Read our submission, written by Dr Eric Crampton to The Ministry of Health. This submission is in response to the public consultation document, Smokefree Environments and Regulated Products Act 1990: Proposals for regulation.

In summary: The Initiative has, over the past several years, undertaken research into tobacco harm reduction policies because of our concern for the inequities caused by the existing tobacco control regime. That research includes Smoke and Vapour: The changing world of tobacco harm reduction (2018) and The Health of the State (2016). We have maintained a watching brief in this policy area and regularly provide public commentary on policy developments. We also submitted on the Smokefree Environments and Regulated Products (Vaping) Amendment Bill in April 2020.

We worry that many of the proposed regulations risk making it harder for smokers to shift to less harmful alternatives. It will be more difficult for potential vapers to find their preferred products, to find advice about alternatives, to be informed about developments in the product area, and to find places in which vaping is permitted. All of these will make vaping relatively less attractive and risk discouraging switching.

While there are trade-offs that need to be managed in some cases, like discouraging youth uptake while encouraging adult smokers to switch to vaping, in other cases the regulations will make vaping more difficult to little benefit.

In this submission, we have appended Bates and Sweanor's submission on the Canadian regulations, and endorse it.