Monday 30 May 2022

Five "don't miss" resources for World No Tobacco Day.

For the first time in its 35 year history, the theme for World No Tobacco Day addresses the environmental consequences of tobacco use. "Throughout its lifecycle, tobacco pollutes the planet and damages the health of all people," WHO's campaign reminds us

This post provides links to some useful resources to help Canadians observe this important occasion - and some updates on measures governments are taking that will reduce pollution from tobacco industry products. 

#1. UNDO (California Tobacco Control Program)

The California government's Tobacco Control Program is renowned for its hard-hitting public messaging and its effective use of denormalization campaigns to reduce smoking. 

This year it is drawing public attention to both environmental and human health damage caused by the industry. Their core message?  "The Tobacco industry is destroying the people and places we love. And they spend billions to convince us it's normal."

You don't have to live in California to benefit from the resources produced for this campaign:
#2. Talking Trash (STOP & WHO)

The University of Bath's STOP and the World Health Organization have collaborated to share their analysis of the tobacco industry's public relations efforts to present themselves as meeting ESG (Environmental, Social and Governance) objectives. 

"Talking Trash: Behind the Tobacco Industry's Green Public Relations"  traces some of the steps taken by these companies to present themselves as responsible stewards of the environment, and how it perverts the notion of sustainability. 

These tactics are familiar to Canadians. Philip Morris International's Canadian subsidiary, for example, uses its #unsmoke tree-planting and cleanup campaigns to greenwash its presence.  

The solution, say WHO and STOP, is for governments to ban such activities "as they are a central part of the industry’s so-called CSR [Corporate Social Responsibility] and marketing campaigns, aimed at industry renormalization, which tends to circumvent Article 5.3. Parties are obliged to end industry CSR under the WHO FCTC, so unlike other industries, there is a mechanism in place to help governments prevent tobacco industry greenwashing."

They also have a message for civil society organizations -- calling on them "to reject partnerships on environmental activities with the tobacco industry that could be used to help the industry portray itself as an environmental ally."

This project is also spreading the word through the international media. Last week the Guardian published their column Big Tobacco is killing the planet with plastics. No smokescreen should be allowed to hide that.

#3. Research summaries 

Five years has passed since the World Health Organization published a comprehensive review of the environmental impact of tobacco products, and this document remains a key resource on this topic. In addition to documenting widespread harms, the report offers a range of options for  governments and communities to address these problems. 

Public Health Ontario has also produced a valuable summary of research on the effectiveness of strategies and policies aimed at reducing environmental impact. Its knowledge synthesis report Smoke Free Series: Post-Consumer Waste is linked here. 

#4. Tips on dealing with E-waste

E-cigarettes and e-liquid containers are considered acute hazardous waste by U.S. environmental regulators, although not yet designated in this way in Canada. The nicotine in discarded containers is a potential source of poisoning (to humans and other living beings), and the batteries, if not properly disposed of, can also release harmful chemicals. Safe disposal is a particular concern for schools and other places where these products are discarded (or confiscated). 

Guidance offered for U.S. schools and communities provide a model for resources that could be developed for use by Canadians.

#5. Innovative public policies

Governments world-wide are exploring new ways to address cigarette and tobacco product waste:

Friday 20 May 2022

This year, the average Canada Pension Plan contributor holds a $17 investment in tobacco stocks

This week the Canada Pension Plan Investment Board provided Canadians with an update on the value of Canada's largest public pension plan. Among the $539 billion in assets managed by the board, it reported shareholdings in tobacco companies worth $343 million. 

This post provides an update on these investments.

CPPIB's role as fund manager

The Canada Pension Plan is a public pension plan administered by the federal government for workers in all provinces except Quebec, where the equivalent Quebec Pension Plan is in place. By law, this year each Canadian worker aged 18 to 70 must contribute 5.7% of their earnings as a contribution, up to a maximum contribution of $3,499. Employers must match that contribution, and the self-employed pay both amounts. The CPPIB currently counts 20 million contributors and beneficiaries

The CPPIB was established twenty five years ago (1997) by the federal government for the purpose of administering contributions without political interference. Since 1999, CPPIB investments have included shareholdings in publicly traded companies in Canada and elsewhere.

The independence of the CPPIB from government interference is reflected in the legislation which established it. The same legislation, however, gives governments the right to set regulations on the investments that the board may make, provided that these are supported by two-thirds of the provinces representing two-thirds of the population. (section 53.)

CPPIB policies on investing in tobacco

When the CPPIB was established in 1999, Parliamentarians expressed concern about the need for ethical guidelines on investments. A year later, then finance minister Paul Martin reported to the Commons that the issue of investments in tobacco companies was "under discussion by officials at both the Canadian government level and the provincial government level." By inference, those discussions did not result in decisions by governments to offer direction on ethical investment.

The CPPIB eventually adopted its own  Policy on Sustainable Investing. This policy does not currently single out industries for exclusion from investments, although the Board has previously refused to invest in landmines and cluster munitions. Currently, investment exclusions result from the CPPIB's determination that: "management’s strategy or lack of engagement with ESG issues undermines the long-term sustainability of the business; Where brand and reputation considerations from ESG factors may generate risk impacts beyond expected risk-adjusted returns; and  Legal considerations."

The CPPIB seeks to enhance environmental, social and governance (ESG) goals through engagement, and it reports it has "supported over 50 shareholder proposals at tobacco companies requesting improved disclosure and standards on a range of ESG factors, including health impacts and human rights-related matters."

The board  makes public how it votes on these shareholder motions. From these reports, we know that this year the Board voted against a motion at the annual meeting of Philip Morris International that would have requested the board to "initiate steps to phase out all production of PMI’s health hazardous and addictive products by 2025."

CPPIB investments in tobacco companies

Over the past 5 years, the CPPIB has reduced its direct investments in tobacco companies, which are now one-fifth the value that they were in 2017 (from $1.748 billion in 2017 to $343 billion in 2022). During the same period, investments in foreign equities grew from $110 billion to $137 billion. The proportion of the foreign equity portfolio represented by tobacco stocks thus fell from 1.6% in March 2017 to 0.25% in March 2022. 

The number of tobacco companies in which the CPPIB directly invests has been reduced from 12 in March 2018 to four this year, of which two  (Philip Morris International and Japan Tobacco) are multinational cigarette companies.

The figure below and supporting data are available for download here

Tobacco companies generally distribute their profits through dividend payments to shareholders. On the basis of its current holdings, the CPPIB would have received about $16.7 million in dividend payments on its tobacco holdings, most of which ($13.6 million) would have been paid by Philip Morris International. 

The investment policies of other Canadian pension funds

The CPPIB is the largest, but not the only pension fund administered for Canadian workers. Among the largest ten funds, the CPPIB is one of only three who do not reject tobacco investments, as shown in the ranked list below. Provincial plans in Ontario, Quebec and Alberta are largely tobacco-free. 

#1  Canada Pension Plan Investment Board (CPP Investments) - 
#2  Caisse de dépôt et placement du Québec (CDPQ) - TOBACCO FREE
#3  Ontario Teachers’ Pension Plan (OTPP) -  TOBACCO FREE
#4  Public Sector Pension Investment Board (PSP Investments) - 
#5  British Columbia Investment Management Corporation (BCI) - 
#6  Alberta Investment Management Corporation (AIMCo) - TOBACCO FREE
#7  Ontario Municipal Employees Retirement System (OMERS) - TOBACCO FREE
#8  Healthcare of Ontario Pension Plan (HOOPP) - TOBACCO FREE
#9  Investment Management Corporation of Ontario (IMCO) - TOBACCO FREE
#10 OPSEU Pension Trust (OPTrust) - TOBACCO FREE

A backgrounder on public pensions and tobacco in Canada can be downloaded here.  

More information is also available at Tobacco-Free Portfolios. 

Monday 16 May 2022

The Philippine's graphic health warnings for e-cigarettes come into force -- or do they?

The Philippines was in the news last week, with the election of a new president with a familiar name: Ferdinand ('Bongbong') Marcos, Jr. 

This election happened on the very week that new restrictions on vaping products were due to come into effect -- adding more uncertainty to the future of that country's tobacco laws.  The post reports on these innovative regulations that may - or may not - set a global first for tobacco control.

2020: The Philippines adopts major reforms to its vaping laws 

In 2020, the Philippine government strengthened controls on the marketing of vaping products in several ways:

  • the minimum age for sale of tobacco and vaping products was raised to 21 years
  • excise taxes on e-liquids were imposed
  • requirements for health warning were extended to vaping products, effective 2022 
  • flavourings were banned, other than 'plain tobacco' and 'plain menthol', effective 2022 
2021: Fierce lobbying leads Philippine's Congress to roll-back legislation  

These restrictions became the object of a sustained lobbying campaign aimed at both houses of the Philippine Congress and by the end of 2021, a majority of legislators had called for some of these measures to be withdrawn. 

Both chambers of the Philippine Congress passed laws which would relax these provisions (Senate Bill 2239 and House Bill 9007). In addition to returning the age to purchase e-cigarettes or heated tobacco from 21 to 18, the law would also remove regulatory authority over these products from the  Food and Drug Administration (FDA) and place them under the authority of the Department of Trade and Industry (DTI). It would remove flavor restrictions on e-liquids and allowing more corporate promotions by tobacco companies.

2022: The out-going President has stalled the roll-backs, but the future is uncertain

The Congress' proposals to relax restrictions on vaping products were sent to the President of the Philippines, Rodrigo Duterte, who had the authority to sign them into law or to veto them. 

The Ministry of Health was reported as opposing these initiatives and President Duterte has neither signed nor vetoed these proposals, despite significant lobbying for him to do so. On July 1st, he will hand over to President-elect Marcos.

With so much this issue surrounded by uncertainty, controversy and politics, last week's deadline for e-cigarettes sold in this Pacific archipelago to begin displaying graphic health warnings and to cease being flavoured with anything but tobacco and menthol has passed by without much mention.

Administrative Order 2

May 2022: The Philippine requirements for graphic warnings that were set for implementation   

It was 8 years ago that the Philippines required graphic health warnings on tobacco products (Graphic Health Warnings Law, Republic Act No. 10643). This obligation was extended to vaping product manufacturers as part of a tax law (Republic Act No. 11346), and a  Joint Memorandum of Finance and Health Ministries issued in November 2020, giving manufacturers 18 months to comply. 

Instructions for new warnings were set by an administrative order issued last November (Department of Health Administrative Order No. 2021-0054), which came into force on May 11, 2022.  (The order also includes similar requirements for graphic warnings for heated tobacco). Warnings must cover the lower 50% of each principal display space, and a separate text message is mandated for side panels. These warnings are required for 2 years, after which new instructions will be issued

Twelve warnings are required, covering 10 health effects: asthma, explosion injury, lung damage, eye irritation, exposure to toxic chemicals, cancer, exposure to second hand emissions, nicotine poisoning, throat irritation and pneumonia.  

On the side panel of each package, Quit-line information is provided with the encouragement to "Quit Vaping", as well a notice that sales to people under 21 years of age is forbidden. 

Message required on side panel
of vaping products sold in Philippines

May 2022: The flavour restrictions that were also due to come into force

Restrictions on flavourings were contained in the same Joint Memorandum that clarified warnings requirements. As with the warnings, this requirement came into force on last week.  

The Philippines has taken a similar approach to that proposed by Health Canada last year -- allowing tobacco and menthol flavourings. It is more restrictive than the proposed Canadian restriction in that these flavourings must be "plain tobacco" and "plain menthol" -- no mixture of the two flavours is permitted, nor are "mint" flavourings.  

It seems probable that these restrictions, like those for warning labels, will not be observed as officials "wait and see" how the outgoing and incoming Presidents decide on the Congress' proposal to roll-back vaping regulations. 

The bumpy road to health regulation 

It is not yet clear whether the Philippines will become second country to require graphic health warnings on e-cigarettes (South Korea issued requirements in late 2018), or the 5th country to implement national level flavour restrictions (following Finland, Estonia, Hungary and Denmark). 

Regulatory progress -- especially innovative and ground-breaking regulations -- too frequently experience political set-backs. Canada is not immune to this:  following an election in 2018, the Ontario government refused to implement vaping regulations passed under a previous government (although it later changed its mind), and last month the British Columbia government quietly rescinded its own innovative  restrictions on vaping product packaging. 

B.C.'s ban on designs on vapour product packaging
was rescinded in April 2022. 

Selected research and resources 

Fact sheets:

Research on graphic warnings on vaping products

Brewer NT, Jeong M, Hall MG, et al.  Impact of e-cigarette health warnings on motivation to vape and smoke. Tobacco Control 2019;28:e64-e70.

Villanti AC, LePine SE, West JC, Cruz TB, Stevens EM, Tetreault HJ, Unger JB, Wackowski OA, Mays D. Identifying message content to reduce vaping: Results from online message testing trials in young adult tobacco users. Addict Behav. 2021 Apr;115:106778. doi: 10.1016/j.addbeh.2020.106778. Epub 2020 Dec 11.

Stevens EM, Keller-Hamilton B, Mays D, et al. Optimizing Images for an E-Cigarette Messaging Campaign: Liking and Perceived Effectiveness. Int J Environ Res Public Health. 2021;18(24):12989. Published 2021 Dec 9. doi:10.3390/ijerph182412989

Li W, Vargas-Rivera M, Ebrahimi Kalan M, Ben Taleb Z, Asfar T, Osibogun O, Noar SM, Maziak W. The Effect of Graphic Health Warning Labels Placed on the ENDS Device on Young Adult Users' Experience, Exposure and Intention to Use: A Pilot Study. Health Commun. 2022 Jun;37(7):842-849. doi: 10.1080/10410236.2021.1872158. Epub 2021 Jan 21.

Monday 9 May 2022

BAT 'shakes things up' - adding haptics, tracking apps and more flagship stores to promote VUSE in Canada.

In the four years since vaping products were legalized for sale in Canada (May 2018), multinational tobacco companies have deployed a variety of tactics to persuade Canadians to purchase their pod-style vapes. Many of the ad campaigns which were described here earlier have largely disappeared, including television advertising, point of sale promotions, billboards and transit ads. Other tactics - like social media promotions, packaging and branding, free giveaways, and health reassurance campaigns-- remain, although some content has been changed after federal regulations on promotions came into effect in the summer of 2020.

This post looks at some of the new marketing elements BAT is engaging to encourage the use of its VUSE vaping, and how these relate to federal restrictions on vaping promotions.

1) The power of connectivity.

At the beginning of the month (May 1), BAT launched a brand new VUSE device, the VUSE ePod 2+. The novelty is not in the appearance of the device (it looks identical to the previous ePod 2) but in its engagement with the Internet of Things. 

This version of BAT's leading vaping device, the ePod is called the ePod 2+. Unlike the others, it includes Bluetooth technology to allow the device to be linked to the user's smart phone or computer. This is done using BAT's specially designed app, which allows the user to control the amount of cloud produced by the vaping device, as well as allowing the device to be tracked (electronically monitored) and remotely locked (electronically controlled). 

BAT/Imperial Tobacco's privacy policy identifies a number of ways in which this data will be collected by the company. In addition, for those using iPhones or other Apple products, the Vuse app can only be managed through another app - Nuviu, which acknowledges that usage data is collected, although not linked to identity. Another red flag about this development is that the company which manages the interface of vapers with the internet is as new as the vaping product it is monitoring: Nuviu Products Limited, was incorporated only a month ago (April 7, 2022).

2) Haptics: the science of touch

The new ePod 2+ has another novel feature -- it vibrates at certain moments to let the user know when the device has been turned on or locked/unlocked. The company encourages users to "Engage all the senses" -- adding touch to the look, smell, and taste of vaping. 

In this drug-delivery device, BAT is already using taste and smell (flavours), and sight (decorations and visual imagery) as reinforcers for the nicotine experience. Will music be next?

3) Branded storefronts and flagship stores 

Not quite two years ago (September 2020), BAT/Imperial Tobacco opened its first VUSE flagship store in Toronto. This March, the company informed the CCAA proceedings that three additional stores have been opened and that it plans to run 12 branded stores by the end of 2022. 

One of these stores opened in down town Ottawa this month (137 Rideau Street), with the same general interior layout as the Toronto store (shown below).  

These stores represent a major investment by the company (large enough to warrant disclosure to the insolvency court). Courts were told that the average lease deposit was $100,000 -- the retail value of 14,000 pods or 7,000 devices. With foot-traffic of only a handful of people an hour, the business case for these high-end stores is clearly not based on sales returns from those venues. 

4) Personalized decorations

Among the offerings at the Vuse store is the option to add personal decorations and engravings to the vaping device. Engravings can be designed by the consumer or executed by a VUSE representative. Those displayed in the stores demonstrate the impact of this personalized no-cost added-value. Other personalizations and decorations -- full colour 'skins' and ornamental rings are also available at a charge. 

VUSE X U  ​is the BAT trademark used to promote personalized design of devices "Make it truly yours in every way,"  consumers are encouraged by Instagram posts and other advertisements,  "with new personalization options from Vuse X U. Think colourful skins, adjustable rings and more engraving choices than ever before." 

5) Branded flavours

One of the ways in which BAT is responding to a potential curb on vaping flavours in Canada is by expanding its range of flavours that it expects will be permitted -- menthol-mint and tobacco. In two years the number of tobacco/mint/menthol flavours on offer by this company has grown from 2 to 13. 

In January 2020, BAT sold only one tobacco flavour in Canada for its ePod device (Tobacco Marvel), although a year later it had launched 3 more. All of these had the word "tobacco" in the flavour name. Today, the company offers  7 'tobacco' flavours, of which only two have tobacco in the flavour name. The flavours are:  Carmelina Mix, Morado Mix, Velvety Mix, Exotic Mix, Rich Mix, Golden Tobacco and Smooth Tobacco.

In January 2020, BAT sold only one mint flavour in Canada for its ePod device (Polar Mint), although a year later it had launched 2 more. Today, the company offers 6 mint flavours in Canada: Fresh Spearmint, River Mint, Forest Mint, Polar Mint, Smooth Mint, Cool Peppermint. 

Increasingly, these flavours are  'branded' with trademarked names that do not describe the flavour so much as provide it with an association that the company can market - 'river mint', 'forest mint', 'carmelina mix', 'morada mix', 'exotic mix'. 

The regulatory context

Although there is no public report of Health Canada raising concerns about these marketing efforts, it is not evident that they are all consistent with the federal Tobacco and Vaping Products Act or the Vaping Products Promotion Regulations

* The Flagship stores display a brand element (the VUSE trademark) in a way that they can be seen by young persons, although this is prohibited under section 2(1) of the regulations.
*  The designs and haptic features are likely to make the device appealing to young persons, although such features are prohibited by section  23.3 of the law.

In drafting the federal tobacco and vaping laws, the government chose a more permissive structure than for tobacco. All tobacco promotions in Canada are banned unless specifically permitted, but the same law permits all vaping promotions unless they are specifically prohibited.  This may have encouraged BAT to launch VUSE-branded stores, even though the federal government has previously required Philip Morris to remove the IQOS name from its Flagship stores for its heated tobacco product. 

Another challenge facing regulators is that vaping companies have more resources and fewer impediments to developing new marketing activities than governments have in responding to them. Ad campaigns can be launched within weeks, but it takes years for regulations to be developed. Many regulations do not survive the initial stages: Health Canada's plans to limit the way in which packaging and designs could be used to promote  vaping were made public in April last year, but were shelved last month.

Thursday 5 May 2022

New survey results show no decrease (and some areas of increase) in tobacco use and vaping

 On May 5, Statistics Canada released results of the third wave of the Canadian Tobacco and Nicotine Survey., in which almost 10,000 Canadians reported their use of tobacco and vaping products. (Top-level results of prior waves, with smaller samples, are available on Health Canada's web-site, and other analysis was reported here earlier). 

This blog presents graphs showing the results of this survey in the context of previous versions of Health Canada's tobacco use surveys.

Very little change overall

Statistics Canada reported very little overall change in vaping behaviour among Canadians as a whole, with mostly unchanged proportions of Canadians who had ever tried a vaping device, who were using one in the past month or who were using one daily. The one significant change they highlighted was the growing proportion of current vapers who were using daily -- up from 44% to 55% between 2020 and 2021.

No change in teen-vaping, but an increase in vaping among young adults.

The good news is that the increase in youth vaping observed after the market was legally opened 4 years ago has stalled. Over the past 2 years, this survey has not observed a statistically significant increase in vaping among teenagers or adults over 25

Vaping rates among young adults, however, have increased. Many of those who were in this age group this year would have surveyed as a teenagers when this survey began. Whether these are the same young people who would have been teenagers in previous surveys or whether they are Canadians who start to vape as young adults will not be known until the survey's full data set is released and analyzed. 

No decrease in smoking for any age group.

The CTNS did not observe a reduction (or increase) in cigarette smoking overall, nor for any age group.

Increased overall nicotine use among younger Canadians

The introduction of e-cigarettes in 2018 complicated the picture of Canada's progress against tobacco use. The age group which has most reduced smoking (adults over 25) is the group with the least use of e-cigarettes. For younger age groups, overall nicotine use has returned to levels higher than they were in 2018. 

Sources for data above:

CTUMS. Canadian Tobacco Use Monitoring Survey, 1999-2012:

CTADS. Canadian Tobacco Alcohol and Drug Survey, 2013, 2015, 2017. 

CTNS. Canadian Tobacco and Nicotine Survey, 2019-2020; and 2021

Monday 2 May 2022

Health Canada trims its tobacco control sails

Last week two more documents were released by Health Canada which set out how the department plans to address the health consequences of tobacco use and vaping. The first is Health Canada's Forward Regulatory Plan for 2022-2024, and the second is the internal evaluation of Health Canada's activities, including management's response to the recommendations made by the evaluators. These, together with the Departmental Plan that was released in March, and revisions to Canada's Tobacco Strategy, released in February, reflect evolving federal priorities for this file.

This post reports on these four documents.



In the official plan made public last week, Health Canada reports that it is working on 5 new regulations under the Act:

The new regulatory plan includes 3 key changes from the plan released this time last year (available on the third-party legacy website
  • Health Canada has dropped plans for regulations on vaping product package and design features. These regulations, which appeared on last year's list, would have placed "certain limits on what promotional elements can appear on vaping product packages. They would also impose restrictions on design features that are appealing to youth to prevent their use in the manufacture of vaping products." They no longer are part of the department's plans. 
  • Reporting regulations for vaping and tobacco manufacturers will be combined. ("They would merge the two sets of reporting regulations into a single one."). 
  • The department is no longer indicating when it will finalize regulations on vaping flavours.  Federal measures to ban the sale of vaping liquids that have flavours other than mint-menthol or tobacco (and to prohibit additives other than a specified list associated with these flavours was pre-published in Canada Gazette last June, along-side a companion regulation for Cannabis products. Health Canada regularly provides timelines in its forward plan -- but for this regulation there is no hint on when the next steps will be taken. 


The 2022-2023 work-plan made public by Health Canada contains a more ambitious list of federal actions on tobacco and vaping than those of recent years. (A comparison of the plans from 2018-2019 to 2022-23 can be downloaded here).

Among the activities identified for action in the coming year are:
  • the regulatory developments listed above
  • raising awareness and public education of the potential harms associated with vaping, particularly for youth;
  • monitoring national trends in vaping and smoking and conducting public opinion research to better understand youth vaping.
  • compliance and enforcement activities of websites, social media, retailers, manufacturers and importers. 
  • modernizing the Pan-Canadian Quitline and developing voluntary standards for smoking cessation
  • public education activities to raise awareness of smoking cessation resources.
  • providing up to $3.5 million for "community organizations that undertake prevention, protection and/or cessation efforts vs. the use of tobacco and vaping products."
Health Canada highlights new activities
to address tobacco use and vaping.

The annual Departmental Plans trace an evolution in Health Canada's public approach to vaping products. In the first two years after legalizing vaping products, the department planned "work towards addressing the risks and potential benefits of vaping products." (emphasis added) After 2020, identification of "potential benefits" had been dropped and measures to "address the rapid rise in youth vaping" were added. This year the department also identifies activities to support cessation efforts by vapers. 



Following guidelines for all  federal departments, Health Canada's programs are periodically evaluated for their relevance, results and efficiency. The 5-year review of the department's tobacco control efforts was scheduled for 2021, and the report "Evaluation of the Health Portfolio Tobacco and Vaping Activities 2016-17 to 2020-21" was released on April 26, 2022.

This 57-page report is rich with detail, and offers an explanation of the structure and function of the department's work that has not previously been disclosed. In developing the report, the evaluators reviewed 500 internal files and conducted interviews with 46 key informants from which they developed their analysis and made their recommendations. 

It is in the management's "response and action plan"  to these recommendations that more detail is provided for activities over the next few years.

The recommendations with which Health Canada's management agreed. 

In the final version of the evaluation report, 4 recommendations are made. The "Management Response and Action Plan" (MRAP) shows agreement with all of these recommendations and the steps that will be taken to implement them.

#1  Communicate to partners and stakeholders Health Canada's action plan for the Department's contribution to achieving CTS goals and for addressing youth vaping.
* The department will establish interim targets for smoking prevalence in 2025 and 2030  by April 2023 and communicate them by September 2023.

#2. Enhance information technology systems and data analytics capacity to support program activities.
* Health Canada will migrate to a new IT system (National Integrated Compliance & Enforcement Management Solution (NICEMS - IP 626)) by September 2023. 

#3 Examine resource distribution between tobacco and vaping activities.
* Health Canada will establish "a risk-based approach for compliance and enforcement activities for tobacco products and vaping products" by December 2022.

#4 Review and update the Health Canada website to reflect the most up-to-date science and public health advice on health risks and benefits of vaping.
* Health Canada will review its website by last week (April 30) and will update it by August 31, 2022. A process for regular review will be established by the year's end.

The recommendations with which Health Canada's management did not agree.

An earlier draft of the evaluation report (dated August 2021) made 5 recommendations, two of which did not survive in the final report (dated December 2021)

The first recommendation was reworded, to remove reference to the need for the department to have a "clear path" and "action plan" in order to reach the 5% prevalence target. This echoed an analysis by Les Hagen and Robert Schwartz that was published last fall (Is “less than 5 by 35” still achievable?) . 

This recommendation did not appear in the final evaluation, and was replaced instead with one that focused on communication, not planning. 

Original text: Recommendation 1: Develop a detailed action plan for achieving CTS goals and for addressing the rise in youth vaping. The goal of less than 5% tobacco use by 2035 is an ambitious target and Health Canada has not articulated a detailed action plan for reaching it. While the program does have some operational and performance measurement documents, they do not set out a clear path for reaching the long-term goal or include interim targets. With the rapid rise in youth vaping, it is also important for Health Canada to articulate a plan to address it. It would be helpful to develop a comprehensive action plan that includes short-, medium- and long-term targets for reaching the CTS goal and for youth vaping. Collaborating with key stakeholders in the development of this plan could bring helpful perspectives and create cooperation and buy-in from relevant groups.

Final text: Recommendation 1: Communicate to partners and stakeholders, Health Canada’s action plan for the department’s contribution to achieving CTS goals and for addressing youth vaping. Health Canada and its partners have an ambitious target of less than 5% tobacco use by 2035. In addition, youth vaping rates remain a concern. While Health Canada does have internal planning and performance measurement documents related to both these issues, these plans have not been communicated to stakeholders in an integrated way. As a result, some key stakeholders have the impression that Health Canada has not defined a coordinated, department-wide plan. Several key informants indicated that having knowledge of Health Canada’s plan could help inform their own work and the work of other groups, and help assess progress on the issues of tobacco use and youth vaping. In communicating this plan, Health Canada should coordinate with Health Portfolio partners and key stakeholders to facilitate cooperation and buy-in from relevant groups.

The fourth recommendation in the draft report related to the benefits of additional regulations, in line with the recommendations of the Chief Medical Officers of Health, was deleted altogether. 

Original text:  Recommendation 4: Building on the regulatory work currently underway, consider additional regulatory options to help address the rise in youth vaping, and support program objectives and needs. The program has already moved forward with many new regulations to help address youth vaping. As the program continues its regulatory work, attention should be given to explore recommendations for action related to vaping made by the Council of Chief Medical Officers in 2020. The program should also explore ways for regulations to further support compliance and enforcement activities, for example through a wider range of enforcement tools, as well as supporting research and surveillance activities through industry reporting.

Final text:  (No such recommendation is included)



In May 2018, Health Canada replaced the Federal Tobacco Control Strategy, which had been in place since 2001 with a revised Canada's Tobacco Strategy. In February 2022, that 2018 document was  officially archived, and replaced with new text on the department's website

The revised version is very concise -- with only 480 words it is less than half the length of the 2018 version (1,130 words) and one-sixth as long as the FTCS (3,150 words). As shown in a side-by-side comparison of the two texts (downloadable here), the approach - or its description - has evolved over the past four years:
  • Harm Reduction is being re-framed. The term "harm reduction" has been dropped, although the concept of vaping product offering "a less harmful option than smoking" remains.
  • Some regulatory directions have been dropped. There is no longer reference to plans to "further reduce the appeal and addictiveness of tobacco, including taxation, price-interventions, and the regulation of nicotine content."
  • Working with Indigenous groups has been reworded and given higher profile.
  • Reference to industry accountability has been dropped.