On the 26th of January 2017, Public Health Wales (PHW) called for a ban on the sale of “sweet-flavoured” e-liquid in Wales. Below is a letter IBVTA has sent to the Chief Executive of PHW, setting out the lack of evidence in support of this proposal, and our concerns with regard to damage to public health such a ban would have. A copy of this letter has also been sent to all Welsh Assembly Members and Welsh Members of Parliament.
Dear Dr Cooper,
I am writing on behalf of our members, some of whom are based in Wales, to express our concern, regarding calls from Public Health Wales (PHW) for a ban on sweet-flavoured e-liquid in Wales .
For the record, all IBVTA members are free from any control or ownership from the tobacco or pharmaceutical industries.
A major characteristic of the vaping market is the availability of a large number of different flavoured e-liquids. This causes concern for PHW who worry that certain flavours may be specifically targeted at young people and that ultimately this could lead to young people taking up vaping and then going on to smoke tobacco cigarettes.
There is no evidence to support these concerns.
Currently there are at least 140,000 vapers in Wales  and 2.8 million vapers in the UK as a whole . Figures produced by the ONS show that 99.9 per cent of vapers are adult current or former smokers . In addition, recent research produced by the anti-smoking charity ASH  demonstrated that children are not vaping in significant numbers. The survey found that regular use of vape products amongst children and young people is rare and is confined almost entirely to those who currently or have previously smoked . Of those young people that do vape, the majority use nicotine fee products .
Research undertaken by Queen Mary University in London  found that a child trying a tobacco cigarette for the first time is 50 per cent likely to become a regular smoker. The same research found no evidence that a child trying vaping for the first time goes on to become a regular vaper. A recent study by John Moores University concluded that: ‘Overall seven out of eight young people had never accessed vape products’ .
Welsh Assembly Government funded research from Cardiff University concluded: ‘Vape products are popular with teens, including those who have never smoked, but few of those who try them become regular users, with most of those who do so also being smokers.” 
Cancer Research UK looked in detail at two major studies into vaping amongst young people in Wales, they concluded: ‘Looking specifically at two studies dedicated the use of vaping devices amongst young people in Wales only a minority of teenagers who try vaping go on to become regular users. And the majority of those who do use the devices regularly were already smokers.’ 
Furthermore, there is no evidence of vaping acting as a gateway to smoking. If there were smoking rates would be rising as vaping has become more popular, instead smoking rates are at their lowest levels, including amongst children. According to ASH, the most recent survey found the lowest recorded smoking rates among children ever: only 18 per cent of 11 to 15-year-olds had tried smoking in 2014 compared with 42 per cent in 2003 . In Wales, specifically, according to the Health Behaviour in School-Aged Children report , smoking is also at an all-time low among 15 and 16 year olds with only 8 per cent of boys and 9 per cent of girls smoking regularly.
We also know from recent research that flavours are not enticing children to vaping either.
Evidence produced by a variety of organisations including ASH and the American Cancer Society (ACS) clearly shows that flavours do not entice non-smokers to use vape products either. Researchers from the ACS  found that flavours did not increase the attractiveness of vaping to teenagers. Rather, ‘Even after controlling for other statistically significant correlates, the odds of a smoker being willing to try a vaping were 10 times those of a non-smoker.’
However, for those adults who have switched to vaping, flavours are important. Why?
In research  carried out by Dr Konstantinos Farsalinos and others, vapers stated that the availability of flavours was ‘very important’ in their effort to reduce or quit smoking. This research also found that the majority of vapers would find vaping ‘less enjoyable’ or ‘boring’ if flavours were restricted, while 48.5 per cent of vapers stated that it would increase their cravings for tobacco cigarettes and 39.7 per cent of vapers said that without flavours it would have been less likely for them to reduce or quit smoking.
This major piece of research concluded:
That far from marketing flavours to attract children, flavours are marketed to ‘satisfy vapers’ demand’,
- Flavours contribute to both perceived pleasure and a reduction in the effort required to reduce or quit smoking,
- Restrictions on flavours could cause harm to current vapers, and
- Current flavour variability must be maintained.
The proliferation of flavours reinforces the view that these (vaping devices) are recreational consumer products, not smoking cessation aids, medicines or tobacco products.
PHW worry that certain flavours are created with children in mind, again this fear in unfounded. Research actually shows that adult vapers (18 – 65) prefer supposedly “juvenile” flavours .
According to recent figures, 19 per cent of Welsh Adults still smoke  and smoking remains the largest cause of preventable illness and death in Wales, responsible for 27,700 hospital admissions each year . This represents a considerable burden on the Welsh health service. In the UK, each year 114,000 people die from tobacco related illnesses according to figures produced by the NHS . We know that nicotine replacement therapies with their 90 per cent  failure rate do not work. We also know that vaping is at least 95 per cent less harmful compared to smoking, according to both Public Health England and The Royal College of Physicians .
There is never a situation where it is better to smoke than it is to vape. Removing flavourings risks driving existing vapers back to tobacco cigarettes and limiting the positive discrimination between smoking and vaping, which is a significant factor in encouraging smokers to transfer their usage to less harmful vape products. Research produced by the Consumer Advocates for Smoke Free Alternatives Association  found that just under two thirds of vapers would return to smoking cigarettes if vape products were made harder to get or were altered in some way such as through the banning of flavours. We hope that you will reflect seriously on the points we have placed before you and will withdraw your call for a ban on sweet-flavoured e-liquid. After all, if sweet-flavours were not important in helping smokers quit/switch why is MHRA approved Nicorette gum available in a range of sweet-flavours? 
Chief Executive, Independent British Vape Trade Association
 Research undertaken by Professor Peter Hajek, Director of the Tobacco Dependence Research Unit at Queen Mary University of London
 John Moores University – ‘Young People’s Perceptions and Experiences of Electronic Cigarettes’
 Dr Jed Rose, Director of the Duke Center for Smoking Cessation and a Professor in the Department of Psychiatry and Behavioral Sciences at Duke University Medical Center, speaking at the Global Forum on Nicotine (Warsaw, Saturday 6th June 2015)
 https://www.gov.uk/government/news/e-cigarettes-around-95-less-harmful-than-tobacco-estimates-landmark-review and https://www.rcplondon.ac.uk/projects/outputs/nicotine-without-smoke-tobacco-harm-reduction-0