Big Question 9 - What is the Role of Flavours in Smokeless Products and THR?

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17 September 2024
CHAPTER 2 . THE BIG QUESTIONS

Big Question 9 - What is the Role of Flavours in Smokeless Products and THR?

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KEY SUMMARY POINTS

01

Menthol and fruit flavours are fundamental for adult smokers switching to Smokeless Products with >70% of use in these flavours.[1,2]

02

Flavours, packaging and descriptors that predominantly appeal to the underaged should be banned.

03

Retail enforcement and education is key to ensure the underaged can neither access these products nor use them through social sharing.


Giving adult smokers, who would otherwise continue to smoke, access to satisfying Smokeless Products can be achieved while preventing underage access and usage of these products.

Flavours play a role in all consumer goods products from food through beverages, and tobacco and nicotine products are no different. The flavours in Smokeless Products are used for differentiation to meet different adult consumers’ preferences and to provide sensorial satisfaction.

We believe there is a clear pathway forward to use flavours that further encourage adult smokers to switch and that do not predominantly appeal to the underaged[4]:

  • Flavours must be adult orientated (Figure 1) 
  • Flavours must be safe for consumption
  • Flavours must have factual-style, adult-orientated descriptors 
  • Flavours must have adult-orientated packaging
  • Retail enforcement is required to prevent underage access 
Scientist examining a flask in a laboratory

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"The [Royal College of Physicians] does not recommend the wholesale limiting of flavours accessible to adults. The RCP supports the use of a range of flavours, including fruit flavours [...]. The use of flavours [...] is an integral part of the effectiveness of vaping [...]. Government should restrict flavour descriptors rather than flavours themselves."

 

Royal College of Physicians

Response to the government’s consultation on creating a smokefree generation and tackling underage vaping, 2024[3]

Flavours must be adult orientated

Flavours that have no relevance to adult smokers do not belong in Smokeless Products, especially flavours with predominant appeal to the underaged. The flavours used by adult Vapour Product consumers in the UK in 2023 were assessed by Action on Smoking and Health (ASH) which found that approximately 80% of adults use Fruit, Mint / Menthol, and Tobacco flavours.[2] That’s why we propose limiting flavours to adultorientated flavours and support an outright ban on Smokeless Product flavours such as confectionery, candylike, desserts or soft drink brands.

 

This approach recognises the role of flavours as an important driver of adoption for adult smokers seeking alternatives, while ensuring the removal of specific flavours that appeal predominantly to anyone underage.

Figure 1. Flavour used by adults in the UK

Figure 1. Flavour used by adults in the UK 

ASH Smokefree GB Adult Surveys 2023. Unweighted base: Adults who currently use e-cigarettes=1,079 [2]

Toxicological assessment of our flavours

Our product stewardship process includes a scientific assessment of flavours. We assess our flavours in both consumables (Heated Product consumables, Vapour e-liquids and Oral Nicotine Pouches) and product aerosols (Heated and Vapour Products) to understand the impact on these ingredients the aerosolisation process has.

 

Scientific evidence underscores the importance of flavours to adult smokers making the switch

Vapour Products, which entered the market in Europe in 2006 and the U.S. in 2007, are available with a wide array of e-liquid flavours.

 

A review of U.S. flavour usage was conducted by Mok et al., who ranked an order of ‘mint/menthol’, ‘other flavours’ (e.g. Fruit), and ‘unflavoured / tobacco’ flavour in terms of transitioning away from smoking. This research illustrates the benefit of Vapour Products and flavours in reducing smoking.[5]

Flavours

Proposed Regulatory Framework

• Tobacco

• Menthol

• Mint

• Fruits

• And other adult-orientated flavours

Market Reality Without Regulatory Enforcement

• Energy / Soft Drink

• Sweets

• Dessert

• Underage attracting

Flavours Safety 
Assessment

• Risk-assessed flavour ingredients

• Tested in liquids and aerosols

• Toxicological assessment of flavours

• No safety background for ingredients

• Not tested in either liquids or aerosols

• Unassessed Carcinogens, Mutagens, Reproductive (CMR) toxicants

Science Supporting 

Switching

Clear scientific evidence highlighting which flavours encourage adult smokers switching

Limited evidence that flavours will encourage adult smokers to switch

Adult-Orientated 

Descriptors

Adult-Orientated Descriptors 1
Adult-Orientated Descriptors 2

*Pictured example

Adult-Orientated 

Packaging

Adult-Orientated Packaging 1
Adult-Orientated Packaging 2

*Pictured example

Retail 

Enforcement

• Retail licencing (subject to

market conditions)

• Punitive penalties and

sanctions

• Limited regulatory oversight at retail

• Meaningless enforcement

or unenforced penalties

Figure 2. A framework for flavours in Tobacco Harm Reduction

Flavours must have adult-orientated flavour descriptors

Descriptors for flavours should describe the particular flavour that is in the product in a factual style.

 

Flavours must have adult-orientated packaging

Packaging that looks like sweets or toys doesn’t belong on tobacco or nicotine products. That’s why our packaging is adult-orientated and simplistic in its design, so that it does not appeal to the underaged.

 

Retail enforcement is required to prevent underage access

We support restrictions on where and how tobacco and nicotine products are sold in the UK like the ones used to restrict the sale of alcohol. This would require those who sell vapes, for example, to have a retail licence which would be revoked if they were found to be selling to anyone underage. Retailers would also have to demonstrate to Trading Standards that they observe either Challenge 25 protocols or fit new technologies at point-of-sale locations which verify age, such as facial recognition cameras.

"Use of fruit [...] flavored e-liquids is positively related to smokers’ transition away from cigarettes "

 

Researchers from Australia, U.S., Canada, and UK universities[6]

Recommendations and steps forward

We recognise that flavours in tobacco products have been a topic of public discussion for many decades. This attention is exacerbated by the growing popularity of Vapour Products, specifically in terms of the wide variety of e-liquid flavours available. We believe that it is essential for regulation to strike a clear balance between providing options to suit adult preferences, and ensuring we have responsible marketing practices and technologies to safeguard against underage use. 

 

Flavours play a critical role in ensuring adult consumers have a suitable alternative to more harmful tobacco products, such as combustible cigarettes.

 

Adult-orientated flavours can be instrumental in harm reduction strategies by further encouraging adult smokers who would otherwise continue to smoke to switch to alternatives. Partnered with a successful Underage Access Prevention (UAP) technology and campaign, as well as regulatory oversight, flavours should be recognised as a means to encourage adult tobacco consumers to move down the risk continuum and be considered as part of an holistic Tobacco Harm Reduction approach.


References

[1] Russell C., et al., Changing patterns of first e-cigarette flavor used and current flavors used by 20,836 adult frequent e-cigarette users in the USA. Harm Reduct J, 2018. 15:33. DOI: 10.1186/s12954-018-0238-6

[2] Action on Smoking Health (ASH), Use of e-cigarettes (vapes) among adults in Great Britain. 2023. Available at:

https://ash.org.uk/uploads/Use-of-e-cigarettes-among-adults-in-Great-Britain-2023.pdf

[3] Royal College of Physicians, The RCP responds to the government’s consultation on creating a smokefree generation and tackling youth vaping. 2023. Available at: https://www.rcp.ac.uk/policy-and-campaigns/policy-documents/the-rcp-responds-to-the-government-s-consultation-oncreating-a-smokefree-generation-and-tackling-youth-vaping/ (Accessed: 23 July 2024)

[4] BAT, You want Britain to be smoke-free by 2030. Available at: https://www.bat.com/campaigns/bat-supports-smoke-free-uk-regulators (Accessed: 23 July 2024)

[5] Mok, Y., et al., Associations between E-cigarette use and E-cigarette flavors with cigarette smoking quit attempts and quit success: evidence from a US Large, Nationally Representative 2018–2019 Survey. Nicotine Tob Res, 2023. 25(3): p. 541-552. DOI: 10.1093/ntr/ntac241

[6] Li, L., et al., How does the use of flavored nicotine vaping products relate to progression toward quitting smoking? Findings from the 2016 and 2018 ITC 4CV surveys. Nicotine Tob Res, 2021. 23(9): p. 1490-1497. DOI: 10.1093/ntr/ntab033

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