Is RRP waste the biggest threat to THR?

Tobacco harm reduction (THR) continues to face many hurdles, the most significant of which has been the influence of Bloomberg Philanthropies over global health policy through its funding of the WHO.

In our blog post, Bloomberg Philanthropies - Taking Tobacco Tactics to the Next Level, we argued that it was reminiscent of the tactics and pseudo-science employed by the US tobacco industry after the formation of the Tobacco Industry Research Committee in 1954. In the end, the pseudo-science was exposed for what it was, and it is only a question of time before the same happens to the misinformation propagated by those opposed to THR.

The science underlying the potential environmental and health risks posed by the inappropriate disposal of reduced-risk products (RRPs) is on rather more solid ground, though. Given a well-funded opponent whose arguments are currently rooted mainly in questionable science, incentives for the industry to find and implement effective solutions extend beyond “normal” environmental and social responsibility.

Following a decision at COP7 – FCTC held in Dehli in 2016, the WHO published Tobacco and Its Environmental Impact: An Overview in 2017. Given its origin, it is clear that the motivation for the report was tobacco control rather than environmental concerns. From the foreword by Dr Vera Luiza da Costa e Silva, then Head of the WHO FCTC Secretariat: “The alarming rise in tobacco consumption and related deaths has turned the battle for tobacco control from one focused primarily on educating a sceptical public about tobacco’s health threat to one involving public engagement on much broader fronts – including on the subject of this overview: the severe and noxious effects of tobacco on the environment.” She further says, “The overview rightly highlights concepts such as Extended Producer Responsibility (EPR), which seeks to reduce a product’s environmental impact by making the manufacturer responsible for its life-cycle costs. Properly implemented, this would result in tobacco product price rises, while relieving municipalities and their citizens of a significant and unreasonable cost.” (Own emphasis).

Although this report dealt mainly with cigarettes over their life cycle, it devoted a page to “Electronic nicotine and non-nicotine delivery systems”, postulating that “Hard plastic disposable ENDS/ENNDS liquid cartridges may become the cigarette butts of the future.” It further suggested that “Extended Producer Responsibility must be in place to take stock of the environmental harms that will result from these new devices. Any projected declines in the market for conventional cigarettes needs careful mapping as the tobacco industry has launched alternative nicotine delivery systems that heat but do not burn tobacco”. (Own emphasis).

The explosive growth in the popularity of disposable vapes has resulted in an equally significant rise in the level of environmental concerns being raised. In the UK, the supermarket chain, Waitrose, announced on 3 January 2023 that it would discontinue the sale of single-use vaping products. Less than a week later, Scottish PhD student and activist, Laura Young, made headlines after a video of her collecting 55 disposable vapes on her dog walk, went viral. Her call to #BanDisposableVapes has attracted significant attention and is supported by the Marine Conservation Society.

On 14 January, the UK Vaping Industry Association (UKVIA) issued a press release saying that the industry was working to address its environmental responsibilities as the focus on sustainability issues was gathering momentum. It further stated that it and its members were in discussions with several waste companies to create a recycling solution that was “fit for purpose for the vaping sector”.

Vaping products present unique recycling challenges owing to their design and the different types of waste they generate. Batteries and circuits are regarded as electronic waste and must be disposed of accordingly, whereas nicotine residue and heavy metals are considered hazardous waste in most jurisdictions. Furthermore, most vaping products contain various types of plastic, which must be disposed of as plastic waste.

Before arriving at a waste management solution, there needs to be clarity on the regulatory regimes that cover the different types of waste generated. Furthermore, product manufacturing innovation that leads to a simpler recycling process and regulatory burden could also be part of the solution.

A critical part of any waste management programme is end-user education and participation. Consumers need to know how and where to dispose of their waste products, and it needs to be easy for them to do so. Providing incentives could help, or a deposit scheme might be introduced.

The recent publicity around the issue of RRP waste in the UK provides a clear incentive for the industry to prevent further, potentially significant, obstacles to THR. In the words of John Dunne, Director General of the UKVIA: “This is why we are working hard as an industry to find a waste management solution that minimises the impact of vapes on the environment, particularly when it comes to single-use disposables, so they are seen for what they do best - helping adult smokers kick their habits and save the lives of millions, as well as millions of pounds for the health service.”