Category: This Issue

  • The Soul of Vaping

    The Soul of Vaping

    So Soul, the rapidly rising vapor brand that began in China in early 2021, has now gone global.

    By Timothy S. Donahue

    Luna Wang wanted to do something different. She was seeing the products that the vapor industry was offering in early 2021, and she could tell that the industry was changing. Disposable devices were becoming the most popular products to help combustible cigarette smokers quit, but the available devices didn’t offer the same flavor or vaping experience that one could get from an open system. Luna Wang wanted to create something better.

    Wang has been in the vaping industry for eight years through various projects. In mid-2021, Wang joined forces with another experienced vapor industry entrepreneur, Peter Zhang. Both also had previous experience working with Fortune 500 companies. Together, they started the So Soul brand in Shenzhen, China, the global capital of e-cigarette manufacturing.

    So Soul soon entered the Chinese market, where more than 300 million smokers reside, and quickly found success. While the company also produces refillable pod products, it was its disposable products that really began to boost So Soul’s sales.

    “So Soul is a creative and dynamic vape brand which believes that innovation could bring freedom of the soul. So Soul has been a maverick and an unconventional company from the beginning,” said Lisa Li, head of media relations for So Soul. “Our founder, Luna, and the rest of the company’s employees are often considered dreamers. We believe that you shouldn’t have to compromise style for substance.”

    So Soul began because its creators believed something was missing in the market. Aside from a device’s appearance, aroma and flavor were two areas that Wang and Zhang felt were lacking in the Chinese vaping industry. The company founded its own research and development laboratory, staffed by the world’s top experts in the field, to develop products that could meet Wang’s high standards.

    “Our line of products offers smokers and vapers alike a range of flavors that are rich, smooth and satisfying. Our designs are inspired by the latest trends in fashion, and we’re always looking for new ways to stand out from the crowd,” said Wang. “Whether you’re a beginner or a seasoned vaper, we’ve got something for everyone.”

    The company devotes 60 percent of its profits to R&D in an effort to always be improving. It wants its products to stand out for their “combination of style, substance and soul,” explains Wang. “We are dedicated to providing our customers with products that are not only stylish and cutting-edge but also made with the highest quality ingredients and backed by extensive research and development.”

    During World Vape Expo Dubai, Wang told Vapor Voice that So Soul has perfected the art of flavor creation, and subtle “fragrances are at the heart of our products.” To accomplish the feat, Wang said that So Soul employs a team of expert mixologists that have years of experience in tobacco product development, and the company only uses the finest ingredients to create its unique flavor blends.

    “Our designs are inspired by the latest trends in fashion, and we’re always looking for new ways to stand out from the crowd. Whether you’re a beginner or a seasoned vaper, we’ve got something for everyone,” said Wang. “In a short space of time, we have already become one of the most popular brands in China. And now we’re bringing our products to the world. We strive to always be at the forefront of the latest technology. Our factory in Shenzhen employs over 1,000 professionals who share our commitment to quality and innovation.”

    An estimated 3 million customers worldwide have tried So Soul’s products. The company prides itself on being a one-stop-shop for all vapers from beginners to advanced nicotine consumers. Wang said that So Soul product users are stylish, creative and aim to present a safer, cheaper alternative to smoking cigarettes. So Soul offers vaping devices with an advanced mesh coil system and that range in volume from 2 mL to 5 mL of nicotine-based e-liquid.

    The company also offers devices that deliver from 600-plus puffs to 10,000 puffs, from bars to boxes and from sleek transparent design styles to designs with exquisitely crafted textures. Although disposable vapes are So Soul’s primary focus currently, Li said the company also provides refillable pod mod devices on demand for its customers.

    “So Soul also provides users with a wide range of flavors that are refreshing, sweet, savory and everything in between from Watermelon Ice, Mixed Berry Ice, Blueberry Ice, Spearmint, Blue Razz Lemonade, to Lemon Strawberry Pie, Pineapple Banana Coconut, Strawberry Watermelon Bubblegum, etc.,” said Wang. “There’s something for everyone. We expect to be responsible for offering the best vaping products to vapers at home and abroad and for pushing the entire industry forward.”

    Currently, So Soul’s products are sold globally in North America, Europe and Asia. The So Soul XC650 (Vibe), Y650 (Box) and S600 (Peak) are some of the most popular devices in the U.K. and European Union, according to Li. Since So Soul X7000 and Y10000 were launched in early 2022, they have been growing a massive market presence and have become popular in the U.S. and Middle East markets, particularly.

    While it depends on how heavily someone vapes and how often they use the device, typically, a So Soul device lasts longer than 92.3 percent of the disposable vape pods in the market, lending to the brand’s popularity. One popular vape reviewer stated that the So Soul X7000 is one of the best disposable vaping devices on the market.

    “The retro look really sets them apart from other disposables but, of course, that’s not the only reason why you should consider them,” the reviewer stated. “The flavors that I tried are all very enjoyable to vape on, and that’s only three out of the 20 that they offer, so there’s plenty more to choose from if the flavors that I tried aren’t quite to your liking.

    “The tight MTL draw is certainly not what I expected, but it was a pleasant surprise. The draw is similar to a cigarette, and that’s going to be a big plus for anyone looking to use these to quit smoking. Add to the fact that these provide a very satisfying draw and up to 7,000 puffs, and you get a great value for your money.”

    One of the major challenges for building the So Soul brand is the varying rules for vapor products from country to country, according to Wang. Regulations in the vaping industry are constantly changing and evolving in nearly every country where e-cigarettes are sold. Those regulatory rules include everything from raising the minimum legal sales age for e-cigarettes in many countries from 18 to 21 and federal, state and local restrictions on flavored e-cigarettes as well as the U.S. Food and Drug Administration recently being given the authority to regulate synthetic products.

    Many countries, like China for example, have even unveiled technical standards for e-cigarettes that will go soon go into effect. In a public document, in April, China’s State Administration for Market Regulation listed the requirements for design, chemical compounds and the mechanics for e-cigarettes that domestic manufacturers must meet in order to sell their products.

    “In addition to staying current on the laws governing the industry, we will keep up to date on the relevant scientific literature concerning the use of vaping products,” said Wang. “We may also consult with independent external scientific and medical experts to lead technology and ingredients innovation, so that we can fulfill our mission of helping people have easy access to affordable, safe and effective alternatives to traditional cigarettes.”

    So Soul’s mission is to promote less risky options for the global tobacco industry. So Soul and its team members are working toward helping create a smoke-free future. Moving forward, she said that the vaping industry is constantly evolving, and So Soul will remain at the forefront of innovation.

    “We have a passion for what we do, and it shows in our products. So Soul is more than just a brand—it’s a lifestyle. It’s about being confident, feeling good and living life to the fullest,” said Wang. “So Soul is style, substance … soul. The perfect vape for those who want it all.”

  • Liquid Success

    Liquid Success

    Zinwi R&D Center

    Zinwi Bio-Tech is the first company to be authorized by the Chinese government to produce e-liquids.

    By Timothy S. Donahue

    The e-cigarette industry is competitive. It is also growing rapidly. According to a recent report from Allied Market Research, the global e-cigarette market was valued at $17.3 billion in 2020 and is projected to reach $94.3 billion by 2031. As stringent regulations are implemented around the world, companies that produce the highest quality products in factories that meet the highest standards are finding themselves in high demand.

    When the State Tobacco Monopoly Administration of China (STMA) passed the Electronic Cigarette Administration Measures in March of this year, it required companies to apply for a license and comply with certain technical standards, including permitted ingredients and additives. Companies applying for the license must submit evidence showing financial and manufacturing fitness, to exacting standards set by the STMA, in a limited time frame.

    According to the SMTA website, fewer than 50 e-cigarette-related companies—including retailers and manufacturers—have received licenses. In June, Zinwi Bio-Tech became one of the first vape industry companies to secure a production license, specifically in the e-liquid category. Jenny Xu, Zinwi’s deputy director for international business, said garnering the license is challenging. Zinwi needed to meet strict quality control standards and go through a screening procedure that proved the company’s strong, reputable status in the industry.

    “The license not only gives Zinwi permission to produce e-liquid in China, helping Zinwi as a leading player in the industry to further enhance its concentration in the e-liquid segment, but also indicates the official recognition on Zinwi’s products, facilities and overall operation,” said Xu. “To secure the license, a company must prove that it is in possession of sufficient funds for production, with adequate facilities and equipment to meet the set standards. The materials and information required to apply are multiple in terms of financial status, production process and quality management.”

    In addition, the time window for submitting applications is narrow—a company must have completed and submitted its application by Sept. 30, 2022. The bar is also high, according to Todd Jiang, Zinwi’s sales director for international business, adding that the STMA’s review of both the application materials and the on-site check are strict as well.

    Jeff Zou entered the vaping industry and began Zinwi in 2016 with the goal of focusing on R&D, production and sales of e-liquid. Headquartered in Shenzhen, China, Zinwi is a high-tech enterprise integrating the R&D, production and sales of e-liquid, having developed into a global leader in the e-liquid solution service sector. Zou believes e-liquid “is at the core of the e-cigarette and has great potential” because it’s needed in every vaping device.

    “All e-liquid is the raw material that consumers vape. Consumers care about taste first followed by brand awareness and product design,” explains Zou. “Especially as the hardware technology becomes more and more mature, and products tend to become standardized, it will not be the hardware that reflects the advantages of e-cigarette brands; instead, the taste of the e-liquid will become the most important factor for consumers to consider when choosing what to vape.”

    In 2021, Zinwi Bio-Tech’s annual e-liquid shipment breached the 2,000-ton mark, equivalent to approximately 1.3 billion pods. Its production base covers an area of nearly 20,000 square meters, with complete production and testing equipment, a standard good manufacturing practices (GMP) workshop and automated production lines. The company’s GMP workshop was completed in 2019 and covers more than 1,800 square meters, according to Xu.

    “Our production base is able to deliver large orders at low cost and handle customer needs in a timely manner. The average monthly production capacity of our e-liquids can reach 600 tons,” Xu said. “We also have plans to expand our manufacturing sites overseas, so the overall production capacity can be further improved.”

    Zinwi Headquarters

    Zinwi’s clients include brand customers as well as original design manufacturer/original equipment manufacturer factories. Most of Zinwi’s e-liquids are used in pod products (including rechargeable closed systems and disposable closed systems). Xu said the majority of Zinwi’s products are initially sold to downstream manufacturers in large quantities and then sub-packaged into pods. The company’s team of professional flavor chemists has developed tens of thousands of e-liquid product formulas.

    “Zinwi produces e-liquid for both export and the Chinese market. The export destinations cover around 20 countries and regions across Europe, America and Canada, the Middle East, Russia and more,” explains Xu. “The company’s team of professional flavor chemists has developed over 40,000 e-liquid product formulas. Popular flavors can vary from region to region, country to country and city to city. For example, European customers prefer high sweetness, moderate coolness and sufficient aroma while Russian customers prefer moderate sweetness, low coolness and sufficient aroma.”

    As of July 2022, Zinwi has approximately 450 employees. The company’s success is based in its strong scientific research ability, secret e-liquid formulas, unique product taste, mastery of market preferences and strict quality control, according to Jiang.

    Zinwi has built a professional quality control and testing team to strictly control the process from raw material procurement, manufacturing to finished product testing, warehousing and after-sales quality, according to Jiang. Through sample collections, retention and traceability systems, Zinwi ensures its product quality with a strict quality control regime, according to Jiang. He says that Zinwi produces an average of 400 quality control samples daily that get stored in its 300-square-meter sample storage facility. The company has an 11-step inspection process conducted by more than 60 quality control professionals.

    The company invested approximately RMB 26 million ($7.4 million) in its R&D efforts in 2021. Jiang said that this year, the company expects to invest about RMB 50 million. Its commitment to quality is supported by numerous accreditations, including ISO9001 certifications, national CNAS laboratory and GMP certifications, and many others.

    “Zinwi has a strong R&D team and first-class scientific research equipment. In 2020, we set up the Atomization Technology Research Institute led by a doctoral team to carry out exploration and research on the basic field of e-liquid,” said Jiang. “Our R&D team continually breaks through the industry’s technical barriers and has obtained and applied for over 200 patents. Our R&D team includes the R&D Center for product R&D and Technology Center for technological innovation.

    “The R&D Center is for customer-oriented e-liquid product development. The Technology Center is for the cutting-edge or basic research on technologies, like essential oil extraction from plant, atomization science, sensory science, etc. The ultimate goal of our product and technology R&D is to realize harm reduction atomization.”

    According to Jiang, recent R&D projects have focused on core raw materials, product safety, consumer experience and health. “We have developed a variety of core raw materials through plant extraction technology. The high-quality core raw materials further enhance the taste of the product, thereby improving the quality of the product,” he says.

    In addition, the company has built a product safety database based on a number of studies of biochemical toxicology, animal toxicology, component analysis and structural identification, among other areas. The knowledge helps guide the company’s research and development of harm reduction products.

    “While pursuing consumer experience of taste, satisfaction, etc., we also insist on guiding product development with experimental data and theoretical research and pursue the concept of safety, low temperature and high-efficiency atomization,” adds Jiang.

    Zinwi Management Team

    When nicotine salts started to explode into the e-liquids market, Zinwi was on the forefront of innovation. Zinwi’s R&D team developed its own nicotine salt technology in 2018, which Jiang said could help vapers achieve a higher level of satisfaction with a softer taste. The company also participates in external research with several universities. Jiang said that the investment allows Zinwi to take advantage of external scientific research institutions and the talent behind those institutions to help Zinwi master the latest technological trends and cutting-edge knowledge.

    “Our cooperative universities and institutions include Guangdong Pharmaceutical University, Shenzhen Institute of Advanced Technology – Chinese Academy of Sciences, Beijing University of Chemical Technology, [Chinese] Society of Toxicology and Shanghai University of Applied Sciences,” said Jiang.

    To remain as active as possible in the industry, Zinwi joined the U.K. Vaping Industry Association and cooperated with its U.S. customers to submit a premarket tobacco product application to the Food and Drug Administration. Xu said that Zinwi’s knowledge of global market preferences in e-liquids can help customers quickly expand their customer base and reduce trial and error costs.

    “Zinwi’s compliance team can provide customers with global compliance solutions for e-liquids. We have rich practical experience and professional knowledge to help customers understand the latest laws and regulations and industry information, ensuring that their products meet the compliance requirements of global markets and thus effectively enhancing their product competitiveness,” said Xu.

    More importantly, the company’s experience in flavor development can set a company apart from its competition. Jiang said that Zinwi’s standardized production, shipping capabilities and quality control processes help the company quickly adapt to changes in a customers’ needs.

    “We may even know the market changes earlier than our customers to give them advice and help them develop unique products,” Jiang says enthusiastically. “Our customization service can efficiently meet clients’ needs and ensure customer satisfaction. We will compare our e-liquid quality and variety of flavors with anyone, but no other e-liquid can compare.”

  • What’s Old is New

    What’s Old is New

    Credit: Toto Jang 1977

    Nicotine was first synthesized nearly 120 years ago and is now being considered a new tobacco product.

    By Timothy S. Donahue

    Synthetic nicotine has been under fire recently. News reports surrounding the product have been negative, and technically, all synthetic nicotine products are illegal in the U.S. Companies had until May 14 to submit a premarket tobacco product application (PMTA) to the U.S. Food and Drug Administration to keep their products on the market. Those that did not gain the FDA’s authorization for their synthetic nicotine products would have had to pull those products from the market by July 13. However, the FDA does seem to be using some discretion in its enforcement of synthetic nicotine products.

    During a panel presentation on synthetic nicotine at the Next Generation Nicotine Delivery USA 2022 (NGN) conference in Miami, Florida, in June, Todd Cecil, the acting co-director for the FDA’s Center for Tobacco Products’ Office of Science, commenting from the audience, said that he could not confirm enforcement discretion for synthetic products. He said “everything” on the market after July 13 is illegal. However, he insisted that the agency would evaluate synthetic products based on the science.

    “I can say that without doubt … the Office of Science will evaluate synthetic nicotine as you would any product, and [it] isn’t looked at with bias either for or against. It is up to the application to demonstrate that their product is APPH [appropriate for the protection of public health],” said Cecil. “And, like the rest of the FDA, no end verdict is evaluated in the absence of the dosage form in which it is administered.

    “So, you may well find a lot of synthetic nicotine products coming off of the marketplace because they didn’t hit the requirements of submission, didn’t hit the requirements of data that’s in the rule, or that they have not demonstrated that it’s APPH, all of which is part of this analysis process. It’s not simply a ‘Well, it’s synthetic. That means it’s OK.’ It has to be evaluated as part of [the PMTA].”

    George Cassels-Smith, CEO of Tobacco Technologies Inc., parent to eLiquiTech, the global distributor of SyNic products, said during the NGN panel that public misconceptions present a considerable challenge in the discussion about synthetic nicotine, adding that the FDA may be partly to blame because of the agency’s lack of clarity on the product’s safety and efficacy.

    “Our role now is to work with the FDA and to educate people that [synthetic nicotine] is a viable alternative and that it’s got a good spot in the future of tobacco products and pharmaceutical products, that it ticks all the boxes,” explained Cassels-Smith. “But unless we can educate the consumer, we’ll continue working with a 90 percent misconception of what this product actually is.”

    Tony Abboud
    Tony Abboud

    Tony Abboud, also speaking on the NGN panel, said that anti-vaping zealots, because of a few bad actors in the vaping industry, wrongly believe that synthetic nicotine was created only to evade the regulatory scope of the FDA. Companies like U.K.-based Zanoprima Lifesciences (the parent to SyNic) “have been manufacturing synthetic nicotine and perfecting the scientific process associated with it for years before the deeming regulation took effect, before the deeming regulation was fully implemented and long before the PMTA process kicked off,” said Abboud. “So that fact suggests that circumvention, again, is no longer an argument that is relevant.”

    Synthetic explained

    Synthetic nicotine is not new. Nicotine was first synthesized by Swiss chemist Ame Pictet in 1904. Since extracting nicotine from natural tobacco is efficient and inexpensive and synthesis from precursor compounds is relatively complex and expensive, for more than a century, synthetic nicotine had no commercial role, according to researchers at Stanford University in the U.S.

    Molecules such as nicotine may exist in mirror image forms with identical chemical makeup but sometimes differing biological activity. The nicotine molecule possesses chirality, meaning it exists in two mirror image versions called enantiomers or stereoisomers. Nicotine comes in left (S) and right (R) forms. The (S) isomer of nicotine greatly predominates in tobacco leaf, which contains only small amounts of the (R) variant (0.1 percent to 1.2 percent).

    Most synthetic nicotine has equal parts of both the (S) and (R) isomers. SyNic only has the (S) isomer—the one that holds all the psychotropic effects that nicotine consumers want, according to David Johnson, eLiquiTech’s president and chief scientific officer. SyNic USP/EP, SyNic nicotine bitartrate and SyNic polacrilex resin are manufactured in FDA-registered facilities using current good manufacturing practices. These products have confirmed purity levels of more than 99.9 percent, (S) levels of more than 99.7 percent and are free of tobacco-specific nitrosamines (TSNAs) and carcinogens, according to Johnson.

    “The molecule is the same and the three-dimensional structure’s the same. It’s not different. There’s nothing new. And so all those studies that were done with tobacco-derived nicotine can be bridged to this synthetic product, so it creates some synergies, reduces some effort on the part [of] people who are generating reports and reduces some of the burden on the regulators in terms of assessing the data that’s generated as well,” explains Johnson. “So this seems to be a pretty straightforward case, right? You have a pure product in terms of the active ingredient. You have delivery mechanisms that clearly evolve at the low end of the risk containers, and you have a strong basic science upon which you compare the products and then evaluate them.”

    Naturally derived nicotine and synthetic nicotine are identical on a molecular level. The differences are the individual or potential impurities. Nicotine derived from tobacco can contain potentially harmful impurities if it is not purified sufficiently. That can be difficult and costly because the impurities appear structurally similar to the nicotine molecule itself. But synthetic nicotine is virtually free of any impurities from the beginning, and none of its varieties are carcinogenic.

    ELiquiTech is committed to Zanoprima to serve as SyNic’s global distributor and the manufacturer of record for synthetic nicotine bitartrate and synthetic nicotine polacrilex resin as well as proprietary SyNic e-liquid formulas. Zanoprima holds the patent, and eLiquiTech maintains the exclusive rights for global distribution to the tobacco and electronic nicotine-delivery system industries. ELiquiTech does not sell flavorings for e-liquids.

    Cassels-Smith said the marketplace for synthetic nicotine has been a rollercoaster. He said SyNic does not make any sales to people that do not have an active PMTA. He said that when marketing denial orders for flavored tobacco-derived nicotine products began to come down from the FDA, the demand for synthetic nicotine was strong. However, SyNic only did business with companies that submitted a PMTA. Subsequently, the FDA opened a short window for new products to enter the marketplace.

    “We saw a very robust sampling and ordering process for people to [bring new products to market]. Now, we are in a period where companies would be marketing that product. But surprisingly, I’m not seeing the demand that I experienced in the beginning,” said Cassels-Smith. “My guess is that people are waiting to find out how those applications will be reviewed before they come in. I think their concern is that if there’s a market denial order and they must remove the products from the shelves, they would have excessive inventory and a high exposure to potential cash flow issues.”

    Globally, the United States has always been the country that “tosses the paddle in the water, and then we quickly see over in Europe the ripple effect,” according to Cassels-Smith. He said that he had recently spent time in Europe and was amazed at the number of vapers and heat-not-burn consumers there.

    “The ratio of people that were smoking cigarettes was the smallest that I’ve ever seen in Europe. I was in Poland for the Global Nicotine Forum. Going to the conventions, I was in Birmingham for [the World Vape Show] two weeks prior. Synthetic nicotine was all the rage, and the U.K. is seeing smoking plummet because of its embracing of vapor products. World Vape Show Dubai had many synthetic products too … it’s very strong right now in the Middle East. And most recently, we see that China is licensing companies to produce an estimated 200 metric tons to [a rumored] 500 metric tons of synthetic nicotine. With those kinds of quantities, they must anticipate an extremely strong demand.”

    Credit: NDABCREATIVITY

    Forward thinking

    The vapor industry is always changing. However, nicotine has always been a traditionally quiet segment. When some companies announced that they would use synthetic nicotine to circumvent FDA regulation, the U.S. Congress acted. It changed the definition of tobacco in the Tobacco Control Act to include synthetic nicotine. That change turned the synthetic nicotine market on its head.

    Cassels-Smith predicts a bifurcation in the nicotine market. This is due to factors such as making the cost of synthetic production more affordable and the certain security guarantees that synthetic nicotine offers over its natural cousin. Synthetic nicotine can be purchased for nearly the same price as tobacco-derived nicotine and in some instances for even less. This is due to advancements in the commercially scaled bulk production of synthetic nicotine for use in the tobacco, vaping, pharmaceutical and scientific research industries.

    However, natural nicotine may not be the best option for nicotine-replacement therapy (NRT) and next-generation nicotine products. This is because nicotine extraction outside the U.S. comes from a supply of dust and recon. India, for example, has used its large stocks of tobacco dust to create a crude nicotine, which is then refined into a purer liquid nicotine extraction.

    Several NRT products have been taken off the market by the FDA recently because they were found to contain TSNAs, residuals from the natural nicotine used in the NRT’s production. Synthetic nicotine has no TSNAs, the harmful, cancer-causing chemicals found in combustible tobacco products, because TSNAs are formed when tobacco leaves are grown, cured, aged and processed. The problem with the tobacco used in most naturally derived liquid nicotine is that the leaf used for extraction can’t be traced back to its origins.

    “When you pick up a pack of cigarettes, you can tell that tobacco is grown in this farm, in this soil, with this seed, with this residual pesticide, with this amount of heavy metals … with a nicotine extraction, you have no idea. You can’t track and trace it,” explains Cassels-Smith. “So that’s an advantage to our product. And I think that you’re going to see more and more of tobacco grown from a specific area with a farmer with known residual pesticides and known heavy metal contents of the soil, and that will be extracted. And I call that the pedigree of natural nicotine. I do see an opportunity for a pedigree brand of natural nicotine to have a substantial seat at the table.”

    Johnson said that having a manufacturing process that produces a synthetic nicotine offers a controlled process that’s repeatable, reproducible and well defined. Every raw material that goes into the production process can be traced by lot. Ingredients can all be tracked back to the source. “You’ve got batch records. You’ve got lot tracking. It meets that pharmaceutical model for producing a product that’s very well characterized [and] very reproducible,” said Johnson from the NGN panel stage. “The product that you produce is very low in impurities. It has no TSNAs, OK? Because those are not produced in this process.”

    David Renteln, co-founder and CEO of Lucy Goods, said that a pure, consistent, traceable form of nicotine is both easier to work with and also better for the consumer. He said that if one were to consider what the future of farming is going to look like, it isn’t going to be the traditional growing on billions and billions of acres of land. And land that needs to be used for food won’t be taken up by tobacco.

    “We’re still using farmland to grow tobacco, something that we’ve done for thousands of years [it’s labor intensive and bad for the environment]. The chemical production and synthetic production of key chemicals is something that will definitely not be done [in the future] by just growing plants on essentially two-dimensional plots of land,” said Renteln. “And as a result, the efficiencies are better for the environment, it’s better for human quality of life and labor practices. And when we reach scale, it will probably be less expensive, all the while being better for the manufacturer and the consumer.”

    Credit: TTI

    A closing cause

    The benefits of synthetic nicotine could extend to other products, such as pharmaceuticals. The 1958 Food Additives Amendment requires the FDA to ban additives that are found to cause or induce cancer in humans or animals as indicated by testing, such as TSNAs.

    Cassels-Smith said that this is why his company is preparing its drug master file for SyNic. The lack of track and traceability for natural nicotine has been a problem not only for the tobacco industry but also for the pharmaceutical industry and NRT manufacturers.

    “I think a lot of data needs to be presented, but I think [an] argument clearly can be made that this is more helpful to use in a habitual way than a Nicorette gum or something else in the NRT space. So, yes, a rising tide will lift all ships,” he said. “We will eventually see pharmaceutical, as well as tobacco products, with a cleaner active ingredient because what’s good for the goose is good for the gander.”

    Renteln said that the agency has the ability to do what it wants. It has a high degree of latitude to make decisions that it believes will help the agency achieve its mission: protecting public health. He said that the intent behind regulating vaping products is to ensure that these products that are APPH remain on the market and that those that aren’t APPH are not allowed to remain on the market.

    “We should take an appropriate amount of time and get the burden of evidence that they need to make that decision. I think that there are, just using common sense, products that are more complicated and will require more time to assess, and then there are products where it would be kind of difficult to mess up,” he says. “I think enforcement priorities can make a great deal of sense. We’ve seen that work relatively effectively already, and so I think they’ve got a precedent that’s not perfect but good enough.”

    Instead of overzealous regulatory actions, Renteln said he would like to see more action taken against the bad actors of the industry. Nobody seems to care if they get a warning letter. He thinks misinformation is a serious issue, claiming 90 percent of the doctors he has spoken with believe nicotine causes cancer and is extremely poisonous. He also doesn’t want the FDA’s decisions to be political.

    “The problem we have is misconceptions and people telling false truths. Nicotine isn’t made in a microcosm; nicotine does have an addictive quality to it, but it’s super clean. It’s not carcinogenic,” said Renteln. “My biggest concern is just that there will be a great deal of pressure [on the FDA] to bow to political influences rather than scientific decision-making … that’s really the agency’s role; that’s their mission. That’s their approach to dealing with everything. I think that the scientists at the agency tend to feel very strongly that they’re going to make a decision based on science.”

  • Misdirection, Lies, Hubris

    Misdirection, Lies, Hubris

    Regulating the vaping industry in South Africa is complicated by deception and distraction.

    By Asanda Gcoyi

    The advent of electronic nicotine-delivery systems (ENDS) and electronic non-nicotine delivery systems (ENNDS) has taken the world of public health policy by surprise, it would seem. Nowhere is this more apparent than in developing and under-developed countries.

    Where previously countries with little public health policymaking capacities could rely on the World Health Organization for guidance on tobacco regulation, the deep uncertainties plaguing the WHO on the best way to regulate ENNDS have left many countries unsure how to regulate important innovation in nicotine delivery.

    In South Africa, this challenge has proven particularly acute. As a former leader in tobacco control, the country has struggled to institute an ENNDS regulatory framework. In May 2022, it was four years since the government first published the draft Control of Tobacco Products and Electronic Delivery Systems Bill for public comment. The bill updates the country’s longstanding Tobacco Products Control Act, first adopted in 1993.

    It does this by introducing more restrictions on tobacco sales and consumption. In a stroke of policy confusion, the bill extends the restrictions imposed on combustible cigarettes to ENNDS. To date, the draft bill has not been approved by the Cabinet for tabling in Parliament, precisely because it is based on misinformation and hubris.

    In general, proposals to restrict smoking and make it difficult for nonsmokers to be initiated into the habit are to be welcomed. However, it is entirely misguided to have the prevention of initiation as its sole objective of public health policy in a country with a staggering 8 million smokers out of a population of 60 million.

    South Africa does not have the resources to support smokers quitting. Other than a barely functional quit line, the country does not have any smoking cessation programs sponsored by the public health system. Nicotine-replacement therapy is not freely available. There are no counselling facilities.

    Asanda Gcoyi

    While the South African government cannot generally be regarded as lacking in policy-making capacity, especially in the area of tobacco control, it can be concluded that shifting narratives about ENNDS have left the government in a difficult position. WHO prevarication on the topic has not helped matters.

    Where government could previously rely on the WHO to issue unequivocal policy guidance, the growing impasse between the WHO and members of the public health community in support of ENNDS as a harm reduced alternative to smoking has put government at a loss on how to proceed on ENNDS regulation. Growing scientific evidence challenging the natural inclination of the WHO to castigate behaviors it does not agree with is proving especially challenging.

    While the ENNDS industry in South Africa shares government’s concern about a new generation of nicotine consumers, it remains a concern that government proposals to regulate ENNDS do not correlate with the intended outcome of reducing smoking.

    As has been demonstrated in places such as the U.K., ENNDS are an efficient tool for moving smokers to potentially less harmful alternatives, with some even deciding to quit. It is a major public health policy opportunity, especially for developing countries such as South Africa, to reduce their costs of public health resulting from noncommunicable diseases associated with smoking.

    In the four years that the government has attempted to come up with a regulatory framework for ENNDS, the Vapour Products Association of South Africa (VPASA) has been at the forefront of calling on government to consult beyond its fellow travelers in the anti-tobacco advocacy lobby. Sadly, this has not happened.

    Instead, the government has continued to rely on outdated, heavily biased studies to back up its untenable policy positions, including the rightly maligned and withdrawn study by Stanton Glantz, a researcher with the University of California, San Francisco School of Medicine, titled “Electronic Cigarette Use and Myocardial Infarction Among Adults in the U.S. Population Assessment of Tobacco Health,” published by the Journal of the American Heart Association in 2019.

    Currently, the government looks set to introduce a tax on vaping products. This is partly justified on the basis of this and other problematic studies, some conducted as long ago as 2014. This happens against the backdrop of new scientific studies demonstrating the likely benefits of adopting ENNDS as part of a broader tobacco control strategy.

    Regrettably, South Africa is not alone in embracing such misdirected policies on ENNDS. Whereas there are easy wins on tobacco control, it seems governments across the developing world have resolved to limit the very innovation that promises the most success in weaning smokers off their deadly habit. From Botswana to Kenya to Mauritius, governments in Africa and other parts of the world are resorting to draconian measures to control ENNDS rather than looking closely at the science and embedding this in their regulatory approaches.

    Overall, smokers, especially poor ones, are likely to be the biggest losers in the overzealous regulation of the vaping industry. This is a direct result of governments that fail to take into account their duty to listen not only to the views they like but also those they may not necessarily appreciate.

    The truth is that even the most rabid anti-ENNDS campaigner accepts that there are major differences between smoking and vaping. As such, it makes sense that governments should differentiate between the two behaviors when putting in place regulatory measures. Such differentiation should favor ENNDS over combustible products. This is not happening in the developing world. Certainly, it is not happening in South Africa. Quite the opposite is being pursued.

    Given tobacco’s dominant and entrenched position as the preferred nicotine-delivery system for most nicotine addicts, stringent restrictions against ENNDS disincentivize smokers from switching. Sustained disinformation and outright lies about ENNDS make this worse. Governments complain about the costs of smoking to the public purse yet seek to protect the biggest drivers of such costs by protecting the tobacco industry from the only real alternative to emerge against smoking.

    The VPASA will remain committed to the fight against senseless regulation in South Africa. To not do so would be to fail the millions of South African smokers who are desperate for alternatives to tobacco.

    Asanda Gcoyi is the CEO of the Vapour Products Association of South Africa.

  • A Survivor’s Story

    A Survivor’s Story

    Nathan (Nate) Coccimiglio

    An entrepreneur is using his business acumen to reinvent the convenience store experience.

    By Norm Bour

    The one thing we can all agree on is that the vape industry has been in a constant flux, peppered with an occasional crisis. The once “easy to operate,” unregulated business from a decade ago has morphed into a highly regulated (with more to come) struggle to stay ahead of the U.S. Food and Drug Administration and maintain their competitive position in a very crowded, ever-evolving market.

    “I think it’s easy to see where the market is going,” claimed Nathan (Nate) Coccimiglio, who has been in the business world for almost 15 years. “But besides having the vision, you need the guts to make a change and the capital to implement [that change].”

    Coccimiglio hasn’t always had the complete package, but as he just crested the age of 40, he has had his share of victories along with the inevitable defeats along the way. However, now, he feels as prepared to go forward as he’s ever been. He’s been a mainstay in the Salt Lake City business community and had a journey through nutritional supplements, enhancement pills and even owned a storage facility for precious metal and bullion.

    “I saw an opportunity in that space, so I took it and grew it into a multimillion-dollar company. I did the same thing with vapes when I ventured into that in 2012,” he said. “In 2007, my life took a serious detour when I got hit on my motorcycle on the interstate doing 80 mph. I was running an electrical contracting business and suddenly that all went out the window. I wasn’t able to do certain hard labor like I used to, and suddenly, I had to reinvent myself,” he shared. “That forced me into starting my own business.”

    ALT21

    Coccimiglio began with vitamin supplements and enhancement-type pills, which he started selling from his home and later expanded into a second location in Tucson, Arizona. That location got burglarized, and the entire inventory was stolen. Once again, he had to backtrack and dig in at his home office.

    Even after adversity, in less than two years, Coccimiglio generated over $5 million in annual sales, and he sold that business just a few years later.

    “I look back and wish I had kept that one,” Coccimiglio confided. “I was in my mid-twenties and didn’t know then what I know now. It taught me lots of lessons about what to sell, how to sell and what to stay away from.”

    The cash from the sale, along with his passion for metals and the business experience, gave him confidence to start a private vault company. He started storing and warehousing bullion in 2012. The company stored platinum, ore and worked with several mines in Utah storing hundreds of millions in metals.

    However, Coccimiglio was still intrigued with supplements and accessories and decided to open an e-liquid company called Tronic Vape. He also created a few other lesser known brands.

    “E-liquid was easy back then,” he laughed. “Just a simple 10 mL bottle filled with liquid, which we made with no restrictions or regulations at all. We also imported little e-cigs from overseas that I thought were the hottest things. Even though there was minimal regulation, we implemented our own and insured our products with Lloyds of London and had full liability coverage.”

    Coccimiglio continued to manufacture his e-liquids until 2018. Over the years, he private labeled for other companies as well. That was when he opened his first vape shop: Draper Vaper, in Draper, Utah.

    I visited that shop and can verify that it was over-the-top beautiful and a true testament to the possibilities of a high-end vape shop. He also opened a second location and phased out of private labeling to focus on his retail locations and to grow his wholesaling opportunities.

    Coccimiglio also offered his experience and knowledge with other shops in the area along with taking an ownership interest with a few that he believed could be successful. He also got involved with many of the vaping advocacy associations to help support the industry. He even served a stint as president of the Utah Smoke-Free Alternatives Trade Association.

    Coccimiglio has been challenged with many of his fellow vape entrepreneurs, who he says have closed minds and unwillingness to change.

    “When they say they are vape only and will stay that way, I just roll my eyes and walk away,”  he said. “If there is one thing I have learned from entrepreneurship, [it] is that you either adapt or die. I started saying that almost 10 years ago when I saw smoke shops carrying vape shop products.”

    He sees standalone vape shops as being a “thing of the past” and instead all-around “vice shops” will carry any and everything that people want.

    “We’re all playing in Big Tobacco’s sandbox,” he lamented. “It’s inevitable that they will control the vape industry over time. If every single one of our vape businesses banded together, we’d still be outmanned, outgunned and out financed.”

    Over the years, Coccimiglio has almost divested out of his vape businesses and is now evolving into his version of where the future is going.

    The key word is “almost” since he still has one shop left, which has added CBD, alternative products and adult novelties. He went back in time with his version of a “build-your-own” flavor station and offers flavors for his customers to create their own e-liquids.

    Coccimiglio believes that flavoring for e-liquids will universally be stopped through regulation. However, his new shop, Alt21, located in Murray, Utah, may be on to something. It also offers clothing, glass, kratom, e-juice and pretty much anything anyone would want.

    Coccimiglio also sees convenience stores taking over a larger share of these types of products. “For years, they’ve been looked down upon,” he said, “but c-store owners are pretty smart. They look down the road and many times band together to totally change the market.”

    Coccimiglio currently manufactures a product for them, Kush Kubes (a brand of Delta-9 and CBD-enhanced gummies) and sells them domestically as well as overseas.

    “We’re a manufacturer/distributor right now, and rather than taking new products to old markets, we’re trying to lay new ground and create new markets for our stuff. We see gas pumps coming out of the ground and c-stores looking totally different in the future. They have so much exposure and visibility right now; it’s up to us to find things for them to sell.

    “We want to sell less SKUs to more markets rather than load everyone up with a surplus of things they can’t sell. If you can’t recognize opportunity, then you’ll always miss it,” he said. “I don’t think I have a magic eye; it’s just a matter of who has the bigger pockets and how can we do business with them.”

    That is how a survivor thinks.

    Norm Bour is the founder of VapeMentors and works with vape businesses worldwide. He can be reached at norm@VapeMentors.com. 

  • Trouble the Water

    Trouble the Water

    Aquios Labs introduces the industry’s first e-liquids with a water concentration of more than 3 percent.

    By Timothy S. Donahue

    Jack Sanders has been in the vapor industry for only six years. He has been in China for the last nine years, and for the last year, he’s been researching a revolutionary idea. When the pandemic forced him to stay in Shenzhen, the capital of e-cigarette production that accounts for about 90 percent of the global vaping market’s manufacturing output, it turned out to be a life-changing happenstance. The situation gave Sanders the motivation he needed to potentially disrupt an already disruptive industry.

    The vaping industry has always embraced innovation. From its beginning, it set out to take customers away from the combustible cigarette sector by offering less risky alternatives for consuming nicotine. Except for maybe synthetic nicotine and nicotine salts, the major innovations in e-cigarettes have been in hardware. Now, Sanders and his new company are introducing a new e-liquid system that its founder says is going to transform the industry.

    It all started with a conversation, almost a joke, among close friends that set Sanders on a journey to take water-based vaping seriously. “We can do this,” he said at the time. Aquios Labs in April launched its new AQ30 disposable vaping system in the United Kingdom. The water-based e-liquids could be troubling for the competition. Sanders, co-founder and CEO of Aquios Labs, says the first generation of this new technology, which requires a specialized atomizer, can support e-liquids with up to a 30 percent water concentration. Water allows for the usage of less PG and/or VG as a base for the nicotine and flavoring.

    “We noticed that there was really nothing new in terms of e-liquids and technology breakthroughs. There’s not been much in terms of e-liquid innovation since nicotine salts came out, so we thought we’d give this idea we had a go,” explains Sanders. “The technology just basically evolved through numerous tests and numerous hours spent in R&D. We managed to make a [coil] technology that matched the liquid with a higher water content. It was never just the e-liquid itself that we were developing.”

    Sanders and his team began to delve deeper into research on water-based liquids, and they found that no one had gotten above 3 percent. As the team got closer to its objectives, through researching and testing, they began to discover that water-based e-liquids brought ancillary benefits as well. Nicotine, for example, can be delivered into the body faster with the addition of water into the liquid. The system  can also be used with nicotine salts and synthetic nicotine.

    “You can reduce the temperature of the boiling point. So, PG and VG, their boiling point is about 188 degrees Celsius [370 degrees Fahrenheit] and 290 degrees Celsius [540 degrees Fahrenheit], respectively,” explains Sanders. “So obviously, being able to bring the temperatures down makes the liquid’s chemical stability better. Lower temps also enhance flavor profiles in the e-liquids.”

    Aquios Labs is positioning itself as a technology company rather than a consumer-facing brand, hoping to integrate water-based vaping into existing product portfolios. The first generation of its technology, dubbed AQ30, can support up to 30 percent water content using a combination of specially formulated e-liquid and hardware design. The first commercially available water-based vaping devices came to market in mid-May. Aquios says it is already developing the capability to support even higher levels of water content.

    “We’re aiming to get the majority of the liquid to be water. It’s in the R&D process. I can’t put out a date on when that would be released, but it’s definitely in the process, and we are more than capable of reaching these points,” explains Sanders. “Currently, the [Aquios] technology is only available in disposable devices because it’s the most stable. But we are working on refillable tanks and to be able to sell separate juices and separate coils for refillable or open systems.”

    Sanders says it’s all very intricate research. One change in the water content and the coil technology needs to change as well. “The technology and the core elements of the devices that we’re producing, they have to be matched. It must be the AQ30 liquids matched with the AQ30 coil. Any kind of deviation, like any less water, we need to change the tech. Any more water, we need to change the tech,” says Sanders.

    The tricky part of the equation in water-based vaping has always been getting enough vapor production because the addition of water reduces vapor production significantly. It is also challenging to ensure the liquid has the proper flavor and doesn’t leak or create dry hits. Everything has to be just right. Sanders says that it entailed a lot of R&D, but with the help of Innokin’s engineers, the problem was solved. However, he can’t give that secret away yet. How the nicotine remains soluble in water is proprietary.

    Sanders says that several devices have been stored for months, and there has been no detectable drop in performance. He just can’t discuss the technology behind the Aquios system because the products are just starting to enter the global market, and no secret is safe in the competitive vaping industry.

    “I just can’t talk about it,” Sanders says. “How the technology must change for varying amounts of water … the technology changes. How that works exactly, I just can’t say. This is as far as I can delve into this right now. I don’t expect it will be long, however, before someone tries to figure out exactly what we are doing. And if they do that, then fantastic. It means that I know that there’s a lot of interest in the product. But we’re working on the next stage of development already, so it would just become a game of catch-up for other companies. We also have the best manufacturing partner that is highly skilled.”

    What sets Aquios Labs apart from other device manufacturers, beyond its high amount of water usage in its liquids, is the dedication and expertise of the company’s manufacturing partner, China-based hardware manufacturer Innokin, says Sanders. Innokin has been in the vaping industry for more than a decade and has a market presence in more than 80 countries. Innokin’s long history includes pioneering variable wattage capability and, more recently, the success of its Zenith tank, which has won numerous awards for being one of the best mouth-to-lung tanks on the market due to its exceptional flavor delivery.

    “We utilized Innokin’s innovation expertise on our hardware. Without the partnership, we would not be able to release a water-based disposable right now,” Sanders says. “Hardware innovation is not as simple as it looks. We needed to balance power, airflow, wicking, the heating element, internal structure, etc. If someone opens it and sees what we are doing, that’s not enough for reverse-engineering. Just think about Zenith tanks; any factory can get the samples, but no one had made something on the same level yet.”

    Several brands are already using the Aquios system. In the U.S., it’s used in Esco Bars. Additionally, Innokin says that it was “already placing a significant bet” on the future of water-based vaping. The company went beyond just manufacturing the hardware and also partnered with Aquios in launching Innokin’s own lineup of vaporizers using the Aquios system in April under the Lota brand.

    “Innokin has always believed that new technology has the power to eliminate the need for combustible tobacco. When we were introduced to Aquios, our product development team was immediately sold on the unique advantages of water-based vaping,” George Xia, a co-founder of Innokin, said. “Water-based technology and e-liquids result in a vaping experience that no other device can replicate, with no leakage, enhanced flavor clarity and faster nicotine satisfaction.”

    Lota’s initial launch included a portfolio of three water-based devices, each with their own position for specific global markets and consumer needs. The Lota Enviro is a disposable device with a clear mission to reduce the carbon footprint of typical disposable vapes. Enviro achieves this with a unique paper shell design using recyclable materials and user-recyclable components. After the Enviro has been fully depleted, the device can be disassembled by the end user, and every component aside from the e-liquid reservoir can be fully recycled. The Enviro launched with 10 flavors and provides a 600-puff lifespan with 2 mL e-liquid capacity for TPD-regulated markets.

    The Lota F600 is the brand’s flagship disposable vaporizer, which is also targeted toward TPD markets. The F600 features a 600-puff lifespan and delivers a constant 3.6 V output, which means consistent performance from the first puff to the last, according to Innokin.

    The third product in the launch is the Lota Prefilled Pod. The Lota Prefilled Pod Kit integrates revolutionary Aquios water-based vaping technology into a closed pod system with a rechargeable battery. Each 2 mL pod is designed to last for 600 puffs, and the battery provides constant 3.6 V output for a consistent vaping experience throughout each charge cycle.

    The Aquios devices are also more environmentally friendly than most current vaping products. Sanders says that the disposable products that use the Aquios system can be easily broken down by the consumer and recycled through traditional means. “The outer shell, which makes up most of the device, is made from reinforced cardboard. This can be recycled in any standard recycling bin,” he says. “The lithium-ion battery has been designed to easily detach from the atomizer and can be recycled at any battery disposal point.”

    Aquios products have been well received by consumers. Sanders says reviews online have shown that people were skeptical at first because the technology is new. However, after vaping Aquios and comparing it to their old device, consumers realize there is a big difference between the two systems.

    “The Aquios vape is a lot smoother. Lowering the PG and VG allows for a lot of advantages, especially in reducing irritation. I know that I’m personally a little bit allergic to PG, so any high-PG ratio liquids for me are not good. It just doesn’t agree with me,” he explains. “Also, with the reduction of the VG, liquids aren’t oversweetened by the VG. The flavoring is amplified. By reducing the amount of VG, you get a much cleaner, natural taste as well.”

    Moving forward, Sanders says he hopes Aquios can collaborate with multiple different companies in producing a range of coils for multiple different tanks. Those coils would be paired with Aquios liquids with varying water amounts, such as 30 percent, 40 percent or even as high as 50 percent water. Currently, the company is based in the U.K. and is developing its European market. It’s a natural place to start because it’s the largest market that has fully embraced vaping as a harm reduction tool. Aquios has its sights set on the global market, however.

    “Moving into additional markets is something that I do think is in the pipeline right now,” says Sanders. “We’re focusing on getting through the intial launch, but there are numerous markets we are looking at in terms of growth and opportunity. The general feeling of this liquid and the tech behind it is that together the system produces a much smoother and more pleasurable vape. I think it’s a product that can be successful in every market.”

    “That’s the end result,” he says. “You don’t have as much of the dry mouth. You don’t have as much irritation in your throat from continuous vaping or higher nicotine levels. It’s going to be something cool. And I think it’s going to be something that—once it has a larger market presence and more people have the opportunity to test it out—consumers are going to realize that it’s something worth having. This is the product they will want to vape. It’s a game changer.”

  • The Taking of Taxes

    The Taking of Taxes

    Credit: Pavlo Fox

    South Africa’s National Treasury expects new taxation rules for e-cigarettes to be in place by the beginning of 2023.

    By Timothy S. Donahue

    The comedian Chris Rock once said, “You don’t pay taxes—they take taxes.” This can be especially true in heavily taxed countries like South Africa, where imposts include income tax (on both a personal and corporate level), value-added tax (VAT), dividends tax, capital gains tax and a wealth tax like estate duty. Now, it seems South African vapers should prepare to pay an additional tax if government officials have their way.

    South Africa’s National Treasury manages national economic policy, prepares the South African government’s annual budget and manages the government’s finances. The agency says it will publish the draft Taxation Laws Amendment Bill 2022 containing the provisions on electronic nicotine-delivery systems (ENDS) and electronic non-nicotine-delivery systems (ENNDS) sometime in June or July.

    Industry stakeholders will then have an opportunity to provide written comments on the draft legislation. Additionally, the country’s standing committee on finance will also have its own consultation process on the draft bill. The draft legislation will be formally brought forward for consideration at the medium-term budget policy statement expected sometime in October.

    The government has proposed to introduce a specific excise tax on both the non-nicotine and nicotine liquid solutions used in e-cigarettes. Users could pay excise duty ranging from zar33.60 to zar346.00 ($2.08 to $21.38) per product, depending on the nicotine content and size of that product. The average excise rate for e-cigarettes is proposed at zar2.91 per mL.

    Essentially, users could pay zar2.03 per mL of e-cigarette solution containing nicotine and zar0.87 per mL of e-liquid solutions that contain no nicotine if the draft proposals are accepted and become legislation in the current form. Products with a higher nicotine content, it is proposed, will attract a higher rate of duty compared with lower nicotine products.

    “Unlike conventional tobacco products, these products are mostly unregulated in South Africa, hence the Department of Health has also started a process of amending the current tobacco control legislation to include these products in the regulatory framework,” the draft states. “Similarly, other governments around the world have started a process of regulating the consumption and use of ENDS through tax and nontax measures.”

    Wesley Grimm, a senior associate, and Rudi Katzke, a partner, at Webber Wentzel, a law firm headquartered in Johannesburg, South Africa, say that the South African government is proposing to introduce a specific excise tax on vaping products using existing policy guidelines applicable to other excisable products, like tobacco products. They say that much like other excisable products, the demand for vaping products is largely inelastic and that short-term consumer resistance to the tax will likely dissipate.

    A close up view of one and two hundred rand notes folded over in a young womens hand

    “National Treasury omitted to deal with this occurrence in detail in a recent workshop with industry stakeholders. In our view, it will be interesting to see if National Treasury’s proposal to tax vaping products with a higher nicotine content at a higher rate than those products with a lower nicotine content will have any impact on consumer buying patterns,” says Grimm.

    During the National Treasury’s Taxation of ENDS and ENNDS Workshop, the agency reiterated its position that the health risks associated with vaping remain “largely unknown,” according to Grimm. However, one of its stated objectives is to curb (and potentially end) the use of vaping products, including severely limiting access to the products by younger users.

    “National Treasury insists that there is a health imperative to regulate and tax the vaping industry within its existing anti-tobacco framework. In our view, the proposal to tax vaping products does not necessarily support [the] government’s stated policy intention of reducing the consumption of tobacco products,” according to Grimm and Katzke. “More specifically, there is insufficient data to speculate on whether National Treasury’s proposed tax on vaping products will prevent youth use.”

    The taxing of vaping products could have tragic unintentional consequences. Grimm and Katzke say that lawmakers should consider what happened in the traditional tobacco sector from March 2020 to August 2020, when South Africa banned all retail sales of traditional tobacco products, ostensibly to help stem the spread of Covid-19. By cutting off the supply of what it deemed “nonessential items,” the government hoped to prevent virus transmissions from people sharing cigarettes and thus prevent the health sector from being overwhelmed by sick cigarette smokers, according to government statements at the time.

    The tobacco industry challenged that decision in court, claiming that the measure was disproportional and counterproductive. In December 2020, South Africa’s High Court agreed and declared the measure unconstitutional. However, significant damage had already been done to the lawful tobacco industry, according to Grimm and Katzke.

    Credit: Enter Line Design

    “Taxing vaping products will most likely stimulate the illicit trade in these products as has happened in the combustible tobacco sector,” they add. “Many commentators from the industry raised this point at the workshop, and National Treasury did not address the proliferation of the illicit cigarette and tobacco trade, or the likelihood that taxing the vaping industry will likely stimulate the illicit trade in these products.”

    Already accounting for a third of the market in South Africa before the country’s Covid-19 lockdowns, the illicit tobacco trade soared to unprecedented heights during the tobacco ban. A recent study, conducted by the University of Cape Town’s Research Unit on the Economics of Excisable Products, found that an estimated 93 percent of smokers were able to purchase cigarettes on the illicit market during South Africa’s sales ban. Shortly after the ban was lifted, South African Revenue Service Commissioner Edward Kieswetter predicted it would take years to investigate and prosecute the corruption and illegal activities that had taken root in those four months.

    A 2021 study, commissioned by the Vapour Products Association of South Africa (VPASA), analyzed the economic impact that the vaping industry has in South Africa. The study concluded that the industry’s total gross value-added contribution to GDP is zar2.49 billion, with an estimated zar710 million in resulting tax payments (mainly income tax and VAT) made in 2019. The VPASA report found that more than 350,000 South Africans use vaping products, that vaping product sales in 2019 amounted to zar1.25 billion and that the vaping industry generated 3,800 jobs.

    The South African government plans to implement its proposed vaping tax on Jan. 1, 2023. The proposals must still go through the normal legislative cycle before being promulgated into law. The draft discussion document will consider comments from vape consumers, manufacturers and importers, which could have an impact on the commencement date of the proposed tax and on its final form. The draft bill, which is anticipated as early as June 2022, is expected to shed further light on the precise nature of the proposed vaping tax.

    Grimm and Katzke say the government should carefully consider what it hopes to achieve by taxing vaping products. In their view, the goals of limiting youth usage and improving the health of South Africans “will not, necessarily, or directly,” be achieved by merely taxing vaping products. Instead, more understanding of the safety and efficacy of e-cigarettes and the impact that a vaping tax would have on consumers is needed.

    “We suggest that government should help fund additional research into these aspects and continue to engage with industry in shaping its new tax policy,” say Grimm and Katzke. “Government should also take meaningful and decisive steps in combating the illicit cigarette and tobacco trade, publicize any successes on that front, and ensure that the lawful tobacco industry is better protected from illicit competitors.”

  • Wordly Advice

    Wordly Advice

    Credit: Alswart

    Headlines in news stories about vaping and tobacco products are often inaccurate.

    By George Gay

    Many years ago, at one of my family’s sporadic gatherings, a then late-middle-aged family member told a story about a distant relative who, on returning from the Boer War discovered that his young son had developed a stammer. The father’s reaction, so the story went, was to take the boy up to the second floor of his house, hold him by his ankles out of the window, and tell him he would get the same treatment the next time he stammered, only with the added benefit that he would be allowed to free fall.

    The boy never stammered again, according to the storyteller, who related this incident, I think, as an example of how, sometimes, even cruel means were justified by successful outcomes. His audience, made up mostly of younger people, were clearly not of the same opinion. They stood, in open-mouthed shock, until one of them said something like: “Of course he never stammered again, the poor chap probably never spoke again.” Whether this suggestion was true, I don’t know, but it seems to me that it cannot be ruled out.

    Why did I relate the above story? Well, I was reminded of it when I saw online the following headline from a Healthline Health News story: “Low-Intensity Electric Impulses May Help Struggling Smokers Quit.” I could see a similar conversation being played out:

    Researcher at conference: “Yes, the results were amazing. We just hung these smokers out of the window on live electric wires, and they quit immediately.”

    Audience member: “And are they still tobacco-free?”

    Researcher, now somewhat cagily: “Yes … they stopped inhaling completely.”

    Audience member: “Do you mean they’re dead?”

    Researcher: “Well, yes, though we’re unsure whether the cause of death was due to the electric shock or the shock of being suspended out of the window. More research is needed.”

    I have a passion for headlines, and I am also very taken by the word “struggling” in the one above. It seems to try to suggest a certain empathy with smokers, but I’m not sure this isn’t misleading. On the other hand, struggling is a good word here because it seems to illustrate the breakdance you perform when you accidentally grab a live wire, and I can imagine the young boy struggling as his father grabbed him by the ankles—though not as he was being held out of the window.

    Credit: Vadosloginov

    Struggling is the justification, I guess, for experimenting with applying “low-intensity electric impulses” to these smokers, who have been convinced that they are victims no longer in charge of their own destinies. They have been convinced that they are addicted to smoking and that it is all but impossible to give up without the intervention of people willing to do stuff to them.

    OK, I don’t want to be unfair. I’m sure the people applying the electrodes are well meaning. The story said a new study had found that smokers receiving noninvasive low-intensity electric or magnetic impulses, also described as noninvasive brain stimulations (NIBS), were twice as likely to go without cigarettes for three months to six months as were those receiving a placebo treatment. The story added that NIBS had emerged as “a new therapeutic option for several conditions, including pain management, weight reduction, alcohol use disorder and/or depressive disorder.”

    The point here, however, is that while the management of pain and depression involves complex matters that have mostly defied the best efforts of researchers to come up with effective remedies that don’t do more harm than good, smoking is a fairly simple matter for which, in recent times, at least one effective—and, joy of joys, noninvasive—remedy has been developed.

    Individuals, companies, organizations and some governments have spent a lot of effort and time developing and improving vaping devices—and other low-risk tobacco and nicotine products—that can wean smokers off cigarettes. And with encouragement, or at least a lack of discouragement, these devices would, I’m sure, be continually improved both in their efficacy and, importantly, in respect of their environmental credentials.

    But these efforts have been hugely undermined to the point where, by the end of this year, the three most populous countries, China, India and the U.S., will have either banned vaping devices or significantly reduced their appeal. Vaping’s detractors constantly moan that one of its problems is that nobody knows what long-term effects it will have.

    However, a story can be published under a health news heading supportive of a little-tested proposed quitting method that works if at all by affecting the brain, without a hint of any concern about our not knowing what the long-term effects of such brain stimulations might be.

    The situation is bizarre.

    But now I want to digress because I always like to spend time with my most recent favorite heading, and that isn’t the one featured above. My most recent favorite heading has to be this one from the Manila Bulletin: “Thailand ready to legalize smoke-free products like the Philippines.”

    Vaping concept word cloud background

    In part, I like this heading because it speaks to a debate that crops up every time a new minister is appointed to head the U.K.’s education department: English grammar. What usually happens with a new right-leaning education minister is that she comes into her post with a demand that the English language curriculum be changed so that pupils are drilled in the (soon-to-be-forgotten) minutiae of complex grammatical rules that are, in reality, of interest only to academics and the otherwise friendless.

    On the other hand, a new left-leaning education minister will demand the curriculum be changed so that pupils are encouraged to be creative rather than necessarily grammatically correct, resulting, in extremis, in their producing highly creative but unreadable twaddle.

    What tends to get forgotten in this debate, and in most others, is that there is a middle way in which basic grammar is taught to everyone, but the more esoteric grammar is pursued only by those with a love of such things.

    To my way of thinking, the most important thing to keep in mind when writing in English is word order. But it is one of the most overlooked. Take any daily English newspaper and you are likely to see a sentence that says something like, “Joe Bloggs was yesterday sentenced to five years imprisonment in the Central Criminal Court.” Of course, this is not true. There is overcrowding in English prisons, but I don’t think anybody has put forward as a solution the idea that convicts should serve their time within the country’s courts.

    The sentence should read something like, “Joe Bloggs was yesterday sentenced in the Central Criminal Court to five years’ imprisonment.”

    And if we in England cannot get such basics right, it is unfair for me to poke fun at a heading in a publication whose journalists and editors are working in their second language. But, in my defense, the heading is funny because, to use one of the U.S. Food and Drug Administration’s favorite words, it “deems” the Philippines, a country of about 112 million people, to be a smoke-free product.

    All that is needed to make sense of the heading is to change the word order to something like, “Thailand, like the Philippines, ready to legalize smoke-free products.”Or if the subs cannot take the commas, then it can be rendered as, “Thailand to follow the Philippines and legalize smoke-free products.”

    But now I would like to digress again because, mainly, I’m more interested on this occasion in looking not at my most recent favorite heading but at my most recent least favorite heading, which appeared in Yle News: “One in three teens buys snus on social media, study finds.”

    Wow, even though the story refers to Finland, which bans sales of snus but might be thought of as being within one of the world’s major spheres of snus interest, 33.3 percent is a huge percentage of the teenage population to be buying snus on social media, especially when you consider that, despite the ban, some teenagers must be obtaining snus in other ways, and yet others must be indulging in different types of tobacco products.

    But, of course, the heading shouts out a message that is not true. When you read the body of the story, it becomes clear the heading should read, “One in three teenage snus users buys snus on social media, study finds,” which puts a different complexion on things. On this basis, there might be only three teenage snus users in Finland, one of whom buys her products on social media.

    Of course, the sub-editors wouldn’t like my suggested revisions because a couple of words have been added to the heading, which now, horror of horrors, contains the word snus twice. But in the interests of accuracy, surely it would be worthwhile running what would admittedly be a clumsy heading, or at least it would be worthwhile spending a couple of minutes getting around the problem caused by a misleading heading.

    It would be easy to get around the number-of-words problem by dropping the superfluous “study finds.” And you could cut out the snus repetition by replacing the second usage with the word “products.” Or if you wanted to go for a harder-hitting headline, you could run it as, “One in three teenage users buys snus on social media.”

    Truth matters, and unfortunately, many casual readers, I’m sure, will have taken the heading to mean what it says. And they will have gone on to have conversations with friends and family, who will have passed the story to others … no doubt in exaggerated form. To me, the heading is likely in this way to nurture a moral panic, and, in so doing, undermine a product people can use to move away from smoking and toward a far less risky future.

    The story, which was based on a School Health Promotion study, seemed to look at students widely, though the only groups specifically identified were those in grades 10–12 and vocational students. And one serious problem with the story, to my way of thinking, is that it indulges in the usual blurring of lines when it comes to references to young people, with the use, in a story of fewer than 300 words, of “children” (three mentions), “young people,” “students” (two mentions), “teens” (including in the heading, three mentions), “youths” (two mentions), “youngsters” and of course the panic-inducing “kids.”

    And to add to the moral panic, the Institute of Health and Welfare (IHW) is quoted as calling for parents to keep an eye on their children’s social media activity, adding that online platforms were making it easier for young people to buy tobacco products. It could have added, but it didn’t, that it might have been a good idea to keep an eye on what was being delivered to the family’s home.

    You have to ask yourself what exactly the problem is here. Well, according to the story, the study found that up to [my emphasis] 43 percent of students in grades 10–12 and 67 percent of vocational school students used a tobacco product at least once last year, “with snus becoming increasingly popular.” Here we have our old friend “up to,” which could mean that no grade 10–12 students used a tobacco product at least once last year.

    Of course, it seems ludicrous, too, to base a study on whether students used a tobacco product once in a year. These people are students, not saints. I bet some of them skipped class at least once last year, drank alcohol and told fibs about the reindeer eating their homework.

    And look at the tired piece about snus, ostensibly the subject of the story but simply tagged on to the end of the sentence as an unsupported afterthought: “with snus becoming increasingly popular.”

    But I think the crowning glory of the story is that, after warning specifically about young people obtaining snus on social media, it comes up with the following: “However, the most common way kids are introduced to tobacco products is through friends, the study found.”

    Of course, there was no quoting the IHW as warning parents to keep an eye on the direct interactions of young people. Perhaps that was regarded as a step too far. Having stoked moral panics over tobacco products and social media, it was thought to be unhelpful to start a moral panic over friends. 

  • International Connections

    International Connections

    The old format of gathering thousands of people together at a vape convention is changing.

    By Norm Bour

    For 18 months while Covid-19 was shutting down borders, the vape industry event space was a ghost town. Between not wanting to travel and the inconvenience, everyone was hunkering down and waiting for the pandemic to end. Even though the pandemic has not ended in any official capacity, the events industry has roared back with a vengeance.

    Nevertheless, it looks different than before.

    There are few, if any, large vape conventions in vapor-filled convention halls, and it’s rare to find “vape only” meetings since all the different components—vape, CBD, hemp and alternatives—have all melded together.

    Alongside traditional large-scale trade shows, there has also been a movement toward more intimate events, and along with SSE and smoke shop events comes the Counter Culture Convention (C3), which recently held two shows in Cancun, Mexico.

    The founder of C3, Michael Wittenberg, is no stranger to the events space since he has been doing them for nearly two decades, nor is he new to vaping. In years past, he ran National Vape Expos (NVE) at locations throughout the eastern U.S. But doing international vape events is new to him even though there have been typical booth shows in Colombia, Mexico and throughout Europe.

    However, that’s just one of the differentiators.

    The other is that this new version is not a booth show but instead it’s formatted as a one-on-one meeting behind closed doors, designed for networking, intimacy and fun.

    “After running NVE for many years, and then being shut down by Covid, I knew I wanted to do something different than before,” Wittenberg said. “I loved the one-on-one meetings format, so we launched that model in Cancun, Mexico, earlier this year. That proved to be a great success, so we duplicated it again in April and [will] have the next one in the Dominican Republic.”

    The C3 website bills its events as “everything you love about conventions or trade shows;” however, the “hustle and bustle” of the show floor is removed. The VIP events instead highlight and amplify the personalized introductions.

    “Our attendees represent the most influential thought leaders, innovators and trendsetters that Counter Culture has to offer, from cannabis and vape leaders all the way to the cutting-edge products and trends of the future,” the site states. “Our mission is to create an environment in which the only thing on our buyers’ minds is how they can find more value for their businesses. These buyers represent the cream of the crop—the leaders in the counterculture space who help facilitate and drive the various industries [that] are helping define our popular culture.”

    The events likely won’t be held in the U.S., according to Wittenberg. He says that finding all-inclusive resorts is not that easy in the U.S., and they’re expensive. “When you go to exotic locations in Mexico, the [Dominican Republic] or other Caribbean countries, the all-inclusive-style resorts are everywhere,” Wittenberg explains. “Plus, the advantage of having everything on-site keeps our gathering intimate; there is no need to go anywhere. We even have our own in-house travel agent with decades of experience and connections, so we do our homework.

    “When we launched our first NVE in 2015, we intentionally did not want to have it at a boring convention center or hotel. Instead, we picked Foxwoods Resort Casino in Connecticut, which was near to us, and later, we moved the event to the Mohegan Casino and Resort. After that, we duplicated the event in Alabama, and the results were terrific.”

    Credit: Vepar5

    Wittenberg said that he also rented the largest suites at his convention show, not because of vanity but because it encouraged networking.

    “I always invited the attendees up to our room, which they [accepted] and many times brought their customers or vendors with them. That worked well until the end of 2019,” he said.

    Until Covid-19 came along, which changed everything.

    “Everything is different now, and vape, CBD, hemp and alternative[s] all run together. Before, you’d have just a vape show or just a hemp show, but now we have vape and smoke shops that carry a variety of crossover products,” he says. “[There’s] something for everyone.”

    The terms “counterculture” or “alternative” are more mainstream than ever, which makes sense since hemp has become legal in many jurisdictions. Medical cannabis is legal in two-thirds of states, and recreational use is legal in almost half the U.S. Legal or not, the negative stigma cannabis once carried is mostly in the past.

    While cannabis is gaining acceptance, vaping faces increasing pressure. The U.S. Food and Drug Administration’s premarket tobacco product application process has proven to be a significant, costly hurdle to many vapor businesses. It’s almost ironic that CBD and marijuana face less pressure than nicotine vapes.

    The industry continues to accommodate regulations along with the needs of the public and the vaping space.

    “In our industry, we’ve learned to be resilient, which makes sense since so many of us are radicals and rule breakers,” Wittenberg said. “In other [industries] under such attack, most entrepreneurs would have quit a long time ago. But so many of our peers have fought demons worse than government intervention, so they tend to stick it out regardless of the pressure. Plus, a lot of our people don’t really have anything else. They put all their efforts into vape and don’t have a Plan B.”

    C3 brings together 30 buyers and 30 vendors and has them rotate through 30-minute meetings. If that time is too short, they can meet over a meal or drinks at night. They check in on Monday, leave on Friday, and the costs to run the event are borne by the vendors; the buyers’ costs are paid. And they do their best to screen the buyers to make sure they are who they say they are, and they now have a waiting list of candidates that wish to attend. Wittenberg calls his concept “luxury business networking.”

    When specifically asked about any challenges C3 had doing events like this in Mexico, which has a long, sorted history and relationship with drug culture, the answer was somewhat complicated. Cannabis is technically illegal without a permit in the country, but you can be sure that attendees brought their own products into the country.

    “They pretty much turned a blind eye,” Wittenberg said. “Our people kept things on the down-low. After Covid, the hospitality market had a long dry spell, and they were looking for (paying) bodies more than they normally would need to. That worked in our favor.” Times change. People change. Vape lounges, cloud comps, events with 20,000 attendees—they are all memories of the past. Now it seems like the right time to reinvent the industry. C3 is stepping up to help make those changes in an industry that always seems to be changing.

    Norm Bour is the founder of VapeMentors and works with vape businesses worldwide. He can be reached at norm@VapeMentors.com.

  • Market Watch: Middle East

    Market Watch: Middle East

    Credit: Adrian Ilie825

    A relatively new market for legal vapor products, the Middle East is beginning to embrace tobacco harm reduction.

    By Timothy S. Donahue

    According to World Bank estimates, the Middle East and North Africa (MENA) market has seen a steady decline in tobacco consumption since 2000, with 23.3 percent of adults using the products in 2000, 20.8 percent in 2010, and 19.2 percent in 2020. Many industry experts attribute this decline to the region’s growing acceptance of vapor products.

    E-cigarettes were banned in Qatar in 2012 and then three years later in Oman but legalized in Bahrain and Kuwait in 2016; however, neither country immediately adopted manufacturing standards or a taxation structure. Then, in April 2019, the United Arab Emirates (UAE) Authority for Standardization and Metrology (ESMA) approved standards for the nicotine-based e-cigarettes. It was the first country to develop standards for the products in the region.

    Before 2019, e-cigarettes were illegal in the UAE, and use of the products was growing rapidly in an unregulated market. This worried UAE regulators who wanted to curb combustible tobacco use, limit youth initiation and check a thriving vapor market.

    The goal of e-cigarette regulations in the UAE was to offer nicotine consumers less risky alternatives to combustible products. The standards set by ESMA were designed to regulate all nicotine components used in vaping products, including technical specifications, ingredients, imports, packaging and labeling requirements in the UAE as well as a corresponding fiscal and tax structure.

    After the success of the World Vape Show (WVS) Dubai in 2021, the first e-cigarette trade show in the region, the number of companies legally producing vapor products in the UAE has grown tremendously. During their 2022 conference, held June 16–18, WVS representatives said that they welcomed 50 percent more visitors than in 2021.

    During a seminar session that focused on the growth of the Middle East markets, several speakers said that the UAE and its regulatory outlook has become a blueprint for other Middle East markets such as Saudi Arabia, Kuwait, Jordan and Egypt. In 2021, Saudi Arabia announced new regulations for e-cigarettes similar to the UAE (which in turn are similar to Europe’s Tobacco Products Directive).

    In April of this year, Relx International, a major China-based vaping manufacturer, commended Egyptian authorities for their decision to allow the legal import and commercialization of vaping products in the country. Like Saudi Arabia, Egypt’s proposed regulations for vaping products are nearly identical to the UAE’s.

    Rebecca Haining, head of external affairs for BAT’s Middle East, South Asia and North Africa markets, said that the UAE should be applauded for being the first Middle Eastern country to enact regulations.  She noted that in 2019, the UAE had approximately 15,000 vapers. In 2020, that number had grown to 60,000 vapers. Today, that number is an estimated 70,000.

    “They paved the way for the regulations in Saudi Arabia … I think what [the UAE] has done in this area is very important … getting the industry together to talk about what are the possible solutions. The UAE moved very quickly to institute a range of regulations and standards that now give the manufacturers certainty and give consumers some certainty around the safety and the quality of the products,” said Haining. “That’s very important, and I think it’s a job very well done.”

    By lifting the ban on e-cigarette products, UAE authorities have allowed for the growth of new businesses and investment opportunities in the region. Experts say the move will bolster existing businesses that sell such products and will attract entrepreneurs. According to Arabian Business, the vaping and e-cigarette market in the MENA region is expected to grow by 9.74 percent annually to reach $485 million by 2025, up from $267.9 million in 2018, the year before UAE regulations were enacted. By comparison, the U.S. vaping market is expected to grow to $40.25 billion by 2028.

    Omar Abdellatif, general manager for Philip Morris Management Services Middle East Limited, told WVS attendees that the increase of exhibitors at this year’s show, compared to 2021, reflects how many new businesses are serving the UAE market. He said the show is also an example of how the market has changed as innovation has flourished since legalization.

    “Look at the evolution that has happened here in the UAE in just over one year. I think the last time you were probably sitting here [at WVS 2021] … it was a lot more about the tanks and closed pod systems; a lot more about the traditional side of vaping,” he said. “But you’ve seen what’s come up very quickly. Disposables, once they became legalized, have taken the market by a storm. And I think this is what we continue to expect. We’ll start to see these innovations.”

    Some studies suggest that e-cigarettes may be gradually replacing the use of shisha products. In a joint investigation with the American University of Beirut, the Tobacco Free Initiative found that an estimated 40 percent of young adults in Lebanon are now using vaping devices instead of hookah tobacco. One speaker during the WVS said that the opportunity for e-cigarettes to replace cigarette use, and to a lesser extent hookah, “represents a considerable shift in the culture of tobacco consumption in the Middle East.”

    Fadi Maaytah, CEO of Alternative Nicotine Delivery Solutions, said during the WVS that to continue the trend of moving combustible tobacco users toward less risky alternatives in the MENA region will require innovation. He said that innovation, however, should not attract new consumers but instead protect consumers looking to stop traditional smoking by bringing high-quality products to market.

    “It’s not for ex-smokers. It’s not for nonsmokers. It is for smokers trying to quit. Today, the development and the flow of product that’s coming to the market, it’s coming with a lot of innovation, but the risk point here is that it might attract the wrong audiences, and this is what we see more often happening,” said Maaytah. “This is why [the industry] needs more of a collaboration between the industry and the regulators to work together and push the industry in the right direction.”

    From a manufacturing perspective, positive industry innovation can only be achieved through product standards that are abided by all participants in the market, according to Haining. She said that standards are not only important for the safety and quality of products for consumers but also—if products comply with the standards—they’re less likely to have youth appeal.

    “That’s part of the reason we have the standards. Secondly, from a manufacturer perspective, it’s around marketing freedoms and marketing regulations … making sure that all players in the market are marketing responsibly and not targeting youth and [are] discouraging youth uptake of these products,” she said. “If I look at an ideal situation, from a regulatory perspective, it would be regulation and excise frameworks, in general, that are proportionate to the risk [of e-cigarettes compared to combustible] cigarettes. There needs to be a wider berth between cigarettes and potentially reduced-risk products when it comes to regulations, standards, marketing freedoms and excise frameworks.”