x This is likely to be onerous and of no health benefit. However, if there are some additives for which there is Requirement for annual testing of product concern, uppoer limits could be set composition and licence fees for adding such ingredients be set high enough to cover compliance monitoring. Probably not necessary, unless Prohibition on free distribution and awards evidence that these appeal to associated with sales Prohibition on discounting I don’t have a clear view on this x See above, limited, but not prohibited Prohibition on advertising and sponsorship x As above may have a negative impact on the impact of warnings on Requirement for standardised packaging products which are really harmful Other Q7 Do you think it is important for legislation to impose some form of excise or excise-equivalent duty on nicotine e-liquid, as it does on tobacco products? Yes No x Reasons/additional comments: I think it is perfectly reasonable for there to be an excise, but strongly believe that it should be set at a far lower level (for equivalent use) than for smoking. If and when these products replace smoking pretty much completely and there is no mass consumer market for smoking tobacco, then governments might use it as a useful revenue raising exercise Q8 Do you think quality control of and safety standards for ecigarettes are needed? Yes x No Additional comments: Area of concern Yes No Reasons/additional comments x Possibly not needed on toxicological grounds, but as they are likely to be Childproof containers left around and not kept out of reach, this is produnt x No issue for the liquids at levels likely to be allowed. Device batteries should Safe disposal of ecigarette devices and liquids be dealt with under same requiremetns of other similar batteries. Not sure what is meant by this. If batteries made to good manufacturing standards and certified (eg CE) this should suffice. They should be treated Ability of device to prevent accidents like any other consumer electric device that is likely to be placed in close proximity to the body. x Good manufacturing practice x Purity and grade of nicotine
Requirement for annual testing of product composition x This is likely to be onerous and of no health benefit. However, if there are some additives for which there is concern, uppoer limits could be set and licence fees for adding such ingredients be set high enough to cover compliance monitoring. Prohibition on free distribution and awards associated with sales Probably not necessary, unless evidence that these appeal to Prohibition on discounting I don’t have a clear view on this Prohibition on advertising and sponsorship x See above, limited, but not prohibited Requirement for standardised packaging x As above may have a negative impact on the impact of warnings on products which are really harmful Other Q7 Do you think it is important for legislation to impose some form of excise or excise-equivalent duty on nicotine e-liquid, as it does on tobacco products? Yes No x Reasons/additional comments: I think it is perfectly reasonable for there to be an excise, but strongly believe that it should be set at a far lower level (for equivalent use) than for smoking. If and when these products replace smoking pretty much completely and there is no mass consumer market for smoking tobacco, then governments might use it as a useful revenue raising exercise Q8 Do you think quality control of and safety standards for ecigarettes are needed? Yes x No Additional comments: Area of concern Yes No Reasons/additional comments Childproof containers x Possibly not needed on toxicological grounds, but as they are likely to be left around and not kept out of reach, this is produnt Safe disposal of ecigarette devices and liquids x No issue for the liquids at levels likely to be allowed. Device batteries should be dealt with under same requiremetns of other similar batteries. Ability of device to prevent accidents Not sure what is meant by this. If batteries made to good manufacturing standards and certified (eg CE) this should suffice. They should be treated like any other consumer electric device that is likely to be placed in close proximity to the body. Good manufacturing practice x Purity and grade of nicotine x
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