Health Canada and Imperial Tobacco Canada Ltd. Meeting – June 5, 2024

Subject(s)

Imperial Tobacco Canada Ltd. (hereinafter referred to as "ITCAN") requested a meeting to present to Health Canada regarding the ingredient list in the draft regulations to restrict flavoured vaping products, to provide observations regarding the Quebec market following its ban on flavoured vaping products, and to propose additional measures to address youth vaping.

Date

June 5, 2024

Participants

Health Canada (HC)

• Sonia Johnson (Chair), Director General, Tobacco Control Directorate (TCD), Controlled Substances and Cannabis Branch (CSCB)
• Sally Gibbs, Acting Director General, Consumer Products and Controlled Substances Directorate (CPCSD), Regulatory Operations and Enforcement Branch (ROEB)
• Mathew Cook, Acting Director, Tobacco Products Regulatory Office (TPRO), TCD, CSCB
• Sophie Corriveau, Acting Associate Director, Office of Compliance for Tobacco and Vaping Products and System Configurations Unit, TCD, CSCB
• Alain Richard, Acting Associate Director, Tobacco, Vaping and Controlled Substances Division, CPCSD, ROEB
• Senior Manager, Tobacco and Vaping Compliance Enforcement Program, ROEB
• Manager, Regulatory and International Policy Unit, Office of Policy and Strategic Planning (OPSP), TCD, CSCB
• Policy Analyst, TPRO, TCD, CSCB (Observer)
• Junior Policy Analyst, International and Regulatory Policy Unit, OPSP, TCD, CSCB (Observer)
• Junior Policy Analyst, International and Regulatory Policy Unit, OPSP, TCD, CSCB (Secretariat)

Imperial Tobacco Canada Ltd. (ITCAN):

• Mathieu Nadon, Chief Marketing Officer
• Sabrina Chartrand, Senior Manager, Government and Regulatory Affairs
• Gavin Mullard, Senior Regulatory Engagement Manager

Introduction

A meeting was held at the request of ITCAN to discuss the ingredient list in the draft regulations to restrict flavoured vaping products, to provide observations regarding the Quebec market following the provincial ban on flavoured vaping products, and to propose additional measures to address youth vaping.

Health Canada (HC) read a transparency and openness statement, reminding ITCAN representatives that the meeting is subject to disclosure as per HC's Openness and Transparency policies. In the interest of transparency, the Department stated that it would be making a record of the meeting publicly available. The handling of information and privacy notice was mentioned and acknowledged.

HC referred to Article 5.3 of the World Health Organization Framework Convention on Tobacco Control, its international obligation to protect tobacco control policies from the vested interests of the tobacco industry. It was acknowledged by ITCAN representatives.
The Chair then invited participants to introduce themselves.

Subjects

ITCAN's presentation included information on the following:

Draft ingredient list outlined in the draft regulations to restrict flavoured vaping products

• ITCAN expressed concerns that functional ingredients that are important for the formulation of vaping e-liquids have been overlooked since they were not included in the draft ingredient list.
• According to ITCAN's methodology, the draft ingredient list omits the inclusion of natural occurring compounds for permitted flavours.
• ITCAN raised concerns pertaining to the toxicology of certain ingredients included in the draft ingredient list, i.e. being unsafe due to being classified as having carcinogenic, mutagenic or reprotoxic properties.
• ITCAN expressed the need for a quality assurance standard on the ingredients used in the manufacture of vaping products in Canada. These ingredient standards exist in other international jurisdictions.
  • ITCAN proposed implementing a list of prohibited ingredients in e-liquid formulations. This would include ingredients that are toxic.

Compliance and enforcement of flavoured vaping products

• ITCAN raised concerns regarding the need for stricter manufacturing compliance and enforcement programs given what they have observed in the market.
• ITCAN reported having observed increased illegal vaping market activity following the ban of flavoured vaping products in Quebec. They have also noted an increase in non-compliant products at retail outlets and amongst smaller manufacturers and distributors, according to in-house market data.

Additional measures to address youth vaping

• ITCAN suggested that HC explore additional measures to address youth vaping such as:
• Increase inspections and penalties for current regulations that address youth vaping (e.g. promotion, nicotine concentration)
• Increase youth education
• Strengthen regulation of online sales
• Place restrictions on the sale of disposable vaping products and volume limits on individual products sold

In closing, ITCAN reiterated they work with multiple partners to try to prevent and reduce youth vaping. ITCAN also emphasized the need for government to establish stricter enforcement programs to target non-compliant products from smaller manufacturers and distributors.

Conclusion

The meeting was then concluded.

Documents

• Agenda as provided by ITCAN.