by Carl V Phillips
This recent paper in Addiction by Hitchman, McNeill, and Brose, is a commentary calling for an “accurate and evidence-based debate” about e-cigarettes. I will admit that my favorite part of it is this reference:
Anti-THR lies and related topics [internet] 2014. Available at: https://antithrlies.com/2014/03/07/stanton-glantz-is-such-a-liar-that-even-the-acs-balks/ (accessed 11 March 2014) (Archived at http://www.webcitation.org/6OJPSzZLh on 24 March 2014).
I find it quite an entertaining citation, and for that I want to offer an apology to the authors. That post was properly cited because it was (in my possibly biased opinion) the best debunking of the spurious gateway claims that was published at the time of their writing. However, citing the title I published the analysis under must have given the authors pause. Fortunately they went ahead and did it anyway.
Not that the title is incorrect — it clearly was accurate. But this blog contains several different types of posts, and I try to reflect the type in the tone of the title. That post was one of more serious types, a deeper analysis that was basically a quick-and-dirty research paper, and I should have given it a fitting title. But when I first started writing it, I was heading somewhere else, and I failed to change the title to better reflect the ultimate content before posting. For that I apologize to Hitchman et al.
To remedy this, I have posted a working paper version at EP-ology. It is a more complete version of the analysis for those who read the first and want more. And it gives future authors something more complete and formal to cite. Comments on it are welcome.
Continuing with the Hitchman paper, after the section on the gateway hypothesis note that the gateway claims are not supported (citing the above), they suggest:
We think a useful research exercise would be to explore the ‘gateway’ hypothesis in more detail—what evidence would be needed before the ‘gateway’ hypothesis could be demonstrated to be accurate? Can we set a standard to which all academics would agree?
Great idea. I have mostly finished that paper (though I have no delusions about all academics agreeing about anything). This time I will release it under a suitable title, I promise.
The authors point out the flaws in current research practice that result from e-cigarettes being very heterogeneous, including their form factor, what they deliver, and how they are sold. They could have added “in their quality control” to that list. The authors soft-pedal the implications of research for this, but basically it boils down to: most generalizations are wrong. This is a good point.
I recall presenting at the European SRNT meeting in 2011 regarding a research agenda on e-cigarettes. My message (which I have been repeating for three years now) focused on explaining why detailed research on particular product or what happens to be the product-mix at a particular point in time was pointless. Chances are that by the time someone finished such a paper, the products they studied would no longer exist. Overview and less-detailed information is useful and more generalizable, but the super-specific analyses that are typical in the field are a waste of time, at best. They are potentially quite misleading for the reasons that Hitchman et al. mention, among others. After the talks in that session — and the other two presenters basically agreed with me, though had different main points — there was an extensive discussion among the room full of researchers who were just discovering e-cigarettes. Several of these comments consisted of someone proposing some ridiculously detailed analysis of a product or the current mix of products. I resisted the urge to scream: “weren’t you even listening?!!”
The problem is that e-cigarettes were dropped into a research community that is full of people who only have one hammer and so use it to hit whatever interesting topic comes along (which is not at all unusual in academia), and who had been studying a single consumer product and behavior that had not substantially changed for decades, and thus could almost be treated as having the properties of a physical constant (which is rather unusual). Their methods were poorly suited for studying e-cigarettes; this could be remedied but has not been (e.g., the continuing failure to figure out how to create a machine vaping regimen; the focus on chemistry that is relevant for cigarettes, but not e-cigarettes). But worse, their mindset was not suitable, and this probably cannot be remedied for most of them.
Hitchman et al. also adamantly argue that e-cigarettes are not tobacco products. My readers will know that I disagree. They assert:
Whether this is due to lack of knowledge, carelessness or attempts to associate e-cigarettes with the immense harm caused by tobacco, classifying e-cigarettes as tobacco is inaccurate and unacceptable.
It is not due to any of these. It is a legitimate categorization. The immense harm is caused by smoking. Other tobacco products — whether smokeless tobacco or e-cigarettes — do not create this harm. If the categorization tobacco products should not include e-cigarettes for the stated reasons, then it should not contain smokeless tobacco either, which seems like rather a strange claim to make.
We do not believe that NRT products are referred to as tobacco products, so why are researchers inaccurately classifying e-cigarettes in this way?
Um, actually I do refer to NRT products as tobacco products. They are low-quality tobacco products, but tobacco products just the same. What makes them such is their niche in society and behavior, not their regulation or manufacturing provenance. Most NRT products sold are used like e-cigarettes, cigarettes, smokeless tobacco, and other tobacco products — as a way of self-administering nicotine (and other chemicals), in a causal way, while going about one’s life.
Trains, ferries, and ride-share vans are all public transport, even though they are quite different physically, regulated differently (with some overlap, of course), and differ enormously in how hazardous they are. Similarly, broccoli, Big Macs, beans, and fugu sushi are all food products. There are useful subcategories within these collectives, of course. But the overarching category is also useful. If a natural-language term evolves to replace tobacco products as the overarching term, that is fine. But in the meantime, the accepted collective term is what it is.
The problem is not that these products have similarities that create a collective identity (in addition to their specific detailed identities). The problem is the tobacco control industry mentality that says “if it is a tobacco product, then we must treat it like we treat cigarettes” (even setting aside the issue of whether it is appropriate to treat cigarettes that way). But trying to socially engineer via vocabulary is a completely hopeless way to address that problem. (There is a reason we refer to ANTZ and not ATZ). Attempting to shield e-cigarettes behind terminology will not work and has many downsides. The viable response for those who object to e-cigarettes being treated “like tobacco products” is to push back against the much broader problems of how tobacco products are simplistically and inappropriately treated.
Tobacco harm reduction, anti-THR lies, and related topics 
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Reblogged this on artbylisabelle and commented:
Excellent
“Attempting to shield e-cigarettes behind terminology will not work……..”
Well …. it most certainly will not work if regulators can change the definition of ‘tobacco product’ whenever they like, even though legislators have defined the phrase ‘tobacco product’.
I am sure that there have been various definitions of the phrase ‘tobacco product’ in different jurisdictions. I cannot speak for other than the UK. Even in the UK, the Zealots have been messing about with the definition to such an extent that a ‘tobacco product’ need not contain anything at all produced from tobacco. For example, this in the The Tobacco Products (Descriptions of Products) Order 2003:
“References to cigarettes in the Act include products consisting in whole or in part of substances other than tobacco that otherwise conform to a description in paragraph (1) above, unless they are herbal smoking products.”
Because of the fiddling by Zealots, one has to go back to the original 1979 Act to get a specific definition of ‘tobacco product’:
Tobacco Products Duty Act 1979.
1 Tobacco products.
(1)In this Act “tobacco products” means any of the following products, namely,—
(a)cigarettes;
(b)cigars;
(c)hand-rolling tobacco;
(d)other smoking tobacco; and
(e)chewing tobacco,which are manufactured wholly or partly from tobacco or any substance used as a substitute for tobacco, but does not include herbal smoking products.
Yes, I know that the above is only concerned with the duty aspect, but, even so, it
does suggest that tobacco itself is not ‘a tobacco product’. Thus, cured tobacco leaf is not, in itself, a ‘tobacco product’ since it is ‘actual tobacco’. Note also that tobacco is not the green leaves of the tobacco plant any more than ‘bread’ is ears of corn on corn plants.
The importance of the above revolves around the phrase ‘tobacco product’ as a descriptor with specific meanings. Yes, nicotine may be produced from tobacco, but it is not a ‘tobacco product’ within the meaning of the ‘descriptor’. Nicotine can be produced from potatoes, tomatoes, egg plants, etc, Who know how many substances exist which contain nicotine? In every case, nicotine could be described generically as “a tobacco plant, egg plant, potato plant, tomato plant, etc product”. Is nicotine derived from a potato a tobacco product? I do not see why not since nicotine derived from either source is the same substance. Wherever it is extracted from, it is the same substance and is therefore described the same. Thus also, any other substance which can be extracted from any source whatsoever, which can also be extracted from the tobacco plant, is automatically a ‘tobacco product’.
—–
Thus, although I agree with you that it is a waste of time arguing about nuances, I still believe that vapers should fight like hell against the idea that e-cig juice is ‘a tobacco product’. If they do, and never surrender, then they will retain ‘the moral high ground’. If they do not, then they will be just ‘smokers’ under another name.
It really, really hurts one’s brain when ‘the system’ loses an entire comment which had be carefully thought out. The worst aspect is that it is almost impossible to reproduce it.
In the lost comment, I spoke about the meaning of the phrase ‘tobacco product’. It may well be true for all I know that a substance which is green in colour could be produced from tobacco plant leaves and which could be used for painting pictures. It would be true that the substance was produced from green tobacco plant leaves, but would it be true that it is a ‘TOBACCO product’? It might also be true that the same green substance could be produced from other green leaves like the leaves of the potato plant. Even if that substance was produced from potato plant green leaves, would it still be a TOBACCO product? I see no reason that it should not be.
That is, unless the phrase ‘tobacco product’ has been specifically defined as products which use tobacco itself.
I do not want to quibble as academics might, and so I shall not mention the various attempts by Zealots to fiddle with the definition of ‘tobacco product’, nor shall I attempt to argue about different jurisdictions. I can only talk about the UK. The definition of ‘tobacco product’ was stated in the Tobacco Products Duty Act 1979:
1 Tobacco products.
(1)In this Act “tobacco products” means any of the following products, namely,—
(a)cigarettes;
(b)cigars;
(c)hand-rolling tobacco;
(d)other smoking tobacco; and
(e)chewing tobacco,which are manufactured wholly or partly from tobacco or any substance used as a substitute for tobacco, but does not include herbal smoking products.
Yes, I know that the definition is only for the purposes of duty. But even so, despite the ‘ifs and buts’, it indicates that tobacco products are made FROM tobacco, and that tobacco itself is NOT a ‘tobacco product’. Further, the definition does not envisage such things as insecticides as ‘tobacco products’, even though the leaves of tobacco plants might be used to produce the substance.
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You might well be right in saying that it is a waste of time quibbling about whether or not e-cig juice is a tobacco product, but that does not mean that vapers must agree. In fact, they would be stupid to do so. If they are to maintain their hold on the ‘high moral ground’, they must fight like hell not to do so. In the UK, ‘tobacco products’ are products which CONTAIN dried, cured tobacco leaf. They are not products which are DERIVED from either dried, cured tobacco leaf or the green leaves themselves or, indeed, potatoes, tomatoes or egg plants. Good heavens! It could be stated that, if I compost tobacco plants, then the compost thus derived is a ‘tobacco product’!
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There is also another extension. Vapers ought not to be caught out be the same ‘divide et impera’ which has so enabled the persecution of smokers. I may be wrong, but it seems to me that e-cig suppliers are falling into the same trap as did tobacco manufacturers – they are thinking only about SELLING their products. They are not thinking about creating a ‘community’.
I could go further, and suggest that vapers and smokers could unite to contest the idea of ‘second-hand smoke’ and ‘second-hand vapour’ harm. But it will not happen. The reason is that denial of SHS harm is ‘politically incorrect’.
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At the moment, the Tobacco Control Industry stands in the place of “The King’s Court”. The problem is that no one know who is The King.
Apparently your previous comment was not entirely lost, but they were enough different I posted them both. As you note, artist’s paint made from tobacco would not be a “tobacco product” in the sense that the term is used, even though it is based on provenance. This makes it clear that provenance is not the determinant of the definition. Nor is regulation. Regulators can choose (subject to getting permission or at least no push-back from the lawmakers) to include e-cigarettes in any control/tariff/limitation that affects that affects cigarettes, or to not do so. They can make the same decision about coffee or liquorice too. Their decision is not substantially affected by either the reality (as defined however) or the natural language vocabulary, and likewise does not define those. I am genuinely baffled about the extent to which people think otherwise.
Well, if you want to mince definitions, in the european “regulation” TPD, e-cigarettes are really NOT defined as tobacco products, contrary to common “knowledge”:
http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L:2014:127:FULL&from=EN
The definition of tobacco products (2.4) does NOT apply, since ecigs contain nicotine, but NO tobacco.
The definition of ecigs (2.16) does NOT define them as tobocco products.
And look at the Titles:
TITLE II – TOBACCO PRODUCTS
TITLE III – ELECTRONIC CIGARETTES AND HERBAL PRODUCTS FOR SMOKING
They ARE regulated in an independent category, which used to be “NON TOBACCO PRODUCTS” before they renamed it. But it is still semantically seperate and forcing the issue would also define herbal smokes as tobacco products which contain neither nicotine nor tobacco.
How would the party people from Boston have reacted if some regulator would have defined coffee to be a tea product? ;)
Or what would be the reaction today, if someone declared cola to be a coffee product?
Wouldn’t that call for a nice padded cell?
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Well, it’s about harm, tax and regulation (more accurately unjust tax and regulation). This is politics not science: what we call things does not have to be scientifically accurate. Because you are a scientist, you see every issue as a science issue and therefore things need to be accurately classified, and for you a taxonomy error is as serious as a factual error.
The reality is that tobacco = high taxes (massively disproportionate to the harm caused, even for cigarettes), unjust regulation (look how crazy the regulation of ST is in Europe), and public disapproval. Since ecigs are likely to cause about as much disease and death as cosmetics and nutritional supplements would if unregulated, then a regulatory scheme appropriate to cosmetics and nutritional supplements is right for ecigs. This is absolutely impossible if a tobacco products classification is used, wherever in the world we are talking about.
Electronic vapourisers are a new product class and they could equally well be slotted into a tobacco product classification or something entirely new. The question is whether or not a tobacco classification could ever result in a just and appropriate level of regulation and taxation, and the answer is a resounding no. The science is not important here, you of all people should realise that it is irrelevant at policy level. Therefore, as we already know that ecigs can never be appropriately regulated while classed as tobacco, the best option (if it were available) would be a new and independent product class.
Since I am a realist and therefore well aware that this will never happen, I am happy to concede that the nomenclature is a theoretical and irrelevant argument. We are stuck with tobacco and always will be, because political expediency rules; so it is better to concentrate on mitigating the damage than yearning for the impossible. Perhaps you would be happier, then, if we talked about creating a new class of tobacco (or nicotine) products within the overall grouping that might better address a tax and regulatory climate appropriate for ultra-low-risk products.
For many of us, calling nicotine vapourisers or pills ‘tobacco’ simply because of their usage mode is ridiculous. For the sake of expediency we will agree that if you want to call it tobacco, then you need to come up with a sub-classification that is independent in every way of the regulations and taxation that, rightly or wrongly, are applied to cigarettes. That looks like a tall order.
Once again, I am not talking about regulation, but identity. And, no, it is not motivated by science. If I were making a scientific claim that depended on the categorization, rather than using it more vaguely, I would need to define exactly what I meant. And in that rarified environment, it would not matter what I called it — it could just be Category X. The same is true for any subcategory thereof (though I would not need to make up new names — they exist in natural language). I am actually motivated by what constitutes useful understanding of the world. So long as a product occupies a weird niche in itself, it can exist outside the broad social categorizations. Once it becomes mainstream and is a widespread substitute for smoking, then it is in the same social category as smoking, whatever that might be called.
Therefore we are talking about two separate things: a convenient description and a sensible taxation and regulation category. The two things are mutually exclusive: calling something tobacco automatically assigns an unrealistic management structure. Ecigs can never achieve what we want them to achieve while termed a tobacco product – they become part of the problem instead of the solution.
If you want it to work, at least as far as ecigs are concerned, then you can’t call it tobacco or smoking. I know this is difficult for you because of your investment in ST and THR. You have to let go; or see ecigs fail.
Mind you I fully realise that what you or I want is irrelevant, of course: this is a financial issue and nothing else has any relevance.
Well, I would like to think that in the world of words about this topic, what I think and do actually does change the discourse. And I am going to stick with recognition of the broad category of “devices for the self-administration of nicotine and other psychoactive constituents of the tobacco leaf”, currently known as “tobacco products”. It is useful in terms of communication and conceptualization and I believe that to the *very tiny* extent its use might influence policy, it will nudge it in a more rational direction, not a bad one.
I think it is a mistake to classify them as tobacco products and it will nudge it in the more irrational direction, even if your aim is laudably different. It’s not a mistake of logic necessarily, though we don’t always categorise products according to the crude source of a single feedstock – we identify wine as an alcoholic product (identifying it according to the active drug) rather than a ‘grape product’. The real reason is pragmatic, because once described as ‘tobacco products’ a whole lot of things that apply to tobacco products are likely to be applied by default to e-cigarettes – whether we like it or not, and however irrational that is. WHO wants to classify e-cigarettes as tobacco products for precisely this reason – so that it can assert jurisdiction over them through the FCTC and apply the controls of the FCTC to them. WHO wants them included in targets to reduce tobacco consumption, instead of using them to reduce (smoked) tobacco consumption. It wants their advertising banned and their vapour treated as though it was second hand smoke. The FCTC would define e-cigarette companies as ‘tobacco companies’ and subject them to marginalisation through Article 5.3. It would advise governments to raise taxes on e-cigarettes and run campaigns against them.
It’s little better in the US… defining e-cigarettes as tobacco products has absolved the FDA and Congress of their responsibility for crafting regulation that is purpose built for e-cigarettes and fit for purpose – something that the FSPTCA and PMTA regime most definitely are not. FDA and WHO shouldn’t do this, but they just will. It is not a good idea to assist them. Would you oppose a legal action against FDA brought by an e-cig manufacturer to challenge the decision to classify them as tobacco products?
I think it is better to define the broad category as recreational nicotine products and see e-cigarettes, cigarettes and all other forms of nicotine used for non therapeutic purposes as sub-categories.
(sorry for the delayed posting — was not attending to this blog for a while)
I notice two things about the active disagreements with my suggestions that the natural terminology for all of these products is “tobacco products”:
1. They always come from Europeans.
2. They never respond to my key point that natural language and functional thinking, whichever way they go on this, do not affect how regulators will choose to regulation non-traditional tobacco products.
I am not entirely sure what to make of that.
Also, I have made it clear that my view of the natural definition of the classification is largely independent of provenance. It definitely does not influence me (if any of these products used ingredients produced in a lab, it would still be part of the natural category).
This argument comes from Europe because we think differently about this – clearly – and other related topics. For example, we would regard a situation where a $1.5 billion industry can operate without any regulation whatsoever as close to lunacy: how do you stop poisonings, electrocutions, or other serious abuses of consumers? But in Europe, as soon as a product hits the shelf it is automatically regulated. In the UK, ecig products are comprehensively regulated by 17 statutes without doing a thing (some say 21). In addition, the local inspectors enforce this consumer product regulation that applies, automatically, to everything everywhere as soon as it is sold. Of course the system is not perfect and I’m not suggesting it is; just that at least we have a system. So you can see that the EU and US situations are fundamentally different, and this is reflected in different evaluations. We don’t need to force a square peg into a round hole, because we already have a system that works reasonably well; not a black hole where everything needs to be invented from the ground up.
Secondly, you yourself declare that what you say can affect the outcome (and I agree); and that what a product is classified as will not affect the outcome – with which I agree in the short term but not for the ultimate outcome. We both agree that (any aspect of) the current debate will not affect the immediate outcome: legislators and regulators will come down hard on ecigs. I regard this as a purely commercial issue, as you know, whereas you probably ascribe additional motives to the regulators. I agree that ideology is important because it provides the footsoldiers, but without the vast commercial backing for resistance to ecigs, the zealots wouldn’t get anywhere.
In the short term we really can’t do anything about the situation in the EU or USA without a major legal challenge. A successful challenge won’t affect the overall issue of product classification, but it might remove some of the more draconian rules that will otherwise shut down 95% of the ecig business and remove 99% of current products from the legal market. The situation in the US will be worse, faster (it will get tough everywhere since, obviously, the agenda is to remove ecigs by any method that can be politically and legally effected).
In the long term, when tens of millions of vapers have come up through the black market, they will make this a voting issue. Vapers won’t bend over and take it up the jaxi like smokers did – vapers will fight, and when 15% of the population vote on the issue then most of our problems will be resolved. They will be helped by a historical record of pressure not to regulate clean nicotine delivery systems as tobacco, which is the logical approach to take when something is part of the solution not the problem.
You risk becoming part of the problem, not the solution, if you support the regulation and taxation of ecig products out of existence, which is what a tobacco products classification automatically achieves. You may think you can affect some aspect of the regulation, but you can’t; therefore it is better to be right from the start, and to avoid accusations in the future that you contributed to the problem by thinking that what you and colleagues argued might somehow reduce the impact of regulation.
Regulation is decided in the offices of multinationals, not those of their wholly-owned government agency puppets. Stop thinking you can tell Pfizer how to regulate ecigs, because you can’t.
Ok, I am going to try to summarize the protests from Europe in as jingoistic a way as possible: The neo-royalist aristocracy who still rule Europe are so simple-minded that (a) they can be tricked into not regulating something by wordplay and (b) are so lazy that if you tell them that two products have any similarities whatsoever they will just glom onto that in order to impose insane decrees like “bananas are fruit, the fruit we already regulate are round, therefore bananas in the common market must be round.”
Perhaps.
But in that case, I think you have bigger problems than the natural use of the language. Have you considered trying to have an Enlightenment? Or maybe a rebellion? Just a thought.
Well, at least I tried to make sense.
To Carl Phillips. Your response at (b) above is probably, sadly, about right. Certainly when it comes to tobacco products and their smoke-free alternatives. Its more of a knee-jerk response than one amenable to logic. Mention the word tobacco or cigarette and the reaction from the European bureaucrats (our neo-aristocracy) is an automatic “regulate it! ban it!”. Public health, it seems, no longer really cares about health, just about the current ideologies. And then, of course, there is the WHO, who don’t just influence OUR lawmakers but most of them around the globe. Doctor WHO? Wish I could “doctor” them so as to render them impotent!
Well put. Hear, hear! Not saying I understand all the nuances of this rather abstruse debate, but I believe you have the right of it.
If what Brad Rodu says is true, and e-cigs MUST be classed as tobacco products in the USA, what might that mean for e-cigs globally?? I mean, if European ANTZ see them classified as tobacco products in the States, won’t they then push for similar classification in Europe??
In the US, ecigs clearly fit the definition of a tobacco product for regulatory purposes, according to the Tobacco Control Act (any device that contain nicotine, anyway — see my recent post on Predicting the Black Market). But again I repeat the point that how people understand them does not define how they are regulated. The regulators can do whatever they are allowed to do, regardless of natural language. They should be understood to be drug delivery devices, by the natural usage of that term, but that does not mean they can be regulated as “drug delivery devices” by the FDA (they can’t, a court ruled). If the EU regulators defined them as “domesticated exotic reptiles”, they would be regulated as such, regardless of the fact that no one thinks of them as such.
There is only one aim of ecig regulation and it is to remove them from the market as far as is possible.
Ecigs are now classed as tobacco products in the EU, since they are regulated by the TPD as such. Originally it looked as if this was the fallback plan if medicalisation failed; but assuming that people who control assets of hundreds of millions of dollars probably aren’t stupid, then it must have been clear to them that medicalisation would fail either at the TPD stage or by legal challenge (as there is a 100% record of medicalisation of ecigs being overturned by the courts globally, including multiple instances in the EU). Therefore it is more logical to regard a tobacco classification as the original and preferred target, since tobacco regulations can be used to shut down all aspects of the ecig market except main street sales of ineffective mini ecigs by major tobacco corporates – a dead end as far as large-scale smoker conversions is concerned.
There are plenty of advantages to giving the ecig market to the major cigarette firms, the most obvious being that they certainly won’t work hard to eliminate tobacco cigarette sales.
We all recognise that tobacco product classification is unavoidable, and anything else is an impossible dream (at this time). The implications of such a classification are very simple: 99% of ecig products will be removed from the (legal) market by force. Our hopes are now pinned on the black/grey markets becoming as efficient as possible, so that the number of vapers can be increased to a level that will become a useful voting bloc. We already know that this is about 15% of voters, so that is our target.
It is the only realistic way of getting a full legal status for effective vapor products; with current and proposed regulations, ecigs are finished (legally). Government (a loose term meaning anyone who can legislate anywhere) strongly depends on the revenues, savings and benefits generated by smoking. All ecigs do is turn off the money tap.
And, once again,what I was saying in this post about the fundamental nature of e-cigarettes was not related to the best way to regulate e-cigarettes.
While I am sympathetic to the dream of defining e-cigarettes separately from tobacco products, European THR advocates need to understand that, in the U.S., virtually everything that consumers ingest is regulated by the FDA as a food, medicine, cosmetic or tobacco product. European THR advocates want a new scheme for e-cigs, which would require at a minimum for Congress to (1) redefine them (as what?) by revising the TCA; (2) create a new agency to manage them. Neither of those events will ever happen, and there is no precedent for a new scheme. A similar recreational drug (with no hazardous delivery system) is caffeine, and it is regulated as both a food (additive) and as a medicine.
We are stuck with a bad law containing many bad provisions for THR, which is why a tiny minority (Carl, Bill Godshall, myself and a few others) unsuccessfully opposed it. Carl’s position on American e-cigarette classification is well articulated. It is indisputable that e-cigs are tobacco products in the U.S.
Well, then it’s obvious: It must be a cosmetic product!
Main ingedients: Propylene glycole, glycerol, and water just like in a lot of cosmetics. Scented like most cosmetics.
;)