electronic cigarette regulation: when less is more
TRANSCRIPT
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Regulation: when less is more
Counterfactual
www.clivebates.com@clive_bates
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WHO1 billion deaths
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I smoked for 45 years and tried every NRT
product available, none of them worked. Icontinued to smoke even though my health
was getting worse, resulting in COPD and usingoxygen daily.
September 2011 I discovered e-cigarettes and
they worked. It was like someone handed me a
miracle. In less than a week I stopped using
regular cigarettes. I havent had a tobacco
cigarette since.
Unsolicited comment left on www.clivebates.com
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From WHO Tobacco Atlas 2006 edition
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The Endgame?Projected global adult population growth
years
9.0
>
15
8.0 Adult
populationadults
7.0
Billion
6.0
5.0
4.0
3.0
2.0
1.0
0.02010 2015 2020 2025 2030 2035 2040 2045 2050
Smokers: WHO Tobacco Atlas 2006. Population: UN
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The Endgame?Projected global adult population growth
years
9.0
>
15
8.0 Adult
populationadults
7.0
Billion
6.0
5.0
4.0
3.0Smoker
2.0 population atconstantprevalence
1.0
0.02010 2015 2020 2025 2030 2035 2040 2045 2050
Smokers: WHO Tobacco Atlas 2006. Population: UN
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The endgame?Scenarios for future smoker population
years
2.5
>
15
Constantprevalence
Billionadults
2.0 (28%)
1.5
1.0
0.5
0.02010 2015 2020 2025 2030 2035 2040 2045 2050
Scenario15% global prevalence by 2050
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The endgame?Scenarios for future smoker population
years
2.5
>
15
Constantprevalence
Billionadults
2.0 (28%)
1.5Global smokingprevalencedeclines to 15%
1.0
0.5
0.02010 2015 2020 2025 2030 2035 2040 2045 2050
Scenario15% global prevalence by 2050
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If all goes wellScenarios for future smoker population
ye
ars
2.5
>
15
Constantprevalence
Billionadults
2.0 (28%)
1.5Contested by tobacco control
Global smokingprevalencedeclines to 15%
1.0
0.5
HARM0.0
2010 2015 2020 2025 2030 2035 2040 2045 2050
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The endgamea nicotine product contest?Scenarios for future nicotine markets
ye
ars
2.5
>
15
Constantprevalence
Billionadults
2.0 (28%)
1.5Contested by tobacco control
Global nicotineprevalencedeclines to 15%
1.0
Contested by nicotine products0.5
0.02010 2015 2020 2025 2030 2035 2040 2045 2050
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How far could low-risk nicotine products go?Scenarios for future nicotine markets
ye
ars
2.5
>
15
Constantprevalence
Billionadults
2.0 (28%)
1.5Contested by tobacco control
Global nicotineprevalencedeclines to 15%
1.0 Contested by low risk nicotine products
0.5 Global smokingprevalence
Cigarettes and other combustible tobaccodeclines to 5%
0.02010 2015 2020 2025 2030 2035 2040 2045 2050
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The endgame: analyst view
Consumption of e-cigs may overtake traditional
cigarettes in the next decade and theyll only
evolve and improve as time goes forward.
Bonnie Herzog, Wells Fargo Securities, 2013
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The endgame: analyst view
Consumption of e-cigs may overtake traditional
cigarettes in the next decade and theyll only
evolve and improve as time goes forward.
Bonnie Herzog, Wells Fargo Securities, 2013
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50:50 by 2030Modified Herzog scenario" for future nicotine markets
ye
ars
2.5
>
15
Constantprevalence
Billionadults
2.0 (28%)
1.5Global nicotineprevalencedeclines to 15%
1.0"E-cigarettes overtakecigarettes by 2030"
0.5Global smokingprevalencedeclines to 5%
0.02010 2015 2020 2025 2030 2035 2040 2045 2050
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Who is this?
Mitch Zeller(now) Director of the Center for Tobacco
Products FDA
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Harm reduction equation
Harm reduction =Reduced risk xNumber who switch
Product toxicity & Product attractivenessother risks
Consumer preference
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Harm reduction categoriesrisk estimates
Crudeestimateofrisk
Cigs=100
120
100
80
60
40
20
0 Cigarettes Heat not burn Smokeless E-cigs NRT
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Focus on the right relative risk
More regulationLower risk
regulated e-cig unregulated e-cig
0 10 100
0 100
e-cigarettes cigarette
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Harm reduction equation
Harm reduction =Reduced risk xNumber who switch
Product toxicity & Product attractivenessother risks
Consumer preference
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Analysts
We remain very bullish on the vast potential of e-cigs given the
rapid pace of innovation. [We believe] that the benefits of e-cigsare becoming increasingly apparent to consumers, helping
to drive trial and repeat purchases aided by stepped-up
advertisingand a lot of internet buzz
Wells Fargo
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Regulation comes at a price
Lesspersonalisation BoringFewer, duller branding &
innovationsmarketing
Slowerinnovation
pace
Greatlyreduced
variety & nicheproducts
ReducedIncreased cost
appeal
Trusted brands& firms
destroyed
Oligopoly &reduced
competition
Black market,DIY
H d i i
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Harm reduction equation
Harm reduction =Reduced risk xNumber who switch
Trade offs
Conclusion 1. The perfectly risk free product that no-one
wants scores badly in the harm reduction equation
Conclusion 2. A diverse range of products with substantiallyreduced risk lets each smoker decide which product is best
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T i l ti
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Triple negative
Tough on harm reduction
S i li d di i l
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Specialised medicines language
Consistent drug dosing
Quality Treats or prevents diseaseAdverse drug reactions
EfficacySafety
Getting tough on harm reduction?
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Getting tough on harm reduction?
Counter-productive Harm reducing
Safety Safest possible Safe enoughQuality Control processes (eg. GMP) Proportionate standards
Efficacy Regulator decides Consumer decides
Labelling Warns of danger Encourages switching
Marketing Like medicines Like consumer products
Bans on use Fear of renormalisation Normalise harm reduction
Retail Pharmacies / as tobacco General sales
Age restrictions Adults Makes little real difference
Taxation Like tobacco Fiscal incentive to switch
What do analysts think ?
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What do analysts think?
We believe many current suppliers would struggle to meet
medical standards, and for the UK they may have to by 2016. Bigplayers with deeper pockets would survive and prices could rise a hugely preferable outcome for Tobacco.BNP Paribas
Tougher regulation, as well as providing a relative advantage
to their e-cigarette divisions, would result in higher prices for
e-cigaretteswhich could also benefit tobacco companies by
limiting their attraction for smokers and slowing the decline in
tobacco sales.Fitch
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European Parliament amendment 170
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European Parliamentamendment 170
Requires medicines regulation if claim made Requires Article 17 notification regime otherwise Emphasises general safety requirement Applies Article 16cross border distance sales Applies advertising directive 2003/33/EC and audiovisual services 2010/13/EU Information leaflet Warning this product is intended for use by existing smokers. It
containsnicotine which is a highly addictive substance Warning size - 30% or 40% (Council =30%) and specification from Article 10 30mg/ml thresholdare not placed on the market (?medicine) Age restriction (no less than 18) Restriction on additivesapplication of Article 6.4 (vitamins etc) No tobacco branding Allows flavourings Requires sales allowed outside pharmacies Review
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Purpose built regulation for e-cigs / NCPs
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Purpose built regulation for e cigs / NCPs
1. Accountabilitiesresponsible person2. Disclosure and notification regime3. Labeling and consumer information4. Safety assessment and product file5. Contaminants / purity6. Prohibited ingredients7. Specific standards for vaping devices CEN/ISO8. Updating: review & technical committee9. Marketing (like alcohol?)mostly member state10. Retail sales age restrictionmember states11. public vaping?
Harm reduction equation with population effects
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Harm reduction equation with population effects
Harm reduction =Reduced risk xNumber who switch
- Extra smokers+ Extra quitters
Gateway to smoking Gateway exitsDual use Complete cessation
Reduced quitting Extra quittingNormalising smoking Normalising non-smoking
Conclusion
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Conclusion
Be positive about the (vast) potential Put the (minor) risks in perspective Regulate as though the 1 billion matter most
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Thank you
Counterfactual
www.clivebates.com
@clive_bates
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Summary of the E-
Cigarette Summit
For more information about the E-Cigarette
Summit, a full review of the event, and
more presentations,read this article.Visit
the E-Cigarette Summit's website here:
http://e-cigarette-summit.com/
http://ecigarettereviewed.com/e-cigarette-summit-london-summaryhttp://ecigarettereviewed.com/e-cigarette-summit-london-summaryhttp://ecigarettereviewed.com/e-cigarette-summit-london-summaryhttp://e-cigarette-summit.com/http://e-cigarette-summit.com/http://e-cigarette-summit.com/http://ecigarettereviewed.com/e-cigarette-summit-london-summary