Submission: Proposals for a Smokefree Aotearoa 2025 Action Plan

Dr Eric Crampton
31 May, 2021

Read our submission to the Ministry of Health on the Proposals for a Smokefree Aotearoa 2025 Action Plan.

The Initiative has, over the past several years, undertaken research into tobacco harm reduction policies because of our concern for the inequities caused by the existing tobacco control regime. That research includes Smoke and Vapour: The changing world of tobacco harm reduction (2018) and The Health of the State (2016).

We have maintained a watching brief in this policy area and regularly provide public commentary on policy developments. We also submitted on the Smokefree Environments and Regulated Products (Vaping) Amendment Bill in April 2020, and on vaping regulations in March 2021.

The Discussion Document proposes a series of novel interventions aimed at reducing smoking rates to levels viewed as consistent with SmokeFree 2025. The interventions are considerably more vigorous, and intrusive, than those that have been part of tobacco policy to date.

We believe that few will choose smoked tobacco over reduced harm alternatives as those alternatives become more broadly available. We view the proposed regulatory frameworks around vaping as being the biggest risk to that outcome: the proposed regulations make it harder for smokers to access flavoured vapes, make it harder to get the nicotine concentrations that heavier smokers will find necessary to quit, and make it impossible for
some community vape services to continue their work because of occupational licensing restrictions.

We also note that the public policy case for increasingly restrictive measures targeting access to cigarettes is also more fraught when reduced harm alternatives are broadly available. There are debatable, but straightforward, arguments from behavioural economics that can justify strict measures as benefitting even smokers themselves, where no reduced harm alternatives are available. That case is more difficult for the small minority of people who might continue to choose cigarettes despite other safer nicotine delivery mechanisms being widely available.
It warrants a reframing of SmokeFree 2025.

Finally, we worry that the proposed measures could easily lead to unintended adverseconsequences if legislated. If the government is determined to go ahead with this set of regulatory measures, we urge strong monitoring and review.

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