May 21, 2019

Stanton A. Glantz, PhD

Consultation on Potential Regulatory Measures to Reduce Youth Access and Appeal of Vaping Products: Evidence and Recommendations from the U.S. Experience

My colleagues and I just submitted this comment to Health Canada on e-cigarettes.  A PDF is here.


Manager, Regulations Division

Tobacco Products Regulatory Office

Tobacco Control Directorate

Controlled Substances and Cannabis Branch

Health Canada

Address Locator: 0301A

150 Tunney’s Pasture Driveway

Ottawa, Ontario K1A 0K9

[email protected]



Consultation on Potential Regulatory Measures to Reduce Youth Access and Appeal of Vaping Products: Evidence and Recommendations from the U.S. Experience


Bonnie Halpern-Felsher, PhD;1,2 Lauren Kass Lempert, JD, MPH;1 Minji Kim, PhD.;1

Lucy Popova, PhD.;3 Shannon Lea Watkins, PhD.;1 Benjamin Chaffee, DDS, PhD.;1

Karma McKelvey, PhD, MPH;2 Julia Mcquoid, PhD.;1 Emily Keamy-Minor, BA;4 Matthew Springer, PhD.;1 Pamela Ling, MD, MPH;1 Stanton Glantz, PhD1  


1UCSF Tobacco Centers of Regulatory Science

2Stanford University, Department of Pediatrics, Division of Adolescent Medicine

3Georgia State University

4 Stanford School of Medicine


(All authors declare they have no conflicts of interest with the tobacco, vaping, and/or pharmaceutical industries)


May 21, 2019



  1.   Health Canada should prohibit all flavors in all e-cigarette products

The tobacco companies, including their e-cigarette companies, add characterizing flavors like mint, menthol, fruit, and candy to tobacco to attract young and new users, often using the same flavorants that are in fruit-flavored candy, and sometimes at higher doses.[1] These flavors appeal to new users by masking the harsh taste of tobacco, and in the case of e-cigarettes, resulting in a more pleasant smell than that found with tobacco alone.


Flavor or “taste” is one of the most common persuasive marketing techniques used to promote food (mostly candy and snacks) to children on TV.[2] Exposure to ads for flavored products is positively associated with youth consumption,[3] and most money spent by youth is on food or beverages, particularly sweets.[4] Research on e-cigarettes shows the same thing, concluding: flavors play an important role for online e-cigarette marketing and boosts user interaction and positive emotion;[5] flavored (vs. unflavored) e-cigarette ads elicit greater appeal and interest in buying and trying e-cigarettes; and the appeal of ads marketing flavors is linked to rapid and persistent adoption of e-cigarettes among youth.[6]

Youth are Attracted to Flavored Tobacco Products

Looking at the experience in the United States, which is likely similar to the Canadian experience, the vast majority of youth in the US who try tobacco initiate with flavored tobacco products, including 81% of e-cigarette ever users, 65% of cigar ever users, and 50% of cigarette ever smokers.[7] Adolescents are more likely to report interest in trying an e-cigarette from a friend if it is menthol-, candy-, or fruit-flavored than if unflavored.[8] Flavor preferences are associated with higher e-cigarette use among adolescents.[9] Most adolescent current tobacco users cite flavors as a reason for use (including 81% for past 30-day e-cigarette users; 74% for past 30-day cigar users).10 Three quarters of adolescent and young adult flavored tobacco product users reported they would quit if flavors were unavailable.[10]

Youth and young adult tobacco users are more likely than older adult tobacco users to use flavored products, including menthol cigarettes,[11] flavored smokeless tobacco,[12] and flavored cigars.[13] Young smokers (12-17 years of age) are three times as likely to smoke menthol cigarettes than smokers 35 years and older.[14]  Research among approximately 4000 school-going youth shows that for 98% of them, first e-cigarettes used were flavored to taste like something other than tobacco, compared to 44.1% of older adults nationwide. Fruit and candy flavors predominated for all groups; and, for youth, flavors were an especially salient reason to use e-cigarettes.[15] Finally, a 2018 study showed that only 1.5% of adolescent and young adult e-cigarette users used tobacco flavored-Juuls and .9% used tobacco-flavored other e-cigarette products.  Instead, the majority used fruit or dessert flavors (33% for Juul users and 64% for other e-cigarette users) and 27% of Juul users and 12% of other e-cigarette users used mint or menthol flavors.[16]

Youth Believe Ads for Flavored E-cigarettes Target Them


Using flavors in e-cigarettes is a key marketing strategy to reach and recruit youth. In a 2014 study of English-language websites, over 7,700 flavors for e-cigarettes were available, with greater than 240 new flavors being added per month.[17] What is most important is that youth find flavored e-cigarette ads are relevant to them.

            In a U.S. study,[18] California adolescents and young adults (mean age 17.5, SD = 1.7), were asked to indicate whether eight different ads for flavored e-liquids (Figure 1), randomly displayed, target someone younger than them, their age, a little older, or much older. Overall, ads were found to target someone just a little older than them (age 18 – 26), their age, and those youger, but were not found to target someone much older. More than half of participants felt ads for cherry, vanilla cupcake, caramel, and smoothie flavors were for someone their age. These findings suggest that while the tobacco industry argues that flavored tobacco products, including sweet and fruit flavored products, are not meant to attract youth, youth see them as aimed at them. Further, these and similar findings suggest that Health Canada should prohibit all flavors in e-cigarettes.