How to make a submission about the proposed vaping flavour ban
Unless we protest, Canada will ban all vape flavours except deliberately unpleasant tobacco, menthol and mint flavours with no sweeteners. The ban will apply across the country, with no exceptions, even for people who smoked for decades and have been vaping with flavours safely for many years.
The easiest way to make your opinion known is to use the form on the SaveFlavours.ca website, but there are other alternative approaches.
This is a guide for Canadian citizens to make their voice heard by making a submission to Health Canada, based on advice from Christina Xydous, Spokesperson, Coalition des droits des vapoteurs du Québec. ( https://www.droitsdesvapoteurs.ca/) Her full presentation can be downloaded here:
The official request for submissions is at:
I have created an annotated Word version of the full text of the vape flavour ban for reference:
You can also check out my submission and Thomas Kirsop’s long and VERY detailed submission.
The Essential Format:
Your submission must be in PDF or Word format.
It must be sent by email to: hc.pregs.sc@canada.ca
The subject must be: Submission – Order Amending Schedules 2 and 3 to the Tobacco and Vaping
Products Act (Flavours) Canada Gazette Part I, Vol. 155, No. 25 on June 19th, 2021
The text of the email should be:
Submitted by: (your full name here)
To: Manager, Vaping Products Regulations Division
Tobacco Products Regulatory Office, Tobacco Control Directorate
CSCB, Health Canada, 0301A-150 Tunney’s Pasture Driveway
Ottawa, ON K1A 0K9
Email: hc.pregs.sc@canada.ca
To whom it may concern,
Please find attached my submission in response to Order Amending Schedule 2 and 3 to the Tobacco and Vaping Products Act (Flavours) as published in Canada Gazette Part I, Vol. 155, No. 25 on June 19th, 2021.
Yours sincerely
(Insert your name and contact information)
The text of the attached PDF or Word file is up to you, but these are some suggestions:
You should begin by stating your position on the proposed vape flavour ban.
If you think that there should be no restrictions on flavours in vape you can begin:
“My submission is in support of Option 1: Baseline scenario (no further restriction on flavoured vaping products).”
You could also say that you think it should be left up to the provinces to decide. You might suggest that British Columbia, Saskatchewan and Ontario are right to restrict flavours to adults-only specialty vape stores. This protects youth while allowing adults access to flavours.
That is all you need to do, but your submission will have more impact if you tell your smoking and vaping story:
Who are you? Start with giving your name, age, and location. State that you are a Canadian citizen and a voter.
Are you / Were you a smoker? When did you start smoking? How many years did you smoke? How much did you smoke? What were the impacts of smoking on your health/wellbeing/quality of life?
For non-smokers / non-vapers who support tobacco harm reduction, describe the impacts of tobacco use among friends and family. Highlight facts such as smoking being the number one cause of preventable deaths in Canada, or that smoking kills 1 out of every 2 smokers.
Prior to vaping, have you ever tried to quit smoking? How many attempts? What methods did you use (patch, gum, Champix or other prescribed medication, behavioural support, cold turkey, etc.)? Were these attempts difficult? Did they succeed?
For non-smokers / non-vapers who support tobacco harm reduction, describe those attempts among the smokers in your life.
How did vaping compare to other quit methods? Have you significantly reduced the number of cigarettes smoked? Have you completely quit smoking? If so, how long have you been smoke-free? What are the impacts of vaping on your health/wellbeing/quality of life?
For non-smokers / non-vapers who support tobacco harm reduction, describe your loved ones’ experience with significantly reducing or quitting smoking with vaping.
Talk about the importance of flavours to you:
What category of flavour(s) do you vape (fruit, dessert, flavoured tobacco, plain tobacco, plain mint/menthol, flavourless)? How important are non-tobacco flavours to you? What impact would a ban of all flavours except for tobacco and mint/menthol have on your health/wellbeing/quality of life? Is there a risk of increased smoking / a complete return to cigarettes? Why?
For non-smokers / non-vapers who support tobacco harm reduction, describe the impact a ban on all favours but tobacco and mint/menthol would have on your loved ones successfully making the switch.
Conclusion
What do you hope will be the outcome of the consultation process? What are your demands? Be clear and concise.
Close with a polite salutation (Regards, Respectfully, Salutations, etc.) and your name and contact information.
Additional items:
If you opt to cite any studies or statistics in your submission, remember to add those at the end of your submission. For example, if you have quoted from websites, cut and paste the URL of the website into your document.
Example:
“Banning flavours for adult smokers trying to quit tobacco is a huge mistake, one that could have deadly consequences”. David Clement, Financial Post, June 30, 2021, https://financialpost.com/opinion/david-clement-dont-ban-flavoured-vapes
Conflicts of interest:
Health Canada stipulates that “Any perceived or actual conflicts of interest with the tobacco industry must be declared when providing input to this consultation” and that “Members of the vaping and/or pharmaceutical industry, an affiliated organization or an individual acting on their behalf are asked to clearly indicate this in their submission.”
Copying your email to others:
You can easily use the “CC:” feature in your email to send a copy to other lawmakers such as Health Minister Patty Hajdu, Prime Minister Justin Trudeau, the leaders of the other federal parties, senators and your own federal MP.
You can find the email contact info for MPs at https://www.ourcommons.ca/members/en and for Senators at https://sencanada.ca/en/contact-information/
Also, consider BCC’ing vaping advocacy groups such as Rights4Vapers (info@rights4vapers.com) or the CDVQ (info@droitsdesvapoteurs.ca).
Tell your friends what you are doing:
Talk about it in person and on your social media. Encourage others to make their own submissions.
THE DEADLINE FOR SUBMISSIONS IS SEPTEMBER 2nd 2021!!!
Better send a brief submission now than a long and wonderous submission after the deadline!