall
not be a concern when the government increases the tax rate, it is clear that
tobacco duty is a powerful tool to control cigarette consumption.
NOT PEER REVIEWED Pressure the CDC and FDA to pressure state legislatures to outlaw the
sale of filtered cigarettes. As I see it, this is the only viable solution
for ending this litter problem. Cigarette smoking should be made as
unappealing as possible to all concerned.
NOT PEER REVIEWED The author appears to believe that the main problem with the FDA is that it is not doing enough to prevent new niche cigarette products reaching the market. This focus of concern is misplaced, given several thousand cigarette products are readily available and smokers are spoilt for choice with or without these new products. I have no great desire to see new cigarette products coming on the market, but is this...
NOT PEER REVIEWED The author appears to believe that the main problem with the FDA is that it is not doing enough to prevent new niche cigarette products reaching the market. This focus of concern is misplaced, given several thousand cigarette products are readily available and smokers are spoilt for choice with or without these new products. I have no great desire to see new cigarette products coming on the market, but is this really the most pressing agenda?
There are important issues for FDA and Congress to address, but on which the author did not comment. Allow me to suggest five:
1. FDA's governing framework for tobacco, the Tobacco Control Act, is unfit for the purpose of managing reduced risk products. It is designed to raise a high regulatory barrier to entry to a market dominated by worst products and to suppress innovation in better products. At the same time, it has protected the existing cigarette trade by 'grandfathering' the thousands of products that were on the market at 17 Feb 2007 and offering them an easy ride for subsequent modifications. A new legislative framework for recreational nicotine products is required.
2. FDA regulation is unlikely to offer a feasible route to market for most vapour products. ?Its approach will cause chaos in the marketplace, even though these products are helping many to quit smoking. The vapour category would be largely wiped out and confined to the tobacco industry's high volume commodity products if FDA proceeds on its present course. That would provide further protection for the cigarette trade and stimulate a black market. Workarounds, a change in the predicate date or simply doing nothing would be an improvement.
3. FDA's approach does little that supports and a lot that suppresses innovation, regardless of whether particular innovations are desirable for consumers. For example, under the proposed framework for vapour products to access the market, a third generation e-cigarette manufacturer would likely need to go through a new and hugely burdensome authorisation (PMTA) to introduce new safety features like temperature control or to improve nicotine delivery through better aerosol science. A notification regime with an FDA right to intervene if the evidence justifies it would be preferable to a cumbersome authorisation regime.
4. FDA applies a bizarre approach to communicating the far lower risk of products like snus to consumers. This starts with a default FDA-imposed warning that is technically correct but not truthful because it is highly misleading ("this product is not a safe alternative to smoking"). It then requires tobacco companies to calculate if they are rich enough, the data extensive enough and whether it is sufficiently in their commercial interest to go through an arduous process to convince the FDA to allow them to change the warning to something more truthful ("No tobacco product is safe, but this product presents substantially lower risks to health than cigarettes") - and face hostile resistance from tobacco control campaigner such as the author. FDA and CDC should be assessing the relative risks of these products, and communicating them clearly - so that public risk perceptions become, as far as possible, aligned with scientific reality.
5. FDA suffers from mission creep - a regulator should not be involved in campaigning. FDA should function, and be seen to function, as a neutral technocratic regulatory agency, leaving the hype to public health bodies like the CDC. In this case, there is a further problem - the scientific foundations of the new smokeless campaign are very poor and undermine FDA's credibility more generally. FDA should stick to its core mission and do it better.
Matthew L. Myers and his campaign would do better to consider the important issues in nicotine regulation, not expend time, money and credibility on marginal issues with negligible public health value.
I am a long-standing advocate for tobacco harm reduction and run the Counterfactual blog. I have no competing interests with respect to any relevant industry.
In a smaller sample of older teenagers, I recently extended and
replicated some of Vasiljevic and colleagues' findings . In line with
their results, I found that e-cigarette advertisements did not increase
interest in tobacco smoking, interest in using e-cigarettes or
susceptibility to either behaviour.
In this experimental study, 65 UK non-smokers aged 16-19 years were
randomised to viewing either six e-ci...
In this experimental study, 65 UK non-smokers aged 16-19 years were
randomised to viewing either six e-cigarette advertisements cleared for
television broadcast in the UK in 2014/15 or recent nicotine replacement
therapy (NRT) adverts. The e-cigarette adverts featured five different
brands and varied in content, setting, people portrayed, type of e-
cigarette and whether flavours were a focus. Participant completed a
baseline survey, watched the three-minute videos and completed a
distractor task and a post-exposure survey in their own time on individual
computers using headphones.
The main outcome measures were interest in using e-cigarettes and
interest in smoking tobacco cigarettes measured using visual analogue
scales from 0 'no interest at all' to 100 'most interest ever' completed
at baseline and post-exposure . Additionally, at both time-points, four
items measured susceptibility to use e-cigarettes/smoke cigarettes by
asking participants if they would use an e-cigarette/smoke a cigarette if
offered one by a friend and if they thought they would use/smoke in the
next month . Those ticking anything other than 'definitely not' on a 4-
point scale were considered susceptible to e-cigarette use or smoking,
Ethical approval was granted from a Research Ethics Subcommittee at
King's College London (PNM 1415 61).
The majority of participants were female (63%), British (83%), and of
non-white ethnicities (65%). The NRT group was on average a few months
older than the e-cigarette group (p=0.02) and the e-cigarette group
indicated higher baseline interest in using e-cigarettes than the NRT
group (p=0.04). Mixed two-way analyses of variance therefore adjusted for
baseline differences between groups.
There was no significant group by time interaction for interest in
using e-cigarettes [F(1,62)=0.81, p=0.372, partial eta-squared=0.013] or
smoking tobacco cigarettes [F(1, 61)=0.30, p=0.86, partial eta-squared
<0.001], indicating that interest was not affected by exposure to the
adverts. Non-parametric tests showed no significant change in the
proportion susceptible to using e-cigarettes or smoking (all p>0.1),
any small changes were towards a reduction in susceptibility.
In conclusion, these results from an older age group of adolescents
and using a different control condition corroborate Vasiljevic and
colleagues' finding that there is no evidence of renormalisation of
smoking due to e-cigarette advertising.
1. Vasiljevic M, Petrescu DC, Marteau TM. Impact of advertisements
promoting candy-like flavoured e-cigarettes on appeal of tobacco smoking
among children: an experimental study. Tobacco control 2016 doi:
2. King AC, Smith LJ, McNamara PJ, Matthews AK, Fridberg DJ. Passive
exposure to electronic cigarette (e-cigarette) use increases desire for
combustible and e-cigarettes in young adult smokers. Tobacco control
2015;24(5):501-4 doi: 10.1136/tobaccocontrol-2014-051563.
3. Bogdanovica I, Szatkowski L, McNeill A, Spanopoulos D, Britton J.
Exposure to point-of-sale displays and changes in susceptibility to
smoking: findings from a cohort study of school students. Addiction
(Abingdon, England) 2014 doi: 10.1111/add.12826.