ITCAN argues new Health Canada guidance on NRTs flawed
Imperial Tobacco Canada (ITCAN) submitted a consultation reply in response to Health Canada's Draft Guidance on Additions to the List of Nicotine Replacement Therapy Dosage Forms last week.
The Draft Guidance outlines criteria for adding new Nicotine Replacement Therapy Products (NRTs) to a list of product formats which may be sold in all retail locations, including places where cigarettes are sold.
ITCAN says, however, it is flawed, requiring NRTs not on the list to prove they won't be misused by non-smokers, is a nearly impossible standard. This discourages the development of innovative NRTs needed to assist smokers and could exacerbate the illicit market for products like nicotine pouches.
"Both the ministerial order and draft guidance fail to provide genuine youth protection. A better approach would be to prohibit sales to minors across all channels, rather than creating an arbitrary division of NRT dosage forms" said Eric Gagnon, vice-president of corporate and regulatory affairs at ITCAN.
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In October 2023, ITCAN launched Zonnic, the first Health Canada approved nicotine pouch for smokers seeking to quit. However, a Ministerial Order by former Health Minister Mark Holland on August 28, 2024, undermined its value. He insisted then that the Ministerial Order would protect youth, but the order lacks provisions for actual youth protection.
ITCAN says it believes protecting young people is crucial, and that the current order not only fails to achieve this goal but also undermines Canada's public health objectives for reducing smoking rates and preventing the rise of illegal tobacco products from being sold.
Unfortunately, all the Ministerial Order has managed to achieve is a boom in the sale of illegal and unsafe nicotine pouches and has made it more difficult for smokers to quit smoking, ITCAN added.
"All smoking cessation products should be regulated in the same way and based on sound science and facts. Nicotine pouches do not pose a greater risk than any other NRT when used as intended. This is not how good public health policy is made," said Gagnon.
In their submission, ITCAN emphasizes the need to replace the Ministerial Order's current division of NRT with a clear, non-discriminatory and enforceable ban on sales to minors. Current evidence, including a notable decline in cigarette sales linked to Zonn's availability, underscores the efficacy of these products as smoking cessation aids. Ignoring this science-based evidence could limit access to essential tools that aid in smoking cessation. If restrictions remain, the criteria for inclusion should be broadened to ensure that all NRT products, subject to the same flavor restrictions, are accessible to smokers in all retail locations.
