E-liquid taxing scheme proposal doing the rounds in Finland

There are a few common constants in the way the Finnish government treats vaping products.

The primary one is that they release a legislation draft, and all the communication around the details in public are made with certainty. This is what we'll do and this is what will happen. No ambiguity whatsoever. Then various organizations and special interest groups make their statements, including whatever arguments and (occasionally, but mostly no) data they deem relevant to the issue.

More often than not, these statements include several points where the law could be stricter.

Committees hear out the statements, and then go on to change more or less nothing.

Makes you feel like the commenting process is just for show.

The other one is that most of the justifications so far have been disjointed to some degree. A lot of jumping to conclusions happens around issues where no substantial evidence exists, making assumptions about the impact of certain things without considering if such events are even plausible.

This time though, the tax law proposal manages to first make a rational assessment about the impact of a sin tax on e-liquids and instantly ignore it's implications completely:

"It can be assumed, that if e-liquids are not taxed, their consumption as a substitute for conventional cigarettes would decrease the consumption of products currently subject to tobacco tax" aka smoking, since all other forms are illegal.

And then they go on to claim this:

"The decrease om consumption of electronic cigarettes due to the implementation of the tax can be estimated to have a positive impact on public health. The positive impact is assumed to be associated with the prevention of uptake of electronic cigarettes, which would prevent the development of nicotine addiction"

No citations of any kind included. No consideration of the fact that the vast majority of vapers are current or former smokers. They also claim there's no tax on electronic cigarettes, which is blatantly false since VAT applies like everything else.

Like I said, disjointed. Very much so.

The Finnish goverment is proposing a tax of 30c per ml, or 3 euros per 10ml bottle. The proposal calculates that the cheapest liquids would double in price with the implementation of this tax. And they want to apply it to both nicotine liquids and nicotine free liquids, based on the idea that this way nobody needs to test if the liquids have nicotine in them or not. Though there's some more gaps in that logic, since every single liquid has to go through the notification process anyway with mandatory testing of the nicotine content and exposure and has to have nicotine volume marked on it..

They do note that the tax would likely increase overseas sales of nicotine free liquids, since they are not subject to distance sales restrictions like nicotine liquids are. I'd estimate that the future liquid market for knowledgeable vapers will develop something like this: People will order large amounts of nicotine free liquids overseas, since it's likely to be around 50-60% cheaper and non-tobacco flavored liquids are illegal here, possibly smuggle high strength nicotine and mix their own. The rest will buy home mixed liquids from other people in dedicated facebook groups.

Current smokers and very new vapers, as in the people who are not part of online communities though?

Screwed.

Basically people will either be ignoring the law or be hurt by it. It will cause unnecessary and arbitrary criminality and death.

Part 13: Thoughts on harm creation

Lately, I've been watching some very interesting lectures on the underlying factors that lead to and exasperate behaviours to such a degree, that they get defined as diseases or disorders under the umbrella of addiction.

Two basic premises came up that were suggested to lie at the core of pathological addictive behaviour:

Structural chages in the brain reward circuitry:

A process involving hypersensitization of the dopamine release process, that leads to overactivative reward pathways (and the physical tolerance-withdrawal cycle) and at the same time loss of activity in the regions that reguate things like impulse control. It has been suggested that the brain scans of these two regions is a reliable way of testing for the presence of addiction. This is kind of a potential objective measure which could be used, unfortunately it seems quite hard to implement on a larger scale, so the prevalence of subjective measures based on mostly frequency of use persist. But it does have some very interesting implications in comparing for instance different nicotine products and their effects on the functionality of the brain.

Chronic dysphoria:

Dysphoria refers to a sort of feeling of social unease, restlessness and is a source of fairly high stress. Others spell this out in with examples, like lack and dysfunctional social connections. It has been long established that functional social networks and relationships are a great resource for not only relapse prevention and helping people with problematic use, but protective against susceptibility for the development of problems in the first place. Dysphoria also seems to exasperate existing problems, due to an increased need to "self-medicate".

The concepts around dysphoria are a great interest to me, and I've touched on similar things in this blog in the past on some thoughts on "creating" addicts by conjuring a problem out of thin air in people that do not actually have addictive behaviour. What I got to thinking during the lectures is somewhat along the same lines of that, but involving the people that are actually addicted.

It seems clear, that if dysphoria is a driving factor in problematic use, then the de-normalization efforts of shame and stigma in reality are not just immoral. They are extremely counter-productive, possibly making the existing problems much worse. 

Potentially so much worse, that it's entirely possible the intentionally created social discomfort and anxiety is potentially acting as a cause of moving to more dangerous, even deadly behaviours AND making them worse.

A self-fulfilling profecy if you will, as low risk product use is generally opposed on the back of this effect happening caused by the product use itself.

A core rule of any policy and regulation measures is (or should be), that the action is weighed against inaction and trying to analyze which option is actually beneficial.

This, simply does not exist in the field of tobacco control. They seem to want any and all possible restrictions they can possibly think of, regardless of the consequences. And if the stick doesn't work, get a bigger stick with more pointy things on it.

it's a steep hill to climb, but I do hope we can get to a point, where people can be treated as human beings again.

As for THR-product use.. My hypothesis so far is that for instance vaping should likely have a fairly radical difference to smoking in the measures for both the addiction inventory questionnaires (excluding things like FTND, which is useless for vaping) but also in the decreases and increases of brain activity potentially associated with addiction.

I would love to see that study!

Maybe then we could see some of the intentional creation of dysphoria fade away and start being rational about nicotine use in a wider scale, not just the echo chambers of advocates.

Part 12: Conflicts of self-interest

Two days ago, I dropped a gofundme page (https://www.gofundme.com/deetwo7) on twitter, after a long time of thinking about doing it and two more weeks of not telling anybody about it. 

Asking for financial help, even when it became absolutely necessary, while doing something I'm perfectly willing to do for free felt weird. It still feels weird.

Advocacy is something that feels like you do because there's a passion and necessity, and getting paid for that is somehow antithetical to the whole idea. But that does get me thinking.. why is there so much assumed conflict of interest in this area?

Anti-tobacco crusaders and various other public health advocates that oppose nicotine use generally tend to be actually paid to do that. They generally work in healthcare or NGOs that drive health-related political agendas. 

And they often seem genuinely surprised people on the other side are not paid by anybody. So much that they might not even believe it, and resort to some form of financial incentive blame game.

Why doesn't the same standards apply to them?

Why do I have this idea in my head that getting something in return for hundreds of hours of work is somehow "wrong"? I'm honestly not entirely sure.

And if the financial angle fails, the final determination in their chain of logic seems to be "you're just addicted". And everybody "knows" you can't trust an addict.

But addiction can only be measured by asking the addict about their behaviour. No truly objective measure or test exists for the determination. There's no machine that can detect addiction, no kind of physical biomarkers that could be investigated.

So, if an addict cannot be trusted, can the tests be trusted?

Is "you're just addicted" even a meaningful argument anyway? Because even if they are, that certainly does not mean they are lying or wrong. It just means a very subjective set of criteria happens to match their behavioural patterns, without necessarily meaning problematic use.

Is addiction a conflict of interest, if it cannot even be meaningfully defined?

What I wonder is, how deep is the (for the lack of a better word) "brainwashing" of temperance movements, that even me as a fairly libertarian advocate have these notions coloring my perceptions of doing this work..

I'm quite certain that promotion of THR is helping reduce the burden of death and disease and I'd like to think I'm having some sort of impact, but still there's a feeling of embarrasment lurking at the back of my head when I'm asking for financial help.

Intellectually, it's quite strange and counter-intuitive. Really feels like being forced to play by the rules of zealots and having no say in what's actually rational. The kind of influential manipulation scheme the tobacco companies can only dream of.

Tobacco control really is an inherently dishonest field.

And as a more positive note, enormous thanks to everybody who has helped. Got a LOT of stress off my shoulders.