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Unified Industry Position Statement?

Doodlebug

Postman
Joined
Sep 6, 2012
Messages
126
Hi, all,

We have been working with a number of colleagues outside our membership to put together a unified industry position to present to the MEPs. It is our hope that this may strengthen the case, when the politicos can see that the position of the industry is clarified in this way.

The wording is below, and I really hope that you will find that you too can agree to it, and that you will want to pass it on to any and all of your colleagues, so that as many vendors as possible can send this to their MEPs:

"We believe the following guiding principles should be the basis of any future regulatory framework for electronic cigarettes:

a. Electronic cigarettes shall not carry any claims that they are a smoking cessation aid unless they have authorisation to do so under the relevant legislation.

b. All electronic cigarette products must comply with all relevant EU consumer protection, safety and other relevant legislation; electronic cigarette products that do not make medicinal claims are not medicinal products (nor are they tobacco products); we acknowledge the need for proportionate regulation of the quality and safety of electronic cigarettes that allows them to compete with traditional cigarettes; and the Commission should be asked to consider the need for and if appropriate propose further specific and proportionate legislation.

c. All electronic cigarette products shall carry a health message regarding the addictive nature of nicotine and the sale of electronic cigarettes shall be restricted to adults and/or those over the legal age for smoking.

These principles are supported by [insert names of electronic cigarette suppliers and their trade associations].

We support amendments to the EU revised Tobacco Products Directive guided by these principles."

Ultimately, we hope to get a version circulated as widely as possible, and get everyone to literally 'sign on the line', ready for presentation to all members of ENVI, JURI, IMCO, the Commission, the Council and others. If you would like to be involved in this way, please email me at [email protected]. Thank you.

All the best,

Katherine
 
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I think that section C is too widely worded.

"all electronic cigarette products" - which could include drip-tips, atomisers etc.

I cannot see the point of having warnings on atomisers and so on.

Perhaps a better wording would be "all nicotine contaning items for electronic cigarettes" - which would basically cover liquid and pre-filled cartos.

I am assuming that part C has been included as a way of getting this through the EU (by allowing them to impose a 'regulation') - Personally, I think that the clause could be watered down slightly to say that this warning must be included AT THE POINT OF SALE - eg prominantly displayed on a website or in a shop - lets face it there is already so much writing on the side of a 10ml bottle that an additional warning would have to be written in text so small as to make it hardly noticeable.
 
I think that section C is too widely worded.

"all electronic cigarette products" - which could include drip-tips, atomisers etc.

I cannot see the point of having warnings on atomisers and so on.

Perhaps a better wording would be "all nicotine contaning items for electronic cigarettes" - which would basically cover liquid and pre-filled cartos.

I am assuming that part C has been included as a way of getting this through the EU (by allowing them to impose a 'regulation') - Personally, I think that the clause could be watered down slightly to say that this warning must be included AT THE POINT OF SALE - eg prominantly displayed on a website or in a shop - lets face it there is already so much writing on the side of a 10ml bottle that an additional warning would have to be written in text so small as to make it hardly noticeable.
That last point is a good one. Many vendors sell sample bottles (5ml and even smaller) and some do away with all the usual warnings simply because there isn't room on the small bottle. Others half fill a bigger, say 10ml bottle, but profit margins are presumably affected to some degree by doing that.
 
The existing regulations do actually allow for the required information to be 'attached by other means' to the package, if the package size is too small for a sufficiently all-encompassing label.

I agree with you, Matt, but this is not about the details: those are dealt with by other means, and frankly, many of the politicos are not ready for full details yet. (We can only hope there may come a time....)

This was not produced by ECITA, or for ECITA, but we are keen to get behind it and gather as much support as we can for it. It is crucially important that we are able to present a united industry position to the policy-makers. Anything less and they will beat us about the head with it.

Cheers,

Katherine
 
Sorry cant support ECITA on this giving too much away; "We support amendments to the EU revised Tobacco Products Directive guided by these principles."

E Cigs should be OUT of TPD, end of.
 
"All electronic cigarette products shall carry a health message regarding the addictive nature of nicotine". "The addictive nature of nicotine" is only potential. This warning is not scientifically valid.

I don't know any scientific publication establishing that nicotine - alone - would be addictive in humans. Though tobacco use is generally addictive, nicotine use alone not.

I don't know any declaration that any ecig naive user (never smoker) would have become addicted to vaping.
 
I couldn't agree more, and just yesterday, I made exactly this point about the health warning to Rebecca Taylor's assistant. That said, if that's the only thing, and the rest of the amendment basically says "kick it back to the Commission to do the job properly, and insist on the existing regulations being enforced for now", then I hardly think it's worth making a big fight over the wording of the warning.

Yes, it is misleading and inaccurate. But is it worth fighting over, if we can gain the far more important stuff we want? Such as the Commission spending an appropriate amount of time figuring out the right course of action? IMHO, no, it's not.

Ultimately, we shall have to see what the amendments actually say, but from what we're hearing, there will be some that give us what we need, in terms of keeping all of the products we use in our hands, and available to smokers who haven't yet discovered vaping. That is what this has always been about - for me at least - and I am not going to lose my focus on that. To allow it to be derailed just because getting broader support - and votes in Committee - requires a slightly inaccurate and rather misleading health warning would seem a little foolish at this stage.

Cheers,

Katherine
 
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