Electronic Cigarette Industry Trade Association
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It was largely due to the collective voice, and hard work from across the vaping community, that this proposal was overruled, and the industry was given the time to grow, and develop to the point of that all-important 'critical mass'.
Since that time, ECITA has continued to work hard alongside the regulators and policy makers, the scientific community, the tobacco control sector, and you, the independent vaping industry, as well as the growing number of consumers advocates, to further promote the continued availability of these products which have proven so miraculous for the consumers who use them.
The industry continues to face fierce opposition from various quarters, and so our work is not finished yet. We believe that, with a stronger collective voice of the independent industry, we can continue to influence the UK government to do its best to implement the Tobacco Products Directive (TPD), and any future regulations, in as proportionate a way as possible, so that they are achievable for the industry, but also address the legitimate concerns about quality and safety standards.
Over the last 6 years, ECITA has built strong connections with policy makers and it is with these long-standing relationships that we are able to raise UK independent sector concerns about the impact on your own businesses directly with the decision-makers at each level.
Katherine Devlin, ECITA's President, has twice given evidence to the Health and Sport Committee of the Scottish Parliament. Transcripts are linked below:
Katherine and Tom Pruen, ECITA's Chief Scientific Officer, both presented evidence to the Welsh Assembly. The video may be viewed here. Ultimately, the Public Health (Wales) Bill was voted down, so there is no longer a pressing threat of a ban on the use of vaping products in public spaces in Wales. This is wonderful news for the whole vaping community, and avoids there being a legal precedent set for public place bans in the UK. Rather, this is an excellent precedent against carelessly including vaping legislation in other Bills.
From the outset, ECITA has been focussed on helping the sector to drive up standards - particularly with regard to quality and safety. This is not only good for your customers, but also protects your business from aggressive enforcement actions, and - in a worst case scenario - expensive legal suits if someone were to be harmed by a product you sold to them.
As the regulatory rumblings grew louder, and the 'anti' voices became more aggressive, we realised that we would need to take further action, in order to demonstrate that the independent vaping sector can behave responsibly, and contribute to significant public health gains. We were approached by the British Standards Institution (BSI), and ECITA's members agreed to sponsor a pre-standard: PAS 54115. BSI invited ECITA's Chief Scientific Officer, Tom Pruen, and its President, Katherine Devlin, to provide Technical Authorship for this document.
|PAS 54115:2015 was published in July 2015, and is available from the British Standards Institution.|
Now, we are actively involved in the development of European standards, with representation on all four of the Working Groups of the CEN Technical Committee 437:
Working Group 1: Definitions
Working Group 2: Devices
Working Group 3: Eliquids
Working Group 4: Emissions
ECITA's Chief Scientific Officer, Tom Pruen, was voted in as Convenor of the Working Group on Eliquids by 10 out of 16 Member States' standards delegations.
New UK legislation was introduced in October 2015: The Nicotine Inhaling Products (Age of Sale and Proxy Purchasing) Regulations 2015. Since late 2013, ECITA has been working with a dedicated group at the House of Lords on Age Verification for Online Sales. The group is the Digital Policy Alliance (DPA), and at ECITA's recommendation, work has now begun to produce a PAS with BSI for this work.
This will provide an opportunity for businesses in the independent vaping sector to demonstrate - with sufficiently robust evidence - that they are meeting the requirements set out in the new Regulations. Furthermore, we have been able to negotiate with the UK Department of Health, and persuade them to allow the work of the DPA to be completed before there is any significant enforcement action.
We recognise - and share! - the frustration across the sector, concerning the lack of information on the practical requirements of TPD implementation. We have been heavily focussed on the solutions for your businesses to remain viable post TPD. Once there is clarification from regulators on the Directive, we shall be able to provide ECITA members with detailed - and accurate! - advice.
However, this does not mean that nothing can be done to prepare your business for what is coming. As soon as the TPD was finalised, back in late 2013, we identified the two most challenging - and potentially devastating - requirements: toxicology and emissions testing. Ever since then, we have been working on solutions for your businesses.
|Toxicology data is required by the TPD, and is very time-consuming and horribly expensive. I am delighted to be able to inform you that the key component of this project, i.e. the actual work of properly qualified toxicologists to carry out the necessary assessments, is now well underway. To find out more about the Toxicology Collaboration Project, please contact VKC Regulatory and Scientific at firstname.lastname@example.org.|
At the heart of this Project is one very simple idea:
And it really is that simple! We have a small group of collaborators, drawn from ECITA's eliquid manufacturers, who have been brave enough to take the plunge and get this project off the ground. They have provided the toxicologists, bibra, with funds to start the work, and with an agreed list of compounds for them to assess. This Project is being administered by ECITA's management company, VKC Regulatory and Scientific Ltd.
There is more information about the Toxicology Collaboration Project in The Toxicology Collaboration Project: FAQs. The good news is that you can be assured that you will have the opportunity to access the toxicological data required for your notifications at an extraordinarily discounted cost, and that sufficient toxicologist resources are already in place and getting on with this work for all of you. (The Toxicology Collaboration Project is offered to all businesses in the sector; you do not have to be a member of ECITA to take advantage of this opportunity.)
This continues to be a headache for the MHRA, as competent authority, and I know it is a matter of grave concern for the businesses in the sector. Our primary concern has centred around one key point: whatever the solution for emissions testing, it needs to be affordable, and widely available at as many testing houses as possible - otherwise, the majority of you will simply not have time to get your testing done in time for your notifications.
|The European standards (CEN) Working Group on Emissions is being led by Professor Riccardo Polosa, a highly respected leader in tobacco harm reduction research, and author of a significant number of published papers on the science of vaping products. However, it is absolutely impossible for that work to be completed in time for the implementation of TPD; the European standard will take at least two years, and probably longer.|
This does not leave us in a vacuum, however. Tom has been proactively trying to engage with a number of different testing laboratories over the past two years, and this is finally bearing some fruit now. Indeed, there is now a collaborative effort between a group of reputable analytical labs to agree a methodology, and work towards validating it. They have asked Tom to liaise directly with the MHRA, since ECITA has such a long-standing relationship with them, and this is already underway.
There has been some very promising work from some of these analysts, particularly in the case of the Guernsey States Analyst, who has been developing a method (initially based on the test bed atomiser developed by Tom and Vicky) which has excellent prospects of being affordable, repeatable, and validatable. Other labs are also making some real headway, and we look forward to seeing what they will have to offer for you.
So yes, we are still waiting for clarity, but there is real progress in some of the key areas of concern.
ECITA has much more still to do. The European standards work will be an ongoing project, requiring resources for years to come, and the implementation of the TPD will not be the end of regulatory interventions on this dynamic sector. Already, the question of taxation is looming large.
We hope you will want to support the work that ECITA does to benefit the whole vaping community. We look forward to continuing to drive up standards, protect consumers, and support all the businesses in the sector.
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